Category Archives: Pipes

Pipe Coatings

In a letter to FERC,submitted as a Motion to Intervene on September 16, 2019, Bill Limpert discusses Dominion’s July 22 and August 23 reports to the Federal Energy Regulatory Commission (FERC). The Dominion reports were in response to FERC’s July 3 request for data regarding possible environmental and health impacts from the 3M Scotchkote Fusion Bonded Epoxy 6233 external pipe coating, and other pipe coating products used for the Atlantic Coast Pipeline.

Limpert says, “I believe Dominion’s reports significantly understate the risk to public health and the environment from this coating, and other products used on the exterior of the pipe. I believe the reports use questionable data, and questionable methodologies to arrive at unreliable conclusions, and therefore, do not adequately answer the FERC’s request for information, or the concerns raised by the Virginia Department of Health.”

Limpert then critiques Dominion’s July 22 report in detail, covering the lack of leaching studies, the impacts of degradation and the long-term health impacts.

He states, “The Dominion reports use questionable data and questionable methodologies to arrive at unreliable conclusions. They do not prove the pipeline coating is safe, or that there will be no negative health or environmental impacts from the coating and associated products used on the exterior of the pipes for the ACP. They do not reliably answer the questions presented in FERC’s request, nor the concerns of the Virginia Department of Health.”

Limpert’s critique of the July 22 report concludes with a list of recommendations for actions FERC should take, including additional study using valid data and methodology, consultation with federal agencies with expertise, advising the US Fish and Wildlife Service that a 3M Material Declaration states that UV degradation byproducts will be toxic to aquatic life, requiring ACP to conduct pre and post construction sampling for chemicals associated with this coating and other products used on the exterior of the pipes in drinking water wells and springs in the vicinity of the proposed pipeline, requiring ACP to provide a potable water source and fair compensation for drinking water sources that are contaminated by these products, and requiring that all pipes be immediately covered to prevent UV degradation material from becoming airborne.

Limpert also writes a detailed critique of Dominion’s August 23 report.

Read the full letter and the attachments to it here.

Dominion Responds to FERC Request on Pipe Coatings

On July 3, 2019, the Federal Energy Regulatory Commission (FERC) requested that the Atlantic Coast Pipeline, LLC and Dominion Transmission, Inc. provide within 20 days toxicological environmental and health information on epoxy coatings associated with pipeline materials used in the Atlantic Coast Pipeline. (see FERC Requests Toxicological Info on ACP Coatings)

On July 22, 2019, Dominion filed a response to FERC’s request – a two page covering letter, a two page response, and 315 pages of attachments, most of which are safety data sheets (SDS) from manufacturers.

In their covering letter, Dominion says the SDS information “is based on the products’ hazards before they are reacted and cured on the pipe. The warnings are based on the presence of substances at very low amounts in the powder or liquid prior to application and cure. According to the manufacturers, these substances are expected to be encapsulated in the polymer matrix when the coating is applied and fully cured onto the pipe and would be dispersed throughout the coating and not migrate onto the surface or leach out of the coating.” We note the careful wording: safety data sheets are based on hazards before they are cured on the pipe, and the substances “are expected to be encapsulated” when fully cured.  Nothing about hazards after coatings have been exposed to UV and to weather for 3-4 years.

Continuing, the letter discusses two different 3M coatings, and says, “Although 3M has no conclusive evidence at this time to confirm their exact identity, the degradation products are generated in low quantities, have low water solubility, and are therefore not expected to enter the environment in amounts capable of producing an adverse human health effect.” Again, note the language” “no conclusive evidence at this time to confirm their exact identity,” and “not expected to enter the environment.”

Dominion says they will be doing evaluation of “composition, toxicity, and potential for environmental exposure” of the primary 3M coating, and will submit results by August 23, 2019.

FERC Requests Toxicological Info on ACP Coatings

On July 3, 2019, the Federal Energy Regulatory Commission (FERC) requested that the Atlantic Coast Pipeline, LLC and Dominion Transmission, Inc. provide within 20 days toxicological environmental and health information on epoxy coatings associated with pipeline materials used in the Atlantic Coast Pipeline. The operative language in the request is:

Please provide toxicological environmental and health information for Fusion Bonded Epoxy (FBE) coatings (3M™ ScotchkoteTM Fusion Bonded Epoxy Coatings and 3M™ ScotchkoteTM Liquid Epoxy Coatings, or their equivalents) used for coating the project’s pipeline and associated utilities. Evaluate and report on the toxicity of the FBE from all potential exposure pathways including from direct and indirect human contact, ingestion or inhalation; as well as environmental pathways (leachability and mobility) in air, soils, surface water, and groundwater. The evaluation should likewise include an analysis of human and environmental exposure from the degradation of FBE due to exposure to sunlight, and sloughing (chalking) of the material.

FERC’s full request is here.

Progressive Pulse news coverage is here.

Safety Threats of ACP Highlighted to PHMSA

From Allegheny-Blue Ridge Alliance’s ABRA Update 233 for June 14, 2019:

No further work on the Atlantic Coast Pipeline should occur until safety threats can be fully assessed and remedied according to a comprehensive letter sent this week to the Pipeline and Hazardous Materials Safety Administration (PHMSA), an agency of the U.S. Department of Transportation.

In a June 10 letter to PHMSA Administrator Howard Elliott, William Limpert, a Bath County, VA landowner whose property would be adversely impacted by the ACP and who is a member of ABRA’s Steering Committee, warned about the “threat to public safety from the ACP from landslides and earth movement, but other public safety concerns exist as well. These include risks from flooding, karst terrain, difficult construction in extreme terrain, and degradation of the pipe exterior corrosion protection from excessive exposure to sunlight during storage.”

Continuing, Limpert wrote:

“I am aware that FERC approves the siting of interstate natural gas pipelines, and that FERC allows an operator’s hired consultant to perform a geohazard assessment. This puts PHMSA in the unenviable position of insuring public safety on a project that PHMSA neither approves nor assesses for geohazards. That, along with the current proliferation of new natural gas pipelines, and your limited staff makes your job a difficult one. Nevertheless, I believe that you have the authority to adequately protect the public safety if you act aggressively, use all of the tools at your disposal, and do not allow the industry to control your agenda.

“I appreciate the recent PHMSA Advisory Bulletin ADB-2019-02 regarding the threat to pipelines from landslides, earth movement, and other geological hazards. The bulletin lists a large number of recent pipeline failures. These failures indicate that current practices are not sufficient to protect the public safety., especially from a project as fraught with peril as the ACP. I applaud the comprehensive list of suggestions to operators in the bulletin to improve safety. Nevertheless, I believe that most operators will not act on PHMSA suggestions. I believe that PHMSA needs to require operators to make safety upgrades, or they won’t be done.”

Pipe Storage Risks

Bill Limpert’s column in the Richmond Times-Dispatch for February 28, 2019, Pipelines put health and environment at risk – and we don’t need them anyway, discusses the risks from the pipes themselves, pipes that have now been stored outdoors, exposed to weather, for far longer than expected and far longer than manufacturers recommend.

Limpert lists the issues with the pipes:

  • Pipes for both ACP and MVP are coated with a fusion bonded epoxy (FBE) to reduce pipe corrosion and explosion risk that degrades when exposed to sunlight and is now chalking off the pipes. “The National Association of Pipe Coating Manufacturers Bulletin 12-78-04 recommends that pipes coated with FBE without additional protection be stored no more than six months in the sun. The ACP admits that all of their pipes will be stored much longer than that, and even longer than the recommendation of pipe manufacturer Dura-Bond. The MVP testified in court that they were concerned about FBE loss.” At this point, ACP pipes have been stored outside for approximately three years, and will continue to be stored outside while the project is on hold.
  • The federal Pipeline and Hazardous Materials Safety Administration (PHMSA) confirms that FBE is coming off the pipes, yet maintains the pipes are safe – but they won’t divulge how many of the estimated 80,000 ACP pipes have been inspected, won’t give any detailed inspection information, and say that no inspection results will be available until the ACP is completed. [In other words, we won’t tell you anything about safety of the pipes until the construction that uses them is finished!]
  • “The Material Safety Data Sheet for the 3M Scotchkote Fusion Bonded Epoxy 6233 used on these pipes lists carcinogenic, mutagenic, and toxic properties. Health impacts include reproductive, developmental, and respiratory impairment.” The material coming off the pipes is now in the environment, and most likely in “the surface and ground waters, and is being ingested through drinking water, especially by persons in karst areas using wells and springs for their drinking water.”

And while the pipelines are delayed, the pipes continue to sit, exposed to sun and all kinds of adverse weather.

Further information on the hazards of long-term storage of pipe segments is in our previous articles on the topic, see PHMSA and the Safe Storage of Pipe, posted on June 21, 2018, and Pipe Storage: Write to PHMSA, posted on April 23. 2018.  See also Pipeline Chemical Coatings Are Serious Concerns, from NRDC in October 2018.  Even in April, June, and October, the pipes had been stored outside for longer than their recommended time – and now it has been even longer!

Flood Carries MVP Pipe Section Off Site

The Roanoke Times reported on October 12, 2018, that flooding from rains the day before carried two 80-foot sections of pipe off the Mountain Valley Pipeline’s right of way onto Dale Angle’s land.   The sections had been left in the right of way before being set in the nearby trench.  “Both had clearly crossed a boundary line drawn earlier this year when Mountain Valley used its legal power of eminent domain to obtain an easement through Angle’s land, despite his fervent opposition.”

Although construction crews can do what then want on the easement, they must have permission to enter a landowner’s adjoining property.

“‘They called this morning wanting me to sign a permission slip’ that would allow company workers onto his property to retrieve two 80-foot sections of steel pipe that floated away, Angle said Friday. ‘I said I couldn’t do it right now. They’ve done destroyed enough of my property. I’m not going to let them do it again.'”

An MVP Spokesperson had few details about how the company might reclaim the lost pipe.

Read the full article here.