Category Archives: Safety

Pipe Storage: Write to PHMSA

Bill Limpert in Bath County has written to the Pipeline and Hazardous Materials Safety Administration (PHMSA), the US Department of Transportation agency responsible for developing and enforcing regulations for the safe, reliable, and environmentally sound operation of the nation’s pipeline infrastructure. With his permission, we are sharing his letter.  He urges others to write their own letters to PHMSA about the long term storage issues with pipes, and the many reasons we know pipe cannot be stockpiled or stored long-term without grave consequences.

Send letters to:
Pipeline and Hazardous Materials Safety Administration
820 Bear Tavern Road
West Trenton, NJ 08628
Attn: Robert Burrough, Acting Director, Eastern Region

Here is Bill Limpert’s excellent letter:

Pipeline and Hazardous Materials Safety Administration
820 Bear Tavern Road
West Trenton, NJ 08628
Attn: Robert Burrough
Acting Director, Eastern Region
Re: Atlantic Coast Pipeline Pipe Safety
April 17, 2018

Dear Mr. Burrough:

I am writing to you to request a PHMSA investigation into unsafe storage practices, and other safety concerns regarding the pipes that are proposed for the Atlantic Coast Pipeline.

I am concerned about the protective corrosion prevention coating on the pipes being damaged by exposure to sunlight, or by other means, including vandalism, or contact with other stored pipes. I am also concerned about the use of cheap foreign steel in these pipes.

Dura Bond advises that the pipes for the ACP were produced from late 2015 through March, 2017. So all of the pipes are over a year old, and some are over two years old. The ACP is already a year behind schedule, and has not received all necessary permits to begin construction. Even under the revised schedule, some of these pipes will not be placed into the ground until late 2019, and that optimistic time frame remains uncertain.

I have been advised that Dura-Bond, the manufacturer of the pipes for the Atlantic Coast Pipeline, states that the pipes should not be left in sunlight for more than 9
months, and we are already well past that time frame.

Pipes for the Atlantic Coast Pipeline were found to be stored outside, in direct sunlight, and subject to other adverse weather conditions in Charlottesville Virginia as early as July of 2016. These pipes were also in an unsecured location where vandals or others could access and damage them.

I have seen images of a very large pipe storage location in an open field near Beckley, West Virginia, near the intersection of Routes 19 and I-77. These images can be found on the cover and first page of the April/May 2018 edition of The Appalachian Voice. These images show very large pipes stacked 4 high, and likely in direct contact with pipes above, below, and on either side. I am concerned that this apparent direct contact with other very heavy pipes will damage the exterior corrosion protection.

I am also concerned about foreign steel in the ACP pipes, and I recall that PHMSA was forced to require replacement of foreign steel pipes some years ago due to inferior and unsafe steel.

Joseph Klesin of your office kindly visited us on October 31, 2017, and we enjoyed spending time with him. I discussed my concerns with pipes stored in the open at that time. Mr. Klesin advised that pipes stored in the open for one year would probably lose 1 or 2 millimeters of external corrosion protection due to exposure to sunlight. He advised that this was within the acceptable safety range of corrosion protection loss. He further advised that leaving pipes exposed to sunlight for two years would constitute an unacceptable safety risk.

During that visit Mr. Klesin also advised that pipeline companies are not required to backfill the pipeline trench with soil, as is shown on the typical drawings in the Federal Energy Regulatory Commission’s environmental impact statement for the Atlantic Coast Pipeline. He stated that the trench could be backfilled with crushed rock. This conversation was prompted by my pointing out that there is very little soil on the proposed 3,000 foot long path of the Atlantic Coast Pipeline on steep and narrow Miracle Ridge on my property. I believe that crushed rock could damage the pipe’s external corrosion protection in any location, and particularly under the pressure of 25 feet of rock overburden in a trench on an extremely steep slope of up to 58% as would be required to place the pipeline through our property. Similar extreme conditions exist elsewhere in Western Virginia and West Virginia.

Please investigate and advise me of the following:

– Where are the pipes for the ACP being stored, and are they exposed to sunlight?
– Are the pipes in contact with one another?- How long have the pipes been stored? Please advise the various ages of pipe by percentage and type of pipe.
– Does Dura Bond recommend that the pipes be put into service within 9 months of manufacture, or other recommendations for storage prior to being put into service?
– What type of corrosion protection is used on the pipe? Please specify manufacturer and name of product. If the type of corrosion protection varies, please advise how it varies per the type of pipe and the location where the pipe will be placed.
– What is the maximum operating temperature of the pipe at 1.5 bcf/d, 2.0 bcf/d, and 2.25 bcf/d?
– Has any consideration been given to increased pipe temperatures due to heated groundwater in some karst areas? There is a large active hot spring near our home.
– What pipe is made of foreign steel, what is the country or countries of origin, and where will that pipe be located?

These issues are very important to my wife and I, our neighbors, and many others in the zone of incineration, the evacuation zone, and otherwise on, or near the Atlantic Coast Pipeline.

The extreme terrain in our area, and other areas of Western Virginia and West Virginia makes pipeline safety even more important. The pipeline would be placed on our property and in Little Valley on extreme slopes with recent landslides within several hundred feet of the route, narrow ridges, karst terrain with sinkholes, and under Little Valley Run, which recently flooded, and deposited many large boulders that relocated the channel within 200 feet of the proposed crossing. Just two days ago another large flood resulted in out of bank flow on many of the proposed stream crossings in our area. As we have previously advised, my wife and I, and a number of our neighbors are located in the zone of incineration for the pipeline, and we would be trapped in the evacuation zone at the head of the valley if we initially survived a pipeline incident, with no chance of rescue.

Additionally, the reduced pipeline safety regulations, remoteness, and fewer emergency response resources for rural areas like ours leave us at greater risk that those in more populated areas.

In my opinion, the Atlantic Coast Pipeline has been less than professional and forthright in their response to the many responsibilities they have in preparing to undertake this dangerous project. In case after case, they have failed to provide needed information and analysis to regulatory agencies. They have repeatedly cut corners to their benefit, and at public expense. I am concerned that they are doing the same regarding pipeline safety.

Please note that I am still attempting to have Dominion conduct a geohazard survey on our property, and I will be sending yet another letter to Dominion to try to accomplish that. Should Dominion finally make that inspection, I will advise you and Mr. Klesin. Mr. Klesin previously advised that he would like to participate in that inspection, and I would like him, or another PHMSA representative to be there if at all possible.

Thank you again for your assistance, and your public service.

Volunteers, Citizens Deserve Information

In an April 4, 2018, editorial, The Recorder reminds us of something we all know already: “Openness and transparency are not Dominion Energy’s strong suits, as we’ve learned over the last four years. It just doesn’t seem to share well with others.” The editorial discusses The Recorder‘s efforts to have a reporter attend a Bath County meeting to discuss the how-to details of responding to emergencies related to Dominion’s proposed Atlantic Coast Pipeline construction and operation.  Dominion first closed the March 20, 2018, meeting to the public, then (after the finally agreeing a reporter could attend) cancelling the meeting, then hurriedly rescheduling a hush-hush meeting in a venue over which Dominion had control of attendees and thus could deny attendance by press and public.

The Recorder says, “To their credit, both Dominion and EMS representatives offered to give us the meeting details later, which they did, but it’s much harder to report the facts and discussion when a reporter is not there to hear context and perspective.

“Emergency rescue and fire volunteers have said dozens of times that understanding the essential plans for handling any emergency during and after pipeline construction was critical to their knowledge base.

“What personnel will Dominion have on hand while construction takes place? What are their skills and certifications? What kind of personnel does Bath County need to augment its own volunteer base? Who responds first? Do our rescue squads, first responders, deputies, and firefighters have the right kind of equipment to handle sudden illness, fire, or accidents in the rough mountain terrain where this pipeline is planned? If there is extra or specialized training needed, will Bath County be able to secure that before construction starts?

“Some of these questions were answered last week; some were not.

“There are dozens of important questions, and neighboring residents want to know these things, too. Everyone needs assurance our county is prepared for the kinds of emergencies that have not arisen here before.

“Bath County citizens, and especially emergency volunteers, deserve answers. We are encouraged that last week’s meeting provided some answers and put a few minds at ease.

“But we are endlessly discouraged that Dominion makes getting answers so difficult for the general public.

“It’s not like these are state secrets, folks. Open up.”

Natural Gas Is Bad for Virginia

In a Letter to the Editor of the Roanoke Times, Jennifer Sims summarizes the “ruinous public policy described in the Jan. 26 commentary ‘Expanding access to natural gas is smart public policy.'” She points out that:

  • Instead of carbon, liquid natural gas (LNG) emits methane, a dangerous heat-producing greenhouse gas, and that the MVP and ACP “would produce the equivalent of 20+ coal plants in terms of greenhouse gases.”
  • The fracked natural gas in the MVP and ACP will NOT be available to anyone in the 20 counties through which the pipelines pass, but is destined for existing and new export contracts.
  • The fracked natural gas is NOT “safe, clean, reliable, affordable and abundant,” as the January 26 opinion piece claimed. Distribution pipelines have about 150 incidents or accidents each year; “ratepayers will be forced to foot the construction bill, business and landowners along both paths will have their private property seized and devalued and we will see a significant loss in tourism revenue.”

She concludes, “it is not a good public policy to introduce 1,000 miles of sediment dumps and herbicides into waterways, miles of mountaintop removal, abuse of eminent domain, loss of tourism revenue and pollution-emitting compressor stations into our Commonwealth.”

About Pipelines: The Short Form

A summary sheet prepared by Water Is Life. Protect It.

The Mountain Valley and Atlantic Coast fracked gas pipelines:

-are not needed by, nor will they bring energy to, the communities whose water and safety they threaten.

-will increase the cost of natural gas to Virginia ratepayers, first because of unneeded costly new infrastructure and later because the march to the sea for export will raise domestic natural gas prices 2 to 3 times.

-represent an immoral and illegal use of eminent domain to seize private land for corporate gain and not common good.

-are a clear and documented threat to the drinking water of over 12 million people either as a result of increased sedimentation from construction or from operational leaks of gas and fracking chemicals.

will not create local permanent jobs or even temporary local construction jobs.

-will more than double the greenhouse gas emissions for the Commonwealth of Virginia.

-against all scientific advice and warning, will be built over karst terrain, a geologic structure that produces most of our region’s clear pure water, but that is subject to sudden and unpredictable sinkholes and unexpected water connections and damages.

-pose a significant and documented risk of explosion and fire in their blast zones of 2,200 feet

-have and will continue to lower the value of any land they are on.

-represent stark environmental racism (especially the placement of the proposed Buckingham Compressor Station and routing through Native American lands) and environmental classism (targeting communities struggling with poverty and job loss).

-will reject the less costly and efficient upgrade of existing lines now running at less than real capacity in order to bring their developers a guaranteed profit of 15% on new energy infrastructure (MVP & ACP together well over 10 billion and rising).

-have revealed via their rushed and incomplete permitting and review processes, a level of corruption in Virginia government and regulatory agencies that is shocking and dangerous.

Residents Weigh in on Pipeline

In this March 2, 2018, article from the Franklin News-Post is about Boones Mill residents in the path of the Mountain Valley Pipeline. But what they say about the MVP and how they have been treated by its builders could be said by anyone on the path of the Atlantic Coast Pipeline as well.

“‘The more that you know about this, and we have been going to meetings for three-and-a-half years, the more frightening it is,’ she said. ‘And it’s all negative. Every single bit of it is negative.'” Another landowner said, “‘They said they had the right to do anything they wanted any time they wanted and tried to make it out like they were our friends and they were working in the best interest of everybody,’ he said. He said the letters were full of legal jargon and that ‘it takes a lawyer to figure out what they were talking about and to understand it.’ He and his wife got so fed up that they told MVP any further correspondence has to go through their attorney.”

Then there is the dubious letter-writing campaign. “After getting phone calls purportedly from the Mountain Valley Pipeline asking whether they support the natural gas project, area residents received pre-written letters to the editor in the mail they could then send to the newspaper, according to recent interviews with people involved. At least three people in the region who received such letters in the mail signed and sent the missives for publication, but it’s not clear who actually wrote and originally mailed the correspondence. MVP’s Cox said she wasn’t aware of any such letters.Pittsburgh-based MVP did not claim any knowledge of the letter-writing campaign. …. ‘I am not aware of any letters being sent by landowners/community members at the request of Mountain Valley Pipeline and I can confirm that these letters did not originate from my office,’ Cox said in an email.”

The article also addresses concerns of local law enforcement. “Boones Mill Police Chief Dennis Deacon has not been contacted by MVP, but said he is very aware of the influx of workers and traffic coming into town. ‘I’m worried about the number of people who don’t have roots here and the type of people that follow these camps,’ he said. He said there is an agreement between the police department, the sheriff’s office and Virginia State Police if additional manpower is needed in case there is a disruption in town.”

“[County Supervisor Ronnie] Thompson said it’s hard to prepare for the unknown, and he’s concerned about ‘the big ugly scar that’s going to be cut through our county that’s never going to go away.’ He sees more negative aspects than positives including gas line explosions, family farms being ruined, property values decreasing and pollution of the groundwater — all of the same concerns voiced by some citizens of the town.”

Everything in the article, including the words of the MVP spokesperson (who could easily be interchangeable with ACP spokesperson Aaron Ruby) is very familiar to people in the path of the ACP.

PA DEP Suspends Mariner East 2 Construction Permits

Another example – in Pennsylvania – of a pipeline infrastructure project failing to implement promised safeguards. The Pennsylvania Department of Environmental Protection (DEP) has issued an order suspending the construction permits associated with the Mariner East 2 pipeline in southern PA until the permittee, Sunoco Pipeline, L.P. (Sunoco) meets the requirements outlined in the order. Sunoco must cease all construction activity on the pipeline project, except for maintenance of erosion controls and limited maintenance of horizontal directional drilling equipment.

The DEP cited a series of spills and other “egregious and willful violations” of state law. “Until Sunoco can demonstrate that the permit conditions can and will be followed, DEP has no alternative but to suspend the permits,” said DEP Secretary Patrick McDonnell. “We are living up to our promise to hold this project accountable to the strong protections in the permits.”

Read the announcement from the PA DEP here. It includes a links to the full DEP order and to a list of the violations issued to Sunoco.  Press coverage on is here.