Category Archives: Safety

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.

A Landslide Study of the ACP in Nelson


At the Friends of Nelson public meeting on June 30, 2019, Anne Witt, a Geohazards Geologist from the Virginia Department of Mines, Minerals and Energy, presented her work on a VDEM-FEMA Pre-Disaster Mitigation Grant Project. This project is to develop a risk assessment of landslides in western Albemarle and Nelson counties based on previous landslide events that occurred largely during Hurricane Camille. According to Ms. Witt, previous landslide locations are prone to having future ones.

The Grant Project consists of 4 parts or stages:

  1. Remote sensing of landslides in the study area using LIDAR (Light Detection and Ranging) scanning technology
  2. Geologic field mapping of landslide prone areas
  3. Landslide Susceptibility Mapping
  4. Presentation of data products and results to the planning community and the public

The project is presently in its first stage, so mapping is preliminary. However, LIDAR has revealed a larger number and a more accurate depiction of these previous landslides in Nelson County than seen before.

Friends of Nelson has overlaid the draft mapping of these landslides on the proposed Atlantic Coast Pipeline route. Doing so reveals how many of these slides are on or proximate to the route. Given the number and concentration of these debris flows, we feel that landowners and county officials should be aware of these past events in assessing future risk and mitigating it. Risk awareness is important given the immense amount of ground disturbance that would happen during pipeline construction and the significant potential for pipeline ruptures and explosions resulting from possible slide events afterwards.

In the figure above, approximately 60 debris flows (green triangles) and 10 debris slides (blue triangles) are on or near the ACP proposed route (in gold).

The figure below illustrates how LIDAR reveals the scope and path of previous slides that is not visible even with aerial photography in winter with no leaves on the trees.

See the short summary of Anne Witt’s talk here. Many thanks to Ms. Witt for sharing some of the slides from her fascinating presentation, and to Charlie Hickox for the summary and for the overlay showing the ACP route.

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.

Not One New Report, But Two


Not one, but two, recently released reports by physicians discuss and document the health risks, both immediate and long-range, of fracking and fracked gas.

A collaboration of health professionals with the Washington and Oregon chapters of Physicians for Social Responsibility have spent many months synthesizing and reviewing research and data, making new findings and conclusions on the threat of fracked gas infrastructure in the Pacific Northwest and how elected officials should respond to the crisis at hand. The report discusses impacts to fishing, safety hazards from facility and pipeline malfunctions, mental health stress on people who may lose their homes and jobs to eminent domain or habitat destruction, and more. Specific case studies include the Jordan Cove LNG project in Oregon and the Tacoma LNG facility and Kalama Methanol refinery in Washington State. Download a PDF of their report, Fracked Gas: A Threat to Healthy Communities. Press coverage is here.

Meanwhile, another review by doctors and scientists of 1,778 articles from peer-reviewed medical or scientific journals, investigative reports by journalists, and reports from government agencies on fracking concludes that the industry poses a threat to air, water, climate, and human health. Physicians for Social Responsibility and Concerned Health Professionals of New York, found that 69 percent of studies on water quality during the same time period found evidence of or potential for fracking-associated water contamination, and 87 percent of studies on air quality found “significant air pollutant emissions” associated with the industry. Their report also examines studies on the natural gas industry’s impact on climate change, and finds that due to methane leaks, natural gas extraction could be contributing to global warming even more than coal. Download their report, Compendium of Scientific, Medical, and Media Findings Demonstrating Risks and Harms of Fracking. Press coverage is here.

Note also the earlier 2017 report from Physicians for Social Responsibility, Too Dirty, Too Dangerous: Why health professionals reject natural gas.

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!