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.