Category Archives: Pipes

Oil and Gas companies are making old pipelines the landowner’s problem.

From Popular Science. In the US private residents end up footing the bill to prevent further eyesores and pollution. March 10, 202.

There are some 3 million miles of natural gas pipelines buried in the US. More than half of all gas transmission lines in the country were installed before 1970, according to data from the Pipeline and Hazardous Material Safety Administration. Those pipelines have an average lifespan of 50 years. And it’s not just old pipelines that are set to go out of service. Younger pipelines are also at risk of falling into disuse as the power sector comes to rely less on natural gas in favor of wind, solar and batteries.


No clearer sign exists that that bridge has been crossed than the cancellation of several high profile natural gas pipeline projects in the last year, including the Atlantic Coast Pipeline and the Constitution Pipeline. What does that mean for the millions of miles of gas pipelines that are already in the ground?


The most comprehensive data on abandoned pipelines comes from Canada. In the 1980s, the Canadian government began an extensive study of abandoned pipelines, which identified a slew of serious risks to leaving them in place. Sinkholes could form as pipelines corroded and collapsed. Leftover fossil fuels, or the cleaning agents used to clear out lines, could leak out into the surrounding soil or water. Aging lines under lakes or rivers could carry water where it’s not wanted. Empty pipelines could also become slightly buoyant, relative to soil, and rise to the surface, where landscaping and signage marking a pipeline’s path is rarely maintained after it has been retired. It is not sure as to how the valving system of the pipelines have been in place, or whether the Butterfly Valves of the pipeline are still intact to keep them from spilling.


The Federal Energy Regulatory Commission (FERC) can order a pipeline company to remove a line that’s not in use, says Carolyn Elefant, an energy and eminent domain attorney, but it doesn’t always do so.


Pipeline companies have ample incentive to leave pipelines in the ground. Removal is expensive and requires heavy equipment, permits and environmental reviews. And pipelines laid before 1980 often have the added feature of an asbestos coating that must be dealt with. It can cost almost as much to get a pipeline out of the ground as it costs to put it in the ground.

Not Just Another Pipeline – The expansion of Enbridge’s Line 3 pipeline is a breathtaking betrayal of Minnesota’s Indigenous communities – and the environment.

From The New York Times. Minnesota Gov. signed off on final water permits for Enbridge to complete an expansion of its Line 3 Pipeline. December 28, 2020

The new section of pipeline will allow the pumping of oil sands and other forms of crude oil from Alberta to Wisconsin. It will cut through Indigenous treaty lands along the way. Despite pending lawsuits, construction has already started.


This is not just another pipeline, but a potential ‘climate bomb’ as it will facilitate the production of one of the most carbon-intensive fuels on the planate for decades to come. An environmental impact assessment of the project found the potential impact of the pipeline’s carbon output to be 193 million tons per year, the equivalent of 50 coal-fired plants or 38 million vehicles on the road.


In addition to this massive carbon cost, the destructive mining of the tar sands will affect the environment of Alberta’s boreal forests permanently. And if the pipelines leak, the sludgy mixture is almost impossible to clean up. The pipelines route will run through two watersheds draining directly into Lake Superior. The Great Lakes contain 84 percent of North America’s available freshwater and the pipeline is an existential threat to our water supply.


Young people are chaining themselves beneath pipeline trucks, clamping themselves to bulldozers, facing down semi trucks. It is unbearable. They know exactly what is at stake.

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.”