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Experts Concerned by MVP Coating Integrity

TUESDAY, SEPTEMBER 13, 2022


With pipes intended for the long-delayed Mountain Valley Pipeline stored above ground for years, concerns have been raised by residents and experts regarding the coatings, corrosion and the safety of the pipes.

The news arrives a month after the Federal Energy Regulatory Commission approved a new deadline for the project, with the deadline for completion of the natural gas pipeline arriving at Oct. 13, 2026. As of last month, the project was reportedly at 94% completion.

First approved in 2017, the project has been delayed by opposition, lawsuits and violations on construction sites over environmental regulations.

Coating Concerns

Back in 2018, a company executive reportedly explained why it was important that construction begin as soon as possible, citing that sections of pipe already purchased needed to be buried before sunlight could break down an epoxy coating safeguarding the steel from corrosion.

“The coating needs to be protected,” Robert Cooper, the company’s vice president for engineering and construction, testified. “You have to do that very carefully.”

However, according to reports, those pipes have still not been buried and are sitting on top of Bent Mountain. One pipe segments reportedly has a stamp that reads “Date of coating: 8/25/2017,” with several others stamped for the same month.

According to industry standards, these kinds of pipes should not be stored above ground for more than six months, unless additional coating is applied. Exposure to the elements can make the pipe more vulnerable once it’s buried, leading to a leak, rupture or explosion.

Public comments from concerned individuals and organizations were made to FERC this summer regarding the exposed coating. FERC responded in an Aug. 23 order that the pipe would have to be inspected before installation.

“And therefore the concerns raised by commenters on this matter do not justify additional analysis,” the order stated.

“Given what I’ve seen of this project, the public is raising valid concerns, and they need answers to those concerns,” said Richard Kuprewicz, an independent pipeline safety expert who is president of Accufacts Inc., a consulting firm in Redmond, Washington.

Mountain Valley spokesperson Natalie Cox told The Roanoke-Times in an email that the company understands that sunlight has changed the pipe’s exterior from shiny green to a chalky and whitish-green appearance. They have reportedly developed a plan to ensure that the coating is not compromised.

“First and foremost, the safe construction and operation of the MVP project remains our top priority,” she said.

Mountain Valley said it “continuously surveys and monitors” sections of above-grade pipe that is either in storage yards or along the right of way.

“Any damaged coating or coating thin spots are repaired prior to installation, or the pipe segment is not installed,” Cox wrote. “All of the pipes shipped to the ROW [right of way] have continued to meet specification. The pipes will continue to be checked to identify any issues that need to be addressed prior to the pipe being placed in the ditch and backfilled.”

However, standards for inspections do not include detailed specifications on how to gauge the coating’s condition, Kuprewicz said, adding that it’s “probably in terrible shape” but doesn’t “prevent the operator from putting it in service.”

“The regulations are written to largely allow the operator to determine if the coating is appropriate as opposed to prescribing exactly what would make a coating safe or unsafe,” said Bill Caram, executive director of Pipeline Safety Trust

Last month, a new rule was issued by the Pipeline and Hazardous Materials Safety Administration to strengthen the safety and environmental protection of more than 300,000 miles of onshore gas transmission pipelines. The rule was transmitted to the Federal Register on Aug. 4.

According to the PHMSA’s release, the rule was first initiated 11 years ago and incorporates lessons learned through the investigation of the San Bruno gas transmission pipeline explosion in 2010. The final rule establishes standards for identifying threats, potential failures and worst-case scenarios from an initial failure through conclusion of an incident.

Pipeline operators conduct inspections before installation, but a pipe’s coating can be damaged later when it’s lowered into a trench. The new regulations call for additional tests to be done after the pipe is underground, which Mountain Valley is planning to employ the high-voltage technology to test the pipe before it goes into service and regularly after that, Cox said.

Kuprewicz said that pipe coatings should work hand in hand with cathodic protection, which uses electrochemical reactions that occur within the soil around the pipe to reduce the likelihood of corrosion. The pipe is coupled to buried anodes, which consist of magnesium or other reactive metals, and an electrical current shifts corrosion away from the pipe and to the anodes.

According to Cox, some of the Mountain Valley pipe already has permanent cathodic protection in place. More than 400 temporary systems have reportedly been installed next to shorter buried segments until the pipe can be connected to an overall network.

Mountain Valley said the coatings will be inspected for any damage or deterioration using a holiday detector, utilizing an electrical current to detect flaws that might not be visible to the naked eye. Then it will be placed in the trench and covered with dirt.

However, William Limpert, formerly of the Maryland Department of Environment said that the holiday detector they plan to use will not detect failed coating flexibility or uptake of corrosion causing chemicals.

“These are coating deficiencies that are also caused by leaving the pipe exposed. A pipeline expert advises that if the coating is not flexible, it won’t stand a chance during pipe bending, or other pipe stresses,” he said. “The presence of chlorides and other corrosive substances in the coating would also indicate that it is unacceptable.”

Limpert added that they couldn’t repair damaged coating or thin spots prior to installation, and that damaged pipe must be discarded or returned to the factory for recoating. He said tests must also look at loss of coating flexibility, uptake of contaminants, coating adherence to the pipe, as well as testing for holes, and coating thickness.

“An MVP explosion would be catastrophic. It would dwarf the horrific San Bruno pipeline explosion which killed eight people, injured 60, left a crater 72 feet long and 26 feet wide, threw a 3,000 pound segment of pipe 100 feet from the crater, and had a reported 1,000 foot high fireball,” he explained.

“That was a 30 inch pipe, with a maximum operating pressure of 400 pounds per square inch. The MVP is a 42 inch pipe with a maximum operating pressure of 1,400 pounds per square inch.”

Mountain Valley Pipeline History

The pipeline is owned and being constructed by Mountain Valley Pipeline LLC—a joint venture between EQT Midstream Partners LP, NextEra US Gas Assets LLC, Con Edison Transmission Inc., WGL Midstream and RGC Midstream LLC. Once complete, the pipeline is slated to be operated by EQT Midstream Partners.

The Mountain Valley Pipeline is expected to run from northwestern West Virginia to southern Virginia, cutting through the Jefferson National Forest. The project is the smaller of two currently underway in the state of Virginia; the other is the Atlantic Coast Pipeline, which is twice as long and passes through the center of the state but does not cut through Jefferson National Forest.

On July 27, 2018, an order from the U.S. Court of Appeals for the Fourth Circuit turned over prior decisions made by the Bureau of Land Management and the Forest Service authorizing construction of the 303-mile pipeline. In early August of that year, the U.S. Federal Regulatory Commission ordered work on the pipeline to cease, alleging that two U.S. agencies had not fully examined the projects.

A few months later, in October, the project was blocked yet again, but this time by the U.S. Army Corps of Engineers, suspending a permit that would allow the pipeline to cross more than 500 streams and wetlands in southwest Virginia. The following month, MVP filed an application with FERC for a 73-mile Southgate permit pipeline extension.

In mid-July 2019, FERC released a request for “toxicological, environmental and health information” from the Mountain Valley Pipeline’s corporate attorney regarding the coatings used on the project’s 42-inch diameter steel pipe. In August, project developers told federal regulators that the coating in question, specifically on stretches in Virginia and West Virginia, does not pose a threat of harm. Also, in August, the developers voluntarily suspended construction on stretches of the pipeline in light of a recent lawsuit that sought to address concerns about the project’s impact on local endangered species.

By October, work on the project ceased once again as the pipeline developer was ordered to pay $2.15 million to resolve a lawsuit brought on by Virginia regulators. In the lawsuit, the accusing party cited repeated violations of environmental standards. The agreement also required that the company submit court-ordered compliance to curb erosion and sedimentation.

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A lawsuit cited the project developer for the violation of stormwater control measures more than 300 times. Those flaws have reportedly been corrected and the company has agreed to certain conditions including independent inspections, but those carrying out the investigations must be monitors approved by the DEQ.

In light of the loss of so many permits, Del. Chris Hurst, D-Blacksburg, called for the stop-work order from FERC. Mountain Valley’s assistant general counsel, Matthew Eggerding, noted in a letter to FERC that pipeline installation had been completed in nearly all accessible areas, though this does not include the areas at issue. Otherwise, the company was still on schedule to complete stabilization and restoration work.

At the beginning of 2020, FERC released an environmental impact statement concluding that while an 75-mile-long extension into North Carolina—also known as the MVP Southgate Project—could cause some environmental damage, they were favorable of the project moving forward.

The Commission also noted that the potential environmental damages could be reduced to less-than-significant levels through avoidance, minimization and mitigation proposed by the developer and staff.

At the time of the announcement, MVP Southgate spokesperson Shawn Day reported that the $468 million project was expected to break ground sometime this year with completion slated for 2021.

Project officials also added that since the expansion was announced, the MVP team had made more than 1,200 adjustments to its route, mostly based on landowner requests, engineering considerations and efforts to avoid sensitive resources. The team says it remains committed to collaborating with a variety of stakeholders, including landowners, federal and state agencies, local governments, tribes, community groups and non-governmental organizations.

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In September 2020, on behalf of Mountain Valley Pipeline LLC, representing attorney Matthew Eggerding filed a letter with FERC in requesting that a stop-work order be lifted.

In the letter, Eggerding requested that FERC grant permission to resume all construction activities permitted by law of the over $5 billion pipeline by Sept. 25. The letter followed a reissued permit by the U.S. Fish and Wildlife Service earlier this month, stating that construction would not likely jeopardize protected species in the area.

However, according to The Roanoke Times, the joint venture still needed two key permits that were set aside after a federal appeals court sided with conservation groups. Following Eggerding’s request, the Sierra Club also issued a letter to FERC, writing that construction couldn’t commence until all federal authorizations were obtained. The letter—which included a notice of intent to sue the Army Corps—was written by senior attorney Elly Benson and was co-signed by other environmental groups.

In December last year, two water permits were approved for the pipeline, raising concerns over its impacts on the environment and sparking lawsuits including a Virginia State Water Control Board permit for the pipeline to cross about 150 streams and wetlands in Southwest Virginia and a West Virginia Department of Environmental Protection water quality permit.

Prior to having the Nationwide Permit 12 from the U.S. Army Corps of Engineers invalidated, more than half of the almost 1,000 stream and wetland crossings in the two states were completed. MVP sought an individual permit from the Army Corps, which could only be provided after state approval.

At the time, the MVP had 236 remaining stream crossings. The stream and river crossings approved by the board will be temporarily dammed and a trench will be dug for the buried 42-inch pipeline along the bottom, referred to as the open-cut method.

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Following the approval, opposition groups, including the Sierra Club and Appalachian Voices, filed a petition with the 4th U.S. Circuit Court of Appeals, citing that the pipeline should not be permitted to continue based on past violations. Mountain Valley officials responded saying the problems were largely caused by heavy rain in 2018 and have been corrected.

A few days later, the WVDEP approved the water quality permit for the pipeline. This permit was the final one needed before the Army Corps could move forward with dredge-and-fill permits in the states.

A similar lawsuit to the Virginia petition was filed at the beginning of the month over the West Virginia permit. The environmental and community groups argued that WVDEP violated the Clean Water Act by granting the permit.

Earlier this year, in April, the FERC issued an order approving changes proposed for the Mountain Valley Pipeline Project, including how the pipeline will cross 183 waterbodies and wetlands. The application was filed by Mountain Valley Pipeline LLC in February last year to amend the original 2017 certificate for the pipeline. The order allows the developer to bore under the bodies of water instead of using the originally approved open-cut method.

The current open-cut process, which involved digging a trench along the bottom of the waterbodies to by a 42-inch diameter pipe, will now be replaced with a tunneling method for the approved bodies of water.

The order was unanimously approved on April 8 by the FERC. According to the 72-page order, the amended application includes the following changes:

  • Change the crossing method for 183 waterbodies and wetlands at 120 locations (some locations contain more than one waterbody/wetland feature) from open-cut to trenchless;
  • Slightly shift the permanent right-of-way at mileposts (MP) 0.70 and 230.8 to avoid one wetland and one waterbody, respectively; and
  • Conduct 24-hour construction activities at eight trenchless crossings.

However, FERC said the decision does not change the commission’s prior findings on the need for the pipeline. The order notes that “any notice to proceed with construction” on the amended project “will only be issued upon Mountain Valley’s receipt of its outstanding federal authorizations.”

Multiple federal permits had reportedly been denied in previous months, and earlier in April FERC was pressed by judges about the agency’s decision in 2020 to give the developers two years to finish the project. A judge said it was “troubling” that FERC had not responded to a pending stop work order requested by environmental groups earlier this year.

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Tagged categories: Coating inspection; Coating Materials; Coatings; Corrosion; Health & Safety; Health and safety; Holidays; Inspection; Ongoing projects; Pipeline; Pipelines; Pipes; Program/Project Management; Quality control; Quality Control; Safety


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