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Dear Senator Kaine:

I am hereby requesting that your office conduct an investigation into public safety
concerns regarding the pipes that are proposed for the Atlantic Coast Pipeline (ACP). I
believe that these pipes are unsafe due to their extended exposure to sunlight,
unsecured storage locations, contact with other large pipes, and foreign steel, which
may be inferior to US steel, used in their manufacture.

My concerns are further heightened by a number of other issues including the extreme
terrain in which the pipes would be placed, the lack of current qualified safety
inspectors, lax pipeline regulations, including reduced pipeline safety regulations in rural
areas, and the fact that the ACP is well behind schedule and will rush to catch up. The
tremendous explosive capacity of this pipeline further adds to the public safety risk.

Pipeline safety is governed by the federal Pipeline and Hazardous Materials Safety
Administration (PHMSA).

The leading cause of pipe failure in our country other than third party encroachment is
failure of the pipe external corrosion protection, resulting in corrosion, breaching of the
pipe, and subsequent explosion. Pipeline incidents that cause death, hospitalization,
extensive property damage, or large discharges of toxic substances occur on average
more than once per week in our country. Even more troubling, newer pipes are failing at
a higher rate than pipes built before 1940.

The pipes for the ACP were manufactured by Dura Bond, at their Steelton,
Pennsylvania site. Dura Bond has refused to respond to my inquiries. Nevertheless, I
have learned that Dura Bond recommends that their pipes be placed into service within
9 months of manufacture to avoid deterioration of the external corrosion protection by
sunlight.

The Dura Bond website indicates that the pipes for the ACP were produced from late
2015 through March, 2017. Therefore, 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 still 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, as much as 4
years after manufacture, and that optimistic time frame remains uncertain.

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.

A PHMSA representative has advised me 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 pipes exposed to sunlight for two years would
constitute an unacceptable safety risk.
Although these may not be the same pipes that would be used for the ACP, 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. They show
very large pipes stacked 4 high, in direct contact with pipes above, below, and on either
side. An eye witness account from an associate confirms direct contact. I am concerned
that direct contact with other very heavy pipes will damage the exterior corrosion
protection.

The same PHMSA inspector 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.

I am also concerned about foreign steel in the ACP pipes, previously hidden from the
public with the misleading statement by Dominion Energy, majority owner of the ACP,
that pipeline manufacture was 100% American. PHMSA was forced to require
replacement of foreign steel pipes some years ago due to inferior and unsafe steel.

The ACP is proposed to carry up to 1.5 billion cubic feet of gas per day, and is allowed
to reach 2.25 billion cubic feet of gas per day. This high volume and high speed
transmission heats up the pipe, and I have been told that the ground will never freeze
above the underground pipe. Dura Bond’s corrosion protection specifications state that
it can withstand temperatures of up to 230F, but tests showing protection above 170F
have not been substantiated. The ACP is proposed to travel through large areas of karst
terrain, including my property, and there is large hot spring a little over a mile from our
home. Karst specialists with the Virginia Department of Conservation and Recreation
(DCR) have indicated that groundwater flow from our area likely is discharged in that
spring. I am concerned that heated underground water will further heat the pipe, and
damage the external corrosion protection. DCR recommended that the pipeline be re-
routed away from this, and other karst areas, but Dominion and FERC have refused to
do so.

No pipeline of this size has ever been attempted in the extreme conditions of Western
Virginia and West Virginia, which include steep landslide prone mountains, flooding
rivers, and karst terrain, with active sinkholes. In fact, just 3 years ago 4 large landslides
occurred on our property and nearby properties within several hundred feet of the
proposed pipeline. The largest of these landslides is 500 feet long, 30 feet wide, and 7
feet deep. The upper end of this landslide extends within 250 feet of the center line of
the proposed pipeline at the top of very steep and narrow Little Mountain. The proposed
route also crosses active sinkholes on my neighbor’s property.

Due to the large amount of pipeline construction at this time, their is a lack of qualified
safety inspectors. Even the industry admits this. PHMSA remains short staffed with only
a little over 100 inspectors nationwide. The inspector who met with us in our Bath
County, Virginia location lives in the New York City metropolitan area.

Pipeline safety regulations are filled with what I call “escape clauses” that allow the
pipeline company to avoid measures to protect the public from the unsafe circumstance.
For example, a regulation states that pipeline companies, where practical, must avoid
crossing steep valleys where internal liquids could collect at the lowest point and
corrode the inside of the pipe. This is the case at our location in Little Valley.
Nevertheless, the ACP apparently feels that it is impractical to move the pipeline,
despite this obvious safety risk to my wife and I, and our neighbors.

When I showed the PHMSA representative the large landslide within several hundred
feet of the proposed pipeline in Little Valley he responded by saying that pipeline
companies can put pipelines just about wherever they want to now, and this is
consistent with the current Administration position on deregulation.

Pipeline safety regulations are also greatly reduced in rural areas. The reduction in
public safety includes thinner pipe walls, fewer welding inspections, less hydrostatic
testing, and further spaced segregating valve stations. The regulations also allow
pipelines to be built where the only egress for property owners in a pipeline emergency
is over the pipeline itself, with no contingency plans for how they would be rescued. All
of these conditions apply to our location as well, and rescue or escape for my wife and I,
and our neighbors would be impossible.

The ACP has now stated that workers will be subject to 12 hour workdays, 7 days per
week. Work will continue through the winter, even in snow and extreme cold on the
steep mountains of Western Virginia and West Virginia. Frequent turns in the pipe would
be attempted by bending the 42 inch diameter pipes in the field, and not in a controlled
factory setting. The pipe would make 8 turns within 3,049 feet on my property alone, on
slopes up to 58%, almost to steep to walk on. Workers will be housed in man camps far
away from their out of state homes. This is a recipe for unsafe work, and a recipe for
disaster for the public.

Another concern I have regards misguided bureaucracy. Even though PHMSA is the
agency with expertise regarding pipeline safety, they are not involved in the approval
process for gas pipelines, including the siting of those pipelines. The siting and other
criteria are approved by the Federal Energy Regulatory Commission (FERC). FERC is
not the expert on pipeline safety, yet they approve the pipeline routes. FERC, unlike
PHMSA, is also fully funded by the energy industry. This is a fundamental case of
mismanagement in our federal government. PHMSA should review the routing of natural
gas pipelines because of their expertise in these matters.
The ACP would be larger than the Keystone XL pipeline, and only 6 inches smaller that
the Trans Alaska pipeline. It would also carry a much more dangerous product, natural
gas. The amount of gas carried in the pipeline would have the explosive force of the
atomic bombs that were dropped on Japan. Even if the remote control valves properly
activate in an emergency to segregate gas in the pipeline, the zone of incineration is still
2,200 feet wide, and the evacuation zone, where failure to leave in a matter of minutes
would result in death or severe injury is 1.4 miles wide. In fact, the entire evacuation
zone for the ACP is a little smaller than 2/3 the size of Rhode island.

A public official’s first priority is to assure the public safety. We The People have
entrusted you with our safety. The ACP, and other pipeline companies are willing to put
our safety in jeopardy in order to make windfall profits. Government officials and the
regulatory agencies they oversee have been all too willing to allow that.

Please conduct an investigation into the safety of the pipes that are proposed for the
Atlantic Coast Pipeline.

Thank you,

William F. Limpert
wflimpert@gmail.com
250 Fern Gully Lane
Warm Springs, VA 24484
540-839-3202

4102B Garfield Road


Smithsburg, MD 21783
301-416-0571

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