MVP too large and terrain too steep for WV & VA
From an Article by Laurence Hammack, Roanoke Times, May 3, 2020
Land movement in a construction area shifted a section of the Mountain Valley Pipeline after it was buried along a West Virginia slope, according to a report filed by environmental regulators.
The Federal Energy Regulatory Commission report stated that “crews verified that the installed pipe shifted … in at least three locations south of Brush Run Road” in Lewis County, about 50 miles from where the natural gas pipeline begins a 303-mile route that takes it through Southwest Virginia.
Inspectors blamed the problem on what’s called a slip, or the gradual movement of land on its own in an area cleared for the pipeline. Although it was not clear how far the pipe had moved, the report alarmed those who have warned against building such a large pipeline in mountainous terrain.
“That’s a big-time concern,” said Angie Rosser, executive director of the West Virginia Rivers Association. Had pressurized gas been flowing through the finished pipeline, which has been under construction for the past two years, any underground movement could possibly cause a rupture and explosion, Rosser said.
A Mountain Valley spokeswoman, however, said the FERC report focused on environmental concerns and did not delve into technical issues of pipeline construction.
“At this time, there is no direct information to indicate that the pipe has shifted along this portion of the route and this information will not be known until a full investigation is complete,” Natalie Cox wrote in an email. After the issue was discovered April 8, an investigation was launched as “an additional precautionary matter,” the email stated.
Crews will dig up the pipe, which generally is buried eight to 10 feet deep, to ensure its integrity and placement. “Additional mitigation controls will be installed if necessary,” Cox wrote.
There have been no other issues of this type in completed areas of the project, she said. Construction began two years ago, and Mountain Valley said the $5.5 billion project is 90% done and slated for completion by the end of the year.
Opponents of the project worry that similar problems with the pipe shifting after it’s buried could occur in parts of Southwest Virginia, where construction is not as far along.
“They have landslides and slips and failures all the time,” said Diana Christopulos, a Roanoke-area environmental advocate who has been monitoring the pipeline since it was first proposed five years ago. “Putting the pipe in the ground does not solve the problem.”
The region’s steep slopes and karst topography make it “pretty challenging terrain,” pipeline safety consultant Richard Kuprewicz said.
Regulators in both Virginia and West Virginia have cited Mountain Valley for failing to comply with erosion and sediment control measures hundreds of times. But the shifting of pipe described in the FERC report was the first of its kind.
Using line locators to monitor installed pipelines
The first sign that something was amiss came about a month ago. According to a weekly summary report of environmental compliance, recently filed on the FERC online docket, the commission’s compliance monitor was notified by Mountain Valley officials of a problem April 8 at the West Virginia construction site. “Movements of the slips” in at least three locations had caused the 42-inch diameter pipe to shift, the report stated.
A slip, also known as land creep, is the gradual movement of soil and rock down a slope and is not as serious as a landslide, said Kuprewicz, a chemical engineer who worked for years in the gas industry and now consults on pipeline safety issues as president of Accufacts Inc. in Redmond, Washington.
The FERC report does not indicate how far the pipe shifted. Survey crews marked where the pipe had originally been laid, and workers dug potholes and used line locators to determine its current location, the report states. Asked about the incident last Wednesday, a FERC spokeswoman said the agency would answer emailed questions “as soon as we can.” No response had been received by 5 p.m. Friday.
FERC listed the incident as a “communication report,” meaning that it could be resolved by discussion between its compliance monitor and Mountain Valley representatives. A communication report is the least serious type of non-compliance listed in FERC’s weekly summary of environmental monitoring. Other write-ups can be for problem areas, non-compliance and serious violations.
Kuprewicz, who reviewed the report on the shifting pipe for The Roanoke Times, said it didn’t contain enough details for him to make an informed opinion about how serious the problem was. “Land slip on its own is not a big deal, depending on the details,” he wrote in an email. However, “the fact that the document mentions three sites calls for further investigation to see if there is a possible systemic issue for the pipeline and its right-of-way.”
According to Cox, Mountain Valley is designed, like all interstate pipelines, to withstand minor ground shifting as the pipe begins to settle in the final stages of construction. That may be true, Kuprewicz said, but it’s important to monitor a land slip closely to make sure it doesn’t get out of hand. “Land creep could eventually result in rupture if it moves the pipe too much too quickly,” he wrote.
An earlier inspection by FERC officials in March — before the shift in the pipeline was discovered — found that two of the three slips at the Lewis County construction site had increased in their size and movement. The leading cause of slips is poor water management on sloped land, Kuprewicz said. Rainfall “starts to liquify the soil and gravity never shuts off,” his email stated.
Cox said the environmental inspector was correct in assessing ground movement so that construction crews could quickly stabilize any areas of concern. “However, it’s important to note that environmental assessments do not necessarily indicate issues with movement or the technical construction of the pipe,” she wrote.
Project delayed for multiple reasons
By now, Mountain Valley officials had hoped to resume construction of a pipeline that will transport 2 billion cubic feet of natural gas a day to markets along the East Coast. But except for stabilization and erosion control work, the project remains in a state of limbo.
A series of legal challenges by environmental groups have led to the suspension of three sets of permits — one for the pipeline to pass through the Jefferson National Forest, a second for it to cross more than 1,000 streams and wetlands and a third for it to be built in a way that does not jeopardize endangered or threatened species.
After the most recent lawsuit claimed that protected fish and bats were not properly taken into account by the U.S. Fish and Wildlife Service, FERC last October ordered a stop to all active construction until the issues could be resolved.
The Fish and Wildlife Service began work on a new biological opinion, the document that allows pipeline construction if there is no substantial harm to plants or wildlife. Originally due in December, work on the opinion was extended three times, with the most recent deadline of April 27.
On that day, the service wrote in a letter to FERC that while “considerable progress” had been made, an additional 30 days are needed to complete the biological opinion. A new deadline of May 27 was set. Another permit needed before work can resume, approval of stream and wetland crossings by the U.S. Army Corps of Engineers, is also facing a delay.
A federal judge in Montana has vacated the Army Corps general permit for stream crossings, known as a Nationwide Permit 12, after opponents of the Keystone XL pipeline filed a lawsuit alleging the Corps did not adequately consider the project’s impact on endangered species.
The ruling “has a nationwide effect, is extremely disruptive, and contrary to the public interest,” lawyers for the U.S. Justice Department wrote in a motion seeking a stay of Judge Brian Morris’s ruling. The attorneys also asked Morris to limit the scope of his decision to the Keystone pipeline.
About 5,500 projects, including Mountain Valley, were awaiting approval from the Corps when the permit was struck down, according to the motion. “Many likely have nothing to do with oil and gas pipelines at all,” such as power lines, water mains and broadband cable, the government said.
If the projects were forced to seek individual permits from the Corps, which require more analysis than the Nationwide Permit 12, it would take the agency an average of 264 days to process each case, the motion states.
The Justice Department asked Morris to rule on its request for a stay by May 11. If that fails, it will appeal to the 9th U.S. Circuit Court of Appeals.
Height Capital Markets, an investment banking firm that issues weekly reports on Mountain Valley and other pipelines, wrote in an April 27 update that it was growing “increasingly concerned” about the case’s impact.
“At this point, we believe it’s too early to shift our late 2020 in-service target for MVP and need to see what actions the Trump administration takes,” the report stated, “though the odds of a 2020 completion are certainly trending down.”
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Pipelines are usually laid in areas where the topography allows deep soil cover to develop, multiple feet deep with, perhaps occasional stones or loose stony deposits. That is not the situation in Lewis and adjoining counties through which the MVP was laid.
I live in Lewis County not far from the locations mentioned, and viewed them shortly after the work was done. They are what we residents affectionately call “straight up and down.” Soil does not accumulate in such areas. It may be a few inches thick, but washes away due to the steep grade, even with the dense forest over it, encouraged by high rainfall.
Trenches in these areas are shallow (to avoid cost and the harder rock as one goes deeper. At 45 degrees, if you measure vertically the depth of eight feet, that gives five and a half feet if you measure vertically from the bottom of the ditch. Subtract three and a half feet for the 42 inch pipe and the coverage is two feet from the top of the pipe to the surface at the closest point. That’s assuming the pipe gets all the way to the bottom of the ditch and the coverage is uniform.
To dig these ditches, the right of way is cleared of trees, the stumps pushed out by “dare devil” bulldozer operators down hill, near the limit they can operate. Then the backhoe starts near the bottom on leveler ground, facing downhill and a cable is stretched from a large bulldozer above the top of the steep grade. Then the cable is reeled in, inch-by-inch as the backhoe digs the ditch. Much of what is dug out clatters down the hillside, rather than staying in place for fill.
The pipe is labored in, setting on the high spots, and welded in place. Finally, the pipe is covered up, stones first which are relatively abundant, with dirt on top to make it smooth. The same thing is done on the ACP pipeline a few miles away in Harrison County, where it is obvious they had to bring in dirt from adjacent areas to get a smooth cover.
Then the abundant rain comes. The rocks along the bottom of the pipe have spaces between them and the area becomes a conduit for water. Before long, the soil on top washes down into the open spaces and is conducted down hill to wash out into a surface stream.
It is somewhere between difficult and impossible to divert water off the right-of-way because of the stony quality of the diverting ditches. With hand work it might be possible, but with bulldozers on steep ground, even the most assiduous driver won’t get it right.
The fact is those pipes will soon be exposed in the steep locations, rubbing against the stone as the steel expands and contracts with temperature change, wearing off the protective coating and then scratching off the rust that will form on the steel pipe. How long will it be until they corrode and/or develop leaks? Who knows when?