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04/23/14
Canyon Country
Coalition for Pipeline
Safety 1
Fidelity Pipeline: A Ticking Time Bomb?
Will faulty construction intersect with record tourism?
04/23/14
Canyon Country
Coalition for Pipeline
Safety 2
Construction Stipulations
 Pipeline design & construction
The BLM clearly promised Grand County a safe pipeline in their
Environmental Analysis(EA): Section 2.2.2: “While this gathering line will not
be regulated, the pipeline would be designed and constructed to meet and
exceed federal and industry standards that would be applied to a similar
transmission pipeline.
Categorization as a transmission pipeline rather than a gathering line is
important to protect the health and welfare of the hundreds of thousands of
visitors to the area.
Section 2.2.2 needs to be enforced & the line regulated as a transmission
pipeline or else the BLM needs to offer a new amendment for the public to
comment on construction of a non-regulated gathering line.
04/23/14
Canyon Country
Coalition for Pipeline
Safety 3
Construction Stipulations (cont.)
 Pipeline design & construction (cont.)
The Federal government establishes minimum pipeline safety standards under
49 CFR, Parts 190 through 199. The BLM is obligated to enforce its construction
requirements.
Section 192.235 - Preparation for Welding
Section 192.307 - Inspection of Materials
Section 192.317 – Protection from Hazards
Section 192.455 – External Corrosion Control
Section 192.479 - Atmospheric Corrosion Control
The General Provision of 49 CFR 192 states that [the] Administrator…that has
submitted a current certification under the pipeline safety laws… with respect to
the pipeline facility governed by an operator's plans and procedures may, after
notice and opportunity for hearing…require the operator to amend its plans and
procedures as necessary to provide a reasonable level of safety.
04/23/14
Canyon Country
Coalition for Pipeline
Safety 4
Construction Stipulations (cont.)
 Adherence to all aspects of the plans, procedures,
design features, & mitigation measures identified in
the Environmental Assessment
The Dead Horse Point Lateral ROW Amendment (UTU-67385) decision
record stipulates that [this] decision is contingent upon Fidelity adhering
to all aspects of the Proposed Action which includes the final Plan of
Development, Safety Procedures, Reclamation Plan, and environmental
commitments (design features). The decision is also contingent upon
Fidelity fulfilling the mitigation measures identified in the EA and Fidelity
posting the required bond.
04/23/14
Canyon Country
Coalition for Pipeline
Safety 5
Concerns/problems
 Examples of safety issues observed:
 In the field, there was no indication that the monitor was reviewing,
documenting or otherwise carrying on oversight.
 Clamping removed before weld completed. Potential for pipe shifting that
creates microscopic cracks in the joint.
 Excessive tension resulting from lack of supports over washes & other low
spots.
 No evidence that dust mitigation for air pollution or equipment power
washing for preventing the spread of noxious weeds & non-native plants is
being implemented.
 No plans in place to coat the pipe to prevent rust & decay.
 Placement over rocks & through trees increases surface grinding & fire
potential because of heat & friction.
 There are no warning signs or barriers preventing vehicles from using the
ROW either north or south of the pipeline route off Mineral Point Road.
04/23/14
Canyon Country
Coalition for Pipeline
Safety 6
Concerns/problems (cont.)
 Location safety issues:
A de facto transmission line located above ground exposes the pipeline to
a number of potential threats: Jeep, ATV or dirt bike accident, gunshot,
lightning strike, vandalism, people playing on it, etc.
Its proximity to the Cowboy Camp, Horsethief campground, & Dubinky
Well Rd. means that an explosion resulting from a rupture threatens
significant injuries & loss of life.
 BLM lack of responsiveness:
 Specifications for the welding procedure have not been made public.
 Why is the BLM not taking every possible step to ensure public safety &
require the pipeline builder to adhere to the construction stipulations?
04/23/14
Canyon Country
Coalition for Pipeline
Safety 7
Field Violations Observed
 Scratched exterior & weld damage from dragging the pipe
 Threatens integrity of the wall & increases chance of rupture
04/23/14
Canyon Country
Coalition for Pipeline
Safety 8
Field Violations Observed (cont.)
 No trestles for support & it passes thru trees
 Leads to scouring & dangerous flexing of the pipe;
public may be tempted to swing on it
04/23/14
Canyon Country
Coalition for Pipeline
Safety 9
Field Violations Observed (cont.)
 Location against trees is a fire threat
 Fire may result from pipe’s heat transfer or friction created by pipe movement
04/23/14
Canyon Country
Coalition for Pipeline
Safety 10
Field Violations Observed (cont.)
 No dust mitigation or power washing of equipment prior to use
 Both required by the Environmental Assessment
04/23/14
Canyon Country
Coalition for Pipeline
Safety 11
Field Violations Observed (cont.)
 Moving of machinery along & across open roads
without using cautionary warning or stop signs
04/23/14
Canyon Country
Coalition for Pipeline
Safety 12
Field Violations Observed (cont.)
 Should Cowboy Camp, Horsethief Campground, & Dubinky Well Road be closed?
 Without barricades, a strong probability exists of pipeline damage from
children horsing around or vehicular impacts
04/23/14
Canyon Country
Coalition for Pipeline
Safety 13
BLM Responsibilities on
Behalf of the Public
 Enforcement of EA section 2.2.2
 Will the BLM be responsible for enforcing all federal codes
necessary for building a high-quality, safe pipeline?
 Survey the pipeline for deviation from pipeline
standards required in Section 2.2.2
 Including but not limited to 49 CFR 190 through 199
 X-ray entire pipeline to test for weld quality
 Mandate an additional inspector & allow access to all
inspector reports
 No visual evidence that the sole monitor was reviewing,
documenting or otherwise carrying on oversight
04/23/14
Canyon Country
Coalition for Pipeline
Safety 14
BLM Responsibilities on
Behalf of the Public
 Allow access to the pipeline construction manual &
safety plan
 MOU between BLM & Canyon Country Coalition for
Pipeline Safety outlining the procedures that will be
used to survey the safety of the line. A final report
will detail the disposition of all problems found by
the pipeline survey
 Designation of whom is liable if a rupture occurs
04/23/14
Canyon Country
Coalition for Pipeline
Safety 15
It’s Common Sense That an Aboveground Pipeline in
a Multi-use Recreational Area Must Meet
Transmission Line Standards
7,978
incidents
512 deaths
2,360 injuries
Isn’t it
better to
be safe
than sorry?
04/23/14
Canyon Country
Coalition for Pipeline
Safety 16
Thank You for Taking the Time to
Listen to Our Concerns
We look forward to carrying on this conversation
with you in the future

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Fidelity Pipeline - Saftey Concerns and Issues for the Dead Horse Lateral Pipeline in Moab, UT

  • 1. 04/23/14 Canyon Country Coalition for Pipeline Safety 1 Fidelity Pipeline: A Ticking Time Bomb? Will faulty construction intersect with record tourism?
  • 2. 04/23/14 Canyon Country Coalition for Pipeline Safety 2 Construction Stipulations  Pipeline design & construction The BLM clearly promised Grand County a safe pipeline in their Environmental Analysis(EA): Section 2.2.2: “While this gathering line will not be regulated, the pipeline would be designed and constructed to meet and exceed federal and industry standards that would be applied to a similar transmission pipeline. Categorization as a transmission pipeline rather than a gathering line is important to protect the health and welfare of the hundreds of thousands of visitors to the area. Section 2.2.2 needs to be enforced & the line regulated as a transmission pipeline or else the BLM needs to offer a new amendment for the public to comment on construction of a non-regulated gathering line.
  • 3. 04/23/14 Canyon Country Coalition for Pipeline Safety 3 Construction Stipulations (cont.)  Pipeline design & construction (cont.) The Federal government establishes minimum pipeline safety standards under 49 CFR, Parts 190 through 199. The BLM is obligated to enforce its construction requirements. Section 192.235 - Preparation for Welding Section 192.307 - Inspection of Materials Section 192.317 – Protection from Hazards Section 192.455 – External Corrosion Control Section 192.479 - Atmospheric Corrosion Control The General Provision of 49 CFR 192 states that [the] Administrator…that has submitted a current certification under the pipeline safety laws… with respect to the pipeline facility governed by an operator's plans and procedures may, after notice and opportunity for hearing…require the operator to amend its plans and procedures as necessary to provide a reasonable level of safety.
  • 4. 04/23/14 Canyon Country Coalition for Pipeline Safety 4 Construction Stipulations (cont.)  Adherence to all aspects of the plans, procedures, design features, & mitigation measures identified in the Environmental Assessment The Dead Horse Point Lateral ROW Amendment (UTU-67385) decision record stipulates that [this] decision is contingent upon Fidelity adhering to all aspects of the Proposed Action which includes the final Plan of Development, Safety Procedures, Reclamation Plan, and environmental commitments (design features). The decision is also contingent upon Fidelity fulfilling the mitigation measures identified in the EA and Fidelity posting the required bond.
  • 5. 04/23/14 Canyon Country Coalition for Pipeline Safety 5 Concerns/problems  Examples of safety issues observed:  In the field, there was no indication that the monitor was reviewing, documenting or otherwise carrying on oversight.  Clamping removed before weld completed. Potential for pipe shifting that creates microscopic cracks in the joint.  Excessive tension resulting from lack of supports over washes & other low spots.  No evidence that dust mitigation for air pollution or equipment power washing for preventing the spread of noxious weeds & non-native plants is being implemented.  No plans in place to coat the pipe to prevent rust & decay.  Placement over rocks & through trees increases surface grinding & fire potential because of heat & friction.  There are no warning signs or barriers preventing vehicles from using the ROW either north or south of the pipeline route off Mineral Point Road.
  • 6. 04/23/14 Canyon Country Coalition for Pipeline Safety 6 Concerns/problems (cont.)  Location safety issues: A de facto transmission line located above ground exposes the pipeline to a number of potential threats: Jeep, ATV or dirt bike accident, gunshot, lightning strike, vandalism, people playing on it, etc. Its proximity to the Cowboy Camp, Horsethief campground, & Dubinky Well Rd. means that an explosion resulting from a rupture threatens significant injuries & loss of life.  BLM lack of responsiveness:  Specifications for the welding procedure have not been made public.  Why is the BLM not taking every possible step to ensure public safety & require the pipeline builder to adhere to the construction stipulations?
  • 7. 04/23/14 Canyon Country Coalition for Pipeline Safety 7 Field Violations Observed  Scratched exterior & weld damage from dragging the pipe  Threatens integrity of the wall & increases chance of rupture
  • 8. 04/23/14 Canyon Country Coalition for Pipeline Safety 8 Field Violations Observed (cont.)  No trestles for support & it passes thru trees  Leads to scouring & dangerous flexing of the pipe; public may be tempted to swing on it
  • 9. 04/23/14 Canyon Country Coalition for Pipeline Safety 9 Field Violations Observed (cont.)  Location against trees is a fire threat  Fire may result from pipe’s heat transfer or friction created by pipe movement
  • 10. 04/23/14 Canyon Country Coalition for Pipeline Safety 10 Field Violations Observed (cont.)  No dust mitigation or power washing of equipment prior to use  Both required by the Environmental Assessment
  • 11. 04/23/14 Canyon Country Coalition for Pipeline Safety 11 Field Violations Observed (cont.)  Moving of machinery along & across open roads without using cautionary warning or stop signs
  • 12. 04/23/14 Canyon Country Coalition for Pipeline Safety 12 Field Violations Observed (cont.)  Should Cowboy Camp, Horsethief Campground, & Dubinky Well Road be closed?  Without barricades, a strong probability exists of pipeline damage from children horsing around or vehicular impacts
  • 13. 04/23/14 Canyon Country Coalition for Pipeline Safety 13 BLM Responsibilities on Behalf of the Public  Enforcement of EA section 2.2.2  Will the BLM be responsible for enforcing all federal codes necessary for building a high-quality, safe pipeline?  Survey the pipeline for deviation from pipeline standards required in Section 2.2.2  Including but not limited to 49 CFR 190 through 199  X-ray entire pipeline to test for weld quality  Mandate an additional inspector & allow access to all inspector reports  No visual evidence that the sole monitor was reviewing, documenting or otherwise carrying on oversight
  • 14. 04/23/14 Canyon Country Coalition for Pipeline Safety 14 BLM Responsibilities on Behalf of the Public  Allow access to the pipeline construction manual & safety plan  MOU between BLM & Canyon Country Coalition for Pipeline Safety outlining the procedures that will be used to survey the safety of the line. A final report will detail the disposition of all problems found by the pipeline survey  Designation of whom is liable if a rupture occurs
  • 15. 04/23/14 Canyon Country Coalition for Pipeline Safety 15 It’s Common Sense That an Aboveground Pipeline in a Multi-use Recreational Area Must Meet Transmission Line Standards 7,978 incidents 512 deaths 2,360 injuries Isn’t it better to be safe than sorry?
  • 16. 04/23/14 Canyon Country Coalition for Pipeline Safety 16 Thank You for Taking the Time to Listen to Our Concerns We look forward to carrying on this conversation with you in the future

Editor's Notes

  1. Mandates (EA), etc.
  2. Mandates (EA), etc.
  3. Mandates (EA), etc.
  4. Input into inspector selection
  5. Input into inspector selection
  6. Transmission line standard