h5>Asbestos and Old Pipelines
Asbestos coating on pipelines is not a popular topic with most pipeline companies. In fact they don’t even like to use the “A” word when describing the coating. Asbestos is a proven, effective, and durable means of protecting steel pipe from corrosion and the elements. For the most part, asbestos might be five to fifty percent of the felt wrapping around a length of line pipe with some tar type outer wrapping. Overall this might mean there is as much as 25% asbestos in the complete coating. Asbestos as a coating on pipelines was very popular until the Clean Air Act was enacted in 1965. It took a few years, but use of asbestos in new pipeline coatings disappeared before 1980. Today, asbestos continues to protect hundreds of thousands of feet of buried pipeline that were laid between 1920 and 1980.
Most of the misinformation over asbestos comes from regulations regarding exposure in an enclosed area such as wall and ceiling insulation in schools, offices, and public buildings. When asbestos becomes dry and broken up, it is in a friable or free-flying and dry state and can be a contaminant if inhaled consistently by humans over time in concentrated amounts. The issue always comes down to whether or not the asbestos in question is friable. Coatings that contain friable asbestos are soft, dry, and pliable enough to crush normally in a human fist and thus release the asbestos fibers freely into the atmosphere.
Asbestos in coatings is never in a friable state while on the pipeline. When a pipeline is cut and removed from the ground, the coating is only minimally disturbed. During excavation, the pipeline is almost always in open spaces such as outdoors on a pipeline right of way where it is impossible to have any concentrated exposure. Any workers would only have exposure for minutes out of days on jobs of short duration. Even so, responsible operators will use some sort of simple respirator over their nostrils as part of the prescribed standard safety equipment. In addition, the use of dampeners keeps the coating material from becoming friable. This can be done with a simple spray bottle of water with backup reserves in a larger tank nearby.
Regulators and bureaucrats can attempt to enforce laws related to enclosed environments in open areas, but most of these attempts have not been successful.
Just simple precautions when taken will prevent any problems with any OSHA (Occupational Safety and Health Act) enforcers. Using simple respirators while slicing or removing asbestos in preparation for cutting or welding pipe satisfies almost all OSHA requirements. Sometimes, an inexpensive air monitor placed nearby might stop any questions even though it seems frivolous, as it is impossible to measure any of these flying particles in an open-air operation. As mentioned, a good practice during pipeline removal is to keep a tank or container of water nearby to keep freshly cut or sliced areas of coating damp while working with the pipe. At times it might be prudent or perhaps required to individually wrap each joint of pipe prior to loading. More often, if it deemed necessary for transporting, operators will wrap all pipe ends at once after a truck is loaded. This method simply covers all the ends with one secured wrap.
As regards this type of coating on pipelines, the National Emission Standard for Asbestos, Subpart M, defines this type of asbestos or asbestos containing material as a Category II nonfriable ACM and means any material containing more than 1 percent asbestos as determined using the methods as determined used the methods specified (Polarized Light Microscopy that when dry, cannot be crumbled, pulverized, or reduced to powder by hand pressure. (Appendix E, Subpart E, 40 CFR part 763, section 1)
In my experience of removing millions of feet of pipeline that for the most part were coated with ACM, I have never had occasion to witness this type of material in a dry state that was separated from the coating product. That is, the asbestos containing material is embedded in a tar coating that is in turn wrapped in a fiberglass material making the material almost impossible to separate. The tar is hard particularly when it is cool or dampened and at that point cannot be crumbled, pulverized or reduced to powder by hand pressure. I will contend that the method of making this type of ACM friable does not occur. Possibly the notion came from asbestos removal in buildings where very norm and loose asbestos is the norm, but in my experience does not occur in pipeline coatings, pipeline removal or pipeline deconstruction.
Prior to removing old coated pipelines, it is prudent to test the coating for asbestos, especially if the pipeline was laid between 1920 and 1980. Samples of the coating should be removed along the length of the pipeline to be removed and sent to testing labs to determine the exact content. In most metropolitan areas, there are labs where these simple tests can be performed. In Houston, J-3 Resources can do number of tests for chemical analysis or embedded properties. As of this writing, J-3 charges $36 per sample to test for the presence and amounts of asbestos and the type of asbestos particle present in the sample. J-3 provides all pertinent documentation regarding the test results. J-3 is one of several testing companies in Houston, and they perform forty to fifty of these tests per month. Generally results are ready within hours or overnight.
Pipe Cleaning Process
ACM coated pipes that require rehabilitation can be cleaned “over the ditch” without totally being taken out of service. Cleaning machines or “line traveling machines” move along the pipeline while removing the pipe coating from the exterior. The coating residue either falls into the ditch (where it was laying before) or is caught in bags and disposed of in designated landfills or other approved sites. These sites charge upwards of $40 per ton and provide documentation.
Another way to clean coated pipelines is to transport the removed pipeline so that no debris of any kind falls on public property to a central staging area. At the staging area, the removed pipe is sliced and cleaned using a track hoe modified with special slice/cleaning attachments on the bucket. The removed coating is immediately picked up and deposited in a “roll-off box” with secured tarps. When each box was filled removed coating material, it is transported along with a licensed and certified asbestos supervisor to the proper landfill for deposit. There is a paper trail for the entire process.
Pipeline recyclers such as Pipeline Equities will remove ACM coated pipelines, load them onto trucks and transport them to a pipeline service yard that is certified in asbestos cleaning. Or, the company will clean the pipe in situ using line-cleaning machines. Pipeline Equities provides certified contractor/supervisors on any job where asbestos is or might be an issue.
Pipe Service Yards
Some pipe service yards are certified to remove asbestos coating from pipe. They have the proper machines to rapidly clean and remove the coating (whether or not the coatings contain asbestos) down to bare metal. Most of these yards are able to perform many other rehabilitation functions as well such as beveling, straightening, cutting and welding together pieces on a custom basis to order. Most can also perform interior cleaning, end finishing of all kinds, and dent removal services. Some of the more prominent pipe service yards are Stauffer Pipe Services in Houston, Texas; CPS in Houston and Lone Star, Texas; and Pioneer in El Reno, Oklahoma. These companies can handle most any type of exterior pipe cleaning of various types of coatings. All are licensed for asbestos containing materials (ACM) and can properly handle the product with proper abatement and disposal methods and documentation. Additionally, Stauffer can deploy field crews as they have equipment that is portable. CPS in addition has facilities for long-term storage for large amounts of pipe.
Pipe Cleaning Expense
Cleaning expenses for removing ACM from pipelines can run from $1 to $3 per foot in a certified pipeline service yard with competent personnel who are versed in the proper methods to remove, sack, label, and dispose of the ACM waste in the prescribed manner. The biggest problem is the transportation expense. Pipe is heavy, bulky, and expensive to load, unload, and transport. The coating itself can contribute as much as 10% to 12% of the total weight of the pipe.
There are weights and bulk issues in handling pipe and the economics can quickly get out of hand. The other logistical problem is location. It is not always convenient or cost effective to ship to Oklahoma, Houston, or East Texas to work on pipe that you excavate in Colorado that is to be shipped to Michigan. Due to the high cost of transportation, it is important to handle some or all of the pipeline rehabilitation work while in the field. At least two recovery or salvage operators have the ability to handle this pipeline rehabilitation in situ: Pipeline Equities and Pipeline Recovery.
The area of licensing and certification to me is somewhat murky. Generally, people throw around the term “certified” pretty liberally. Basically, certification is education. A practitioner can receive certifications based on length of time in practice in the area, coursework via online or classroom instruction for a certain number of courses or classroom hours, or some combination of all of these methods. For asbestos certification, a supervisor goes to school for forty classroom hours, takes a test upon completion of the coursework, and upon successful completion of the course and exam, receives a certificate or embossed piece of paper showing when and how the certification course was completed. This certificate satisfies state licensing requirements in Texas, Oklahoma, New Mexico and Louisiana.
In Houston, the most competent of these schools, and the most popular, is Natec of Texas, Inc. Not only do they have schools for supervisors, but also certifications for workers who will actually be doing the work. Their classes are generally two to three days long. All Natec of Texas courses require renewal or refresher courses to re-certify. Re-certification is usually required on an annual basis. Natec of Texas is reasonably priced, well taught, and considered to be the best in the industry. Pipeline Equities has found Natec of Texas and David Roberts, a Vice President, to be extremely helpful on a continuing basis. Pipeline Equities supervisors have had occasion to call Natec for additional advice and questions regarding proper disposal techniques and regulations. David Roberts and Natec have always been congenial, eager, and responsive. They are the best informed in this part of the country on asbestos law, regulations, and safety issues.
This article is neither meant to be technical in nature, nor a debate or analysis of the regulations or authorities of the various federal and state agencies regarding asbestos. It is sufficient to state that asbestos in pipeline coatings is not friable and not a hazardous material by nature, even though some lawyers may attempt to make it seem so. It takes great effort to make these products friable and thus potentially a problem to human health. Even so, for the pipeline industry, even if friable conditions exist, work is done in the open air and not in enclosed conditions. The products are not considered a hazard to human health when in the open air.
The pipeline recovery and rehabilitation industry is very small by industry standards. One of the reasons it remains small is due to fear from lawsuits. Indeed, most company environmental administrators and their accompanying legal departments simply do not want additional problems or have a desire to invite potential law suits. Therefore, they shy away from tampering with pipelines that might have asbestos coating. The coming storm, however, will happen when regulators and legislation mandate the removal of abandoned pipelines. At that point all will have to deal with the issues of asbestos coating.
There is simply too much concern by landowners and developers to ignore the problem of “abandoned pipelines” much longer.
The problem is deciding which problem to address: bite the bullet and competently remove the pipelines once they are deemed uneconomic; or wait until the EPA and OSHA mandate removal as a result of lawsuits from landowners and deal an aggressive EPA. Pipeline Equities receives an increasing number of calls from landowners who want abandoned pipelines removed from their property. They ask the pipeline company to remove the line, but the company balks at removal due to perceived environmental risks. This leaves the alleged “contaminated” pipeline abandoned on an unsuspecting landowner’s property. With the rapid dissemination and availability of information via the Internet, landowners are no longer unsuspecting, but becoming very sophisticated in these areas. If a farmer is sophisticated enough to hedge his crop on the futures market, he is smart enough to “Google” abandoned pipelines or asbestos coating on pipelines. So what is the paranoia about in identifying, claiming or taking responsibility for idled, out of service, or abandoned pipelines?
Pipeline Equities and other pipeline removal companies have removed a total of over 50 million feet of out-of-service pipelines in the U. S. There has never been an incident of an employee or field worker having problems with anything related to asbestosis as a result of working on the removal process. There have never been any related lawsuits in this regard, even after the best efforts of some the most persistent ambulance chasers available.
Nevertheless, the scare has made a great impression on environmental and legal watchdogs. The problem seems to stem from lack of knowledge of the current regulations and to whom the regulations are addressed. The threat is one of perception, rather than reality, as far as threat to worker’s health or exposure to asbestos through pipeline. Company environmental and legal departments should take the time to get more education or certification to learn the realities of what actually is going on in the arena of abandoned pipelines.