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Asbestos (ACM):

As most of us in the pipeline industry know, many years ago asbestos containing material (ACM) was utilized in conjunction with coal tar enamel as a coating to insulate pipe while it sat underground. Later we found that asbestos was linked to Mesothelioma (asbestosis), a cancer in the lungs. In 1989 the United States Environmental Protection Agency (EPA) banned the use of ACM and issued regulations to phase it out all together.

Today asbestos in new pipe coating materials is no longer being used, but we must still deal with this hazardous material as we renovate and/or remove our existing pipelines and systems.

SouthWest Pipe Services is approved for working with regulated waste materials found in pipe coatings.

March 16, 2006 SouthWest Pipe Services wrote the EPA to ask for clarification and guidance as what our roles and responsibilities are while purchasing and cleaning pipe with ACM. On August 31, 2006 the EPA replied with the attached letter.

The EPA’s letter explained and clarified regulations under 40 CFR Part 61, Subpart M and the EPA’s National Emissions Standards for Hazardous Air Pollutants (NESHAP) as they relate to pipeline renewal/renovation projects. Following are some highlights from this letter;

A pipeline project where the pipe coating contains asbestos becomes regulated after 260 linear feet of ACM has been disturbed.
   
  • When pipe is cut into sections so it can be removed from the ground and transported from the right-of-way, 6 – 12 inches of coating are disturbed for each cut. If the pipe is cut into 40 foot sections, the project becomes regulated after 260 – 520 joints have been cut.
   
  • Once pipe is sold, and the buyer is removing the ACM coating, it only takes 6-1/2 40 foot joints for the project to become regulated.
   
NESHAP, as it relates to asbestos, defines an owner or operator of a renovation or demolition as; “any person who owns, leases, operates, controls or supervises the facility being demolished or renovated or any person who owns, leases, operates, controls or supervises the demolition or renovation operation, or both”.
   
  • We noted that NESHAP uses the word “person”, not company. We believe that this means individuals can be found liable if the right thing is not being done.
   
Once the pipe is sold the original “owners” are still liable for ensuring ACM waste is disposed of properly. As asbestos generators the pipeline company has cradle-to-grave responsibility.
 
Some companies use third parties to handle and clean pipe, so its important to do your research on who exactly will be handling your waste. Southwest Pipe Services, Inc. handles 100% of pipe cleaning in house and has never used a third party.
 
If you have any concerns about a company you are thinking about using for your next project, you can perform a background check on them at:
 
Can you afford the risk?
 


   
Polychlorinated Biphenyls (PCBs):

Before 1973 when PCBs were banned for use in products such as paints and coatings, PCB oils were utilized in coal tar enamel coatings during the application process. The coal tar material needed to be kept hot so the tar would be pliable and thin enough to spray onto the pipe. This was accomplished in large 30 to 100 barrel melting pots. After the tar material had been in the melting pot for a long period of time, it would start to "coke-up".  It started to take the consistency of lava rocks.  Contractors started to lose product.  The contractors confronted the coal tar manufacturers with this problem. The solution to their problem was to add PCB oils supplied by the manufacturer to prevent the coal tar material from hardening. This was a great solution in the 1930s through the 1960s and into the 1970s due to the insulation properties of PCBs.

Because the PCB oils were not used in all applications on all jobs, your company may be lucky enough not to find PCBs in your coal tar coatings. Some companies may find intermittent positive results in an area sampled, and yet others may find PCBs throughout the pipeline.

The EPA now regulates PCBs and all activities connected to them under regulation 40 CFR 761, Polychlorinated Biphenyls (PCBs) Manufacturing, Processing, Distribution in Commerce, and Use Prohibitions.   Subpart D of this regulation (761.79 Decontamination Standards and Procedures), mentions how coatings containing PCBs are to be removed. The final disposition of the pipe once decontaminated, will determine what NACE standard the pipe will need to be cleaned to. Pipe being sold back into commerce requires that it be cleaned to a NACE Visual Standard No. 2, Near-White Blast Cleaned Surface Finish. If the final disposition of the pipe is going to be smelted (scrap metal), the EPA requires the pipe surface to be cleaned to a NACE Visual Standard No. 3, Commercial Blast Cleaned Surface Finish. SouthWest Pipe Services has been inspected by a NACE Inspector and has been recognized to have the ability to clean pipe to a NACE No. 2 Visual Standard.

Recommendations & Observations When Handling Pipe Containing Hazardous Material:

  1. When there are ACM or PCBs present, be careful who you are selling pipe to.

     
  2. Be sure to audit and pre-qualify all potential buyers of your pipe to assure they have the capability and knowledge of handling ACM and PCBs in accordance to the regulations.

     
  3. Handling ACM and PCB's in accordance with local, state, and federal regulations is expensive.

     
  4. When selling pipe, the high bidder may not be handling your hazardous material in accordance to the regulations.

     
  5. Attempting to manage this risk in a purchase and sales agreement is not sufficient. Due diligence is the only way to be sure your hazardous material is being handled properly.

     
  6. Get your Environmentalist involved in every pipeline renovation project.