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	<title>Comments on: Energy:  Out with the Dirty, In with the Clean</title>
	<atom:link href="http://www.clf.org/blog/clean-energy-climate-change/energy-out-with-the-dirty-in-with-the-clean/feed/" rel="self" type="application/rss+xml" />
	<link>http://www.clf.org/blog/clean-energy-climate-change/energy-out-with-the-dirty-in-with-the-clean/</link>
	<description>For a thriving New England</description>
	<lastBuildDate>Tue, 17 Sep 2013 14:27:54 +0000</lastBuildDate>
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		<title>By: Sandy Levine</title>
		<link>http://www.clf.org/blog/clean-energy-climate-change/energy-out-with-the-dirty-in-with-the-clean/#comment-2924</link>
		<dc:creator>Sandy Levine</dc:creator>
		<pubDate>Thu, 09 May 2013 17:52:58 +0000</pubDate>
		<guid isPermaLink="false">http://www.clf.org/?p=15025#comment-2924</guid>
		<description><![CDATA[CLF remains concerned about the environmental impacts of the tar sands pipeline especially in the areas where it is exposed. We are pleased that the recent decision by the Act 250 District Coordinator that any use of the pipeline for tar sands will require review by Act 250. You can read that &lt;a href=&quot;http://www.clf.org/wp-content/uploads/2013/05/JO-Decision-April-15-2013.pdf&quot; rel=&quot;nofollow&quot;&gt;decision here&lt;/a&gt;.]]></description>
		<content:encoded><![CDATA[<p>CLF remains concerned about the environmental impacts of the tar sands pipeline especially in the areas where it is exposed. We are pleased that the recent decision by the Act 250 District Coordinator that any use of the pipeline for tar sands will require review by Act 250. You can read that <a href="http://www.clf.org/wp-content/uploads/2013/05/JO-Decision-April-15-2013.pdf" rel="nofollow">decision here</a>.</p>
]]></content:encoded>
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		<title>By: pete blose</title>
		<link>http://www.clf.org/blog/clean-energy-climate-change/energy-out-with-the-dirty-in-with-the-clean/#comment-2916</link>
		<dc:creator>pete blose</dc:creator>
		<pubDate>Fri, 03 May 2013 14:11:58 +0000</pubDate>
		<guid isPermaLink="false">http://www.clf.org/?p=15025#comment-2916</guid>
		<description><![CDATA[In 2008 the Portland Pipeline Company was issued a Notice of Amendment by PHMSA for violation of (among other things) 49 CFR 95.583 which requires coating of pipe exposed to the atmosphere. See CFRs below. The violation was supposedly corrected. However it is apparent that the violation continues at present.  The pipeline remainss exposedat a number of locations.
       
If nothing else, these violations could form a legitimate basis for a civil action under 49 USC 60121. I suspect that additional grounds would be revealed in the discovery process.

Well that&#039;s my two cents.

Pete Blose

Barnet, Vermont
802-633-4152

49 CFR
 . . .      
              § 195.581
              Which pipelines must I protect against atmospheric corrosion and what coating material may I use?
              (a) You must clean and coat each pipeline or portion of pipeline that is exposed to the atmosphere, except pipelines under paragraph (c) of this section.
              (b) Coating material must be suitable for the prevention of atmospheric corrosion.
              (c) Except portions of pipelines in offshore splash zones or soil-to-air interfaces, you need not protect against atmospheric corrosion any pipeline for which you demonstrate by test, investigation, or experience appropriate to the environment of the pipeline that corrosion will—
              (1) Only be a light surface oxide; or
              (2) Not affect the safe operation of the pipeline before the next scheduled inspection.
                       
              § 195.583
              What must I do to monitor atmospheric corrosion control?
              (a) You must inspect each pipeline or portion of pipeline that is exposed to the atmosphere for evidence of atmospheric corrosion, as follows:
             
                If the pipeline is located:
                  Then the frequency of inspection is:
             
                  Onshore
                  At least once every 3 calendar years, but with intervals not exceeding 39 months.
                               
                  Offshore
                  At least once each calendar year, but with intervals not exceeding 15 months.
               
                (b) During inspections you must give particular attention to pipe at soil-to-air interfaces, under thermal insulation, under disbonded coatings, at pipe supports, in splash zones, at deck penetrations, and in spans over water.
              (c) If you find atmospheric corrosion during an inspection, you must provide protection against the corrosion as required by § 195.581.
           
               § 195.585
              What must I do to correct corroded pipe?
              (a) General corrosion. If you find pipe so generally corroded that the remaining wall thickness is less than that required for the maximum operating pressure of the pipeline, you must replace the pipe. However, you need not replace the pipe if you—
              (1) Reduce the maximum operating pressure commensurate with the strength of the pipe needed for serviceability based on actual remaining wall thickness; or
              (2) Repair the pipe by a method that reliable engineering tests and analyses show can permanently restore the serviceability of the pipe.
              (b) Localized corrosion pitting. If you find pipe that has localized corrosion pitting to a degree that leakage might result, you must replace or repair the pipe, unless you reduce the maximum operating pressure commensurate with the strength of the pipe based on actual remaining wall thickness in the pits.]]></description>
		<content:encoded><![CDATA[<p>In 2008 the Portland Pipeline Company was issued a Notice of Amendment by PHMSA for violation of (among other things) 49 CFR 95.583 which requires coating of pipe exposed to the atmosphere. See CFRs below. The violation was supposedly corrected. However it is apparent that the violation continues at present.  The pipeline remainss exposedat a number of locations.</p>
<p>If nothing else, these violations could form a legitimate basis for a civil action under 49 USC 60121. I suspect that additional grounds would be revealed in the discovery process.</p>
<p>Well that&#8217;s my two cents.</p>
<p>Pete Blose</p>
<p>Barnet, Vermont<br />
802-633-4152</p>
<p>49 CFR<br />
 . . .<br />
              § 195.581<br />
              Which pipelines must I protect against atmospheric corrosion and what coating material may I use?<br />
              (a) You must clean and coat each pipeline or portion of pipeline that is exposed to the atmosphere, except pipelines under paragraph (c) of this section.<br />
              (b) Coating material must be suitable for the prevention of atmospheric corrosion.<br />
              (c) Except portions of pipelines in offshore splash zones or soil-to-air interfaces, you need not protect against atmospheric corrosion any pipeline for which you demonstrate by test, investigation, or experience appropriate to the environment of the pipeline that corrosion will—<br />
              (1) Only be a light surface oxide; or<br />
              (2) Not affect the safe operation of the pipeline before the next scheduled inspection.</p>
<p>              § 195.583<br />
              What must I do to monitor atmospheric corrosion control?<br />
              (a) You must inspect each pipeline or portion of pipeline that is exposed to the atmosphere for evidence of atmospheric corrosion, as follows:</p>
<p>                If the pipeline is located:<br />
                  Then the frequency of inspection is:</p>
<p>                  Onshore<br />
                  At least once every 3 calendar years, but with intervals not exceeding 39 months.</p>
<p>                  Offshore<br />
                  At least once each calendar year, but with intervals not exceeding 15 months.</p>
<p>                (b) During inspections you must give particular attention to pipe at soil-to-air interfaces, under thermal insulation, under disbonded coatings, at pipe supports, in splash zones, at deck penetrations, and in spans over water.<br />
              (c) If you find atmospheric corrosion during an inspection, you must provide protection against the corrosion as required by § 195.581.</p>
<p>               § 195.585<br />
              What must I do to correct corroded pipe?<br />
              (a) General corrosion. If you find pipe so generally corroded that the remaining wall thickness is less than that required for the maximum operating pressure of the pipeline, you must replace the pipe. However, you need not replace the pipe if you—<br />
              (1) Reduce the maximum operating pressure commensurate with the strength of the pipe needed for serviceability based on actual remaining wall thickness; or<br />
              (2) Repair the pipe by a method that reliable engineering tests and analyses show can permanently restore the serviceability of the pipe.<br />
              (b) Localized corrosion pitting. If you find pipe that has localized corrosion pitting to a degree that leakage might result, you must replace or repair the pipe, unless you reduce the maximum operating pressure commensurate with the strength of the pipe based on actual remaining wall thickness in the pits.</p>
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