by Marjorie L. Share
DC Water is about to undertake a major project in our backyard in the name of environmental protection, but its methods will impose unnecessary risks upon our community. These risks can be avoided, and a solution exists.
About 6,100 linear feet of century-old sewer infrastructure runs through Soapstone Valley, a national park lined with homes, apartments, schools and businesses. The sewer is scheduled to be refurbished. Unfortunately, DC Water has chosen a method that has been repeatedly shown to discharge high amounts of toxins into the air and water, including suspected carcinogens, hazardous pollutants and suspected endocrine-disrupting compounds.
The stakes are high because the Soapstone project leads the way for similar DC Water projects throughout the District.
On July 15th, 2021, DC Water engineer William Elledge told me that Inland Pipe Rehabilitation would be the contractor undertaking the project. He also told me in our phone conversation that a thermal method for installing and curing the new pipe linings would be used in Soapstone Valley. The method is called steam or hot water CIPP, which stands for cured-in-place pipes. And that was disturbing news. I had come to understand that an alternative method of sewer rehabilitation would substantially reduce pollution risks.
Two years ago, I was primarily concerned about preserving and protecting Soapstone Valley trees. DC Water made clear in a June 26, 2019 public meeting that the number of trees to be removed in the park depended on being able to reach work zones with “heavy equipment” vehicles that steam or hot water CIPP required. I thought to myself, smaller vehicles and less equipment would require narrower pathways and less construction for access roads, thereby leaving more trees standing. It was while looking for alternatives to the large environmental footprint that thermal CIPP would require that I found ultraviolet (UV) light CIPP.
My efforts to understand the difference between UV and thermal CIPP methods uncovered scientific studies, peer-reviewed journal articles and news reporting on the environmental and human health impacts of DC Water’s preferred method. The more I dug, the more concerned I became.
The White Plume
Phone and email exchanges with CIPP companies and engineers led me to Andrew Whelton, a Purdue University professor and civil and environmental engineer who has been studying CIPP since 2013. Whelton’s research has found that the legacy steam method is highly polluting, and should not be used without sweeping changes, especially in close proximity to homes, schools and businesses.
The source of pollution is the manufacture of plastic pipes on site. “This process releases harmful chemicals into nearby pipes and surrounding air,” Whelton told me.
DC Water and DC Department of Energy and the Environment told me in a recent email that the plume of white you will see rising into the air during the thermal CIPP process “is a cloud of steam.”
Not so, said Whelton. “Calling it steam is like calling a cigarette a piece of paper. Steam and paper sound harmless,” Whelton said. But it is “the waste from the manufacture of a plastic. It’s toxic. It’s a mixture of partially cured resin droplets, particulates, organic vapors (styrene and more than 29 other measurable VOCs and SVOCs) and some water vapor.”
His team’s 2017 U.S. National Science Foundation-funded study was the first evaluation of CIPP emissions into the air to be published in a peer-reviewed journal, the American Chemical Society’s Environmental Science and Technology Letters. Whelton and other researchers followed up with a study published in the 2019 Journal of Hazardous Materials, which noted that “[m]ore than 100 air contamination incidents have been associated with CIPP manufacturing sites.”
[Read more about the contents and amount of resin waste discharged at CIPP project sites.]
CIPP: Thermal vs UV
Invented in the 1970s, CIPP gained wider use in the 1990s. Utilities find it an attractive alternative to digging up and replacing buried pipes, since CIPP avoids the work of excavating long trenches and reduces soil, tree and traffic disturbances. It is also cheap and fast. Installers access pipes at manholes and feed in resin-soaked liners to blanket leaks, corrosion and other pipe damage. The lining is then cured (hardened) in place using either steam and hot water or ultraviolet light – and becomes the new pipe.
UV CIPP has been used in Europe for more than 20 years, and in the U.S. for more than 10 years. It is also the cleaner of the technologies. “UV does not inject water vapor, and the waste discharged into the air is likely only organic vapors,” said Dave Hutton of SEH, a Minnesota employee-owned engineering, architectural, environmental and planning firm which uses both steam and UV technologies.
Whelton concurs. “Evidence indicates that UV CIPP may be the least polluting option,” he said, “and possibly presents a lower risk to nearby bystanders and the environment.”
One reason utilities avoid UV CIPP is cost. Liners can be three to four times more expensive than the steam and hot water CIPP materials. Yet, several states and jurisdictions have switched to or encourage use of UV CIPP to reduce their air pollution magnitudes and to avoid styrene resins.
Mobile Plastic Manufacturing Sites in Neighborhoods
Steam CIPP is cheaper and faster because it is essentially mobile plastics manufacturing. But while PVC and other plastic pipes are manufactured in enclosed factories with filtration, ventilation and proper disposal regulated and built in, CIPP contractors discharge their plastic manufacturing waste into the air; they don’t capture it.
According to a federal agency which investigated contamination in Wisconsin, this pollution can remain in buildings for more than a month. The chemicals can travel into nearby buildings through sewer laterals, HVAC and intake systems, windows, doors and foundation leaks. A variety of illnesses and injuries have been reported. Scientific American, in a November 2019 article, documented several cases in which children and adults near CIPP work sites experienced symptoms including headaches, vomiting, and burning of the eyes, nose and throat.
Water pollution is another concern. The Virginia Department of Transportation temporarily banned steam CIPP in 2005, after an employee noticed a filmy resin leaching into a stream from a plastic-lined stormwater culvert that the state had recently installed. Further investigation found levels of styrene, which the EPA classifies as a “hazardous air pollutant,” that would have been toxic to water fleas and rainbow trout, species that biologists use to measure water quality. The source: uncured resin that escaped from the liner during installation.
A Failure to Consider Pollution Risks, and Community Questions Left Unanswered
The 2019 environmental assessment for the Soapstone sewer project failed to consider the pollution risks of steam or hot water CIPP. Nor did it mention climate impacts.
The public, in response to the Soapstone EA, did raise concerns. The hundreds of public comments included worries that hazardous pollutants would be discharged into the air.
ANC 3F’s July 2019 resolution approving DC Water’s proposal was conditional, based upon requested modifications to the environmental assessment. The ANC specified “consideration of ultraviolet curing for the lining method and to provide additional justification for DC Water’s preferred choice [of steam].” A reason for this stance was UV’s “environmental superiority potential.” The commissioners’ requests were never addressed.
And it was during the 2019 public comment period that former DC Water board member and neighborhood activist David Bardin found a copy of another DC Water Soapstone sewer assessment, published more than eight years earlier in March 2011. It was authored by a different team of engineers who recommended UV curing. We never learned what changed during those intervening years and why.
In April 2020, the National Park Service declared that “there would be no significant environmental impacts projected to occur.” The following month, DC Water announced that it had NPS approval to proceed.
The system that was supposed to allow for analysis and clarity, public input and dialogue, edification and review has let us down. The stakes remain high. Still and now, I believe that there is a way to do better and right – with quality and integrity.
What Can Be Done
Several options exist for DC Water and parties involved, including the community, to prevent endangering human health and the environment.
As community members, we can:
- Attend the next community meeting. ANC 3F and DC Water are jointly hosting a special meeting on the Soapstone sewer project at 7 p.m. on Tuesday, December 7th. We will have an opportunity to learn from DC Water the environmental and human health impacts it specified to firms bidding on the Soapstone contract, and what terms the selected contractor, IPR, accepted or rejected.
- Submit testimony to the DC Council. On Friday, December 17th, three committees are holding a joint hearing on climate resiliency planning in the District. Members of the public are invited to testify live or submit testimony via email or voicemail.
DC Water and its contractor should:
- Use the cleaner of the CIPP technologies. That is UV CIPP, which is a less polluting and destructive technology, if not for the Soapstone project, for others going forward.
- Learn from other jurisdictions. To lessen chances of pollution, six states, including Virginia, California and New York, jointly asked Professor Whelton’s team to create a set of standards, guidelines and actions (see the report’s page 38) for transportation agencies to implement in CIPP contracts. These were developed to be included in the engineer’s bidding contract, and focus on topics such as minimizing air and water pollution, onsite monitoring and waste disposal.
- Present the community with plans and permits for air and water pollution controls. There should also be a notification process for an inspection that could force a shutdown of the project if it has found that pollutants have escaped.
And as for other agencies:
DOEE and NPS should exercise oversight. DC’s Department of Energy and Environment oversees air and water quality. The National Park Service oversees Rock Creek and tributaries including the Soapstone Valley. As such, DOEE and NPS should require proof of Clean Air Act and Clean Water Act pollution permits and mitigation measures of DC Water before construction begins. For example, air pollution should be captured so that it does not exit the work site. Polluted water should be collected and properly discharged to an approved facility that can accept hazardous liquid waste. Air monitoring should be conducted to confirm no emissions entered the environment.
Repairing aging pipes (which themselves have the potential to impact our safety and well-being) need not endanger human health or our environment, especially when DC Water’s stated objective is to “protect their assets” and safeguard our well-being. DC Water at one time estimated losing 1,400 Soapstone Valley trees to the project, and has worked since then to bring that down to a far lower number. If DC Water can do that, so too can it avoid bringing unnecessary adverse environmental and health impacts of thermal CIPP on our community, our park and our city.
Marjorie L. Share is a museum professional, educator and author whose work has been published by, among others, the Smithsonian Institution, Johns Hopkins University and Robert Wood Johnson Foundation. She has lived in Forest Hills since 1986.