Document Accession 20190402?0014 Filed Date: 03/21/2019 ll. 1r elite-35,25: ?Eligi?ftgi COMMONWEALTH of VIRGINIA Department of Health M. Norman Oliver. MD. MA 0 BOX 2448 TN 7-1-1 OR State Health Commissioner RICHMOND. VA 23218 1-800-828-1120 March 21, 2019 The Honorable Kimberly D. Bose, Secretary Federal Energy Regulatory Commission (FERC) 888 First Street, NE Washington, DC 20426 Re: Docket 16-10-000, Mountain Valley Pipeline, LLC (MVP) Docket CP15-554-000, Atlantic Coast Pipeline (ACP) Dear Ms. Bose and Members of the Commission: We write to you in our respective positions as the Commissioner for the Virginia Department of Health (V DH) and the Director of the Virginia Department of Environmental Quality VDH and DEQ have received communications from constituents within the Commonwealth of Virginia expressing their concerns regarding the potential public health risks ?'om the 3M Skotchkote Fusion Bonded Epoxy (F BE) that is used to coat the Mountain Valley Pipeline (MVP) and the Atlantic Coast Pipeline (ACP). Our agencies contacted 3M Manufacturing Company, the United States Environmental Protection Agency, and the National Sanitation Foundation regarding the constituents? concerns. To date, these organizations have not shared or identi?ed any speci?c short-term or long?term risk with the use of FBE. The concerned Virginia residents, who have each sent direct correspondence to FERC and shared with us those letters (dated January 23, 2019), continue to believe there are health impacts with FBE, particularly when pipes are stored outdoors and exposed. Their concerns are particularly focused on the degradation and sloughing of the coating chalking), accelerated with prolonged exposure to sunlight and the environment, and how such material can potentially contaminate groundwater and potable water supplies. We have not identi?ed a direct response to these comments ?'om your of?ce; however, we note FERC provided the following response to public comments on the Final Environmental Impact Statement for the MVP (PS2A-130): ?the pipeline coating would not release dangerous chemicals into the groun v0 Topa?ddnhu?lu?m?le Meridian):th Document Accession 20190402-0014 Filed Date: 03/21/2019 The Honorable Kimberly D. Bose, Secretary March 21, 2019 Page 2 We understand this coating material has been used for a number of years and there is considerable industry and federal regulatory experience with the product and the chalking. VDH and DEQ have reviewed the environmental impact analysis (BIA). Both agencies provided FERC with comments when FERC considered permits for the Mountain Valley Pipeline and the Atlantic Coast Pipeline, applicable Material Safety Data Sheets, and other publicly available information. To date, neither VDH nor DEQ has found a speci?c environmental or public health risk with use of the coating material. VDH has identi?ed ?ve degradation products (benzene, styrene, benzophenone, benzoic acid, and benzaldehyde) that are listed in literature as being produced by photo-degradation of epoxy resins. VDH and DEQ would like to make sure there is opportunity to review all available technical guidance or health risk information that FERC, EPA, or 3M might have available on the toxicity and exposure pathways for this product, including the chalking substance. Speci?cally, VDH and DEQ would like to review the safety pro?le of FBE, the potential ability of the pipe coating and its photo-degradation byproducts to leach and impact the environment, your view of risks to the potable drinking water supplies, and any other documented health and safety hazard from the use of FBE as a pipeline coating. We kindly request that PERC provide DEQ and VDH with any additional information regarding the pipe coating material not found in the BIA. We appreciate your time and assistance. Should you have additional questions regarding this request or seek additional information, please contact Dr. Parham Jaberi, Chief Deputy Commissioner with the Virginia Department of Health, by email at or by 9110116 304-3647026- Respect?rlly, 44/ as) M. Norman Oliver, MD, MA State Health Commissioner Vir 'a Department of Health vid 1C Paylor Director Virginia Department of Environmental Quality Document Accession #: 20190402-0014 Filed Date: 03/21/2019 Document Content(s) 15204491.TIF .............................................................1