Document Accession #: 20200918-5099

Filed Date: 09/18/2020

Kimberly Bose, Secretary
Federal Energy Regulatory Commission
888 First Street, NE
Washington, DC 20426
Re: Atlantic Coast Pipeline CP15-554-000, CP15-554-001, CP15-555-000
Comments on Tox Strategies August 27, 2020 Pipe Coating Study
September 18, 2020
Secretary Bose:
Please find my review of the Tox Strategies Pipe Chalking Impact
Assessment, Revision 1 dated August 27, 2020, which was submitted by
Dominion Energy Transmission Inc. to FERC on August 31, 2020. The
report states that the fusion bonded epoxy coating used on the Atlantic
Coast Pipeline is not a threat to the public health, or the environment. This
same coating is used on the Mountain Valley Pipeline, and other pipelines
across our country.
I find that the report uses questionable methodology and unfounded
assumptions, thereby producing unreliable conclusions.
The report does not resolve the potential negative impacts to the public
health and the environment from this coating, including degradation of the
coating from inappropriate storage in the sun for over 4 years. These
potential negative impacts remain unresolved.
Since this report was commissioned by Dominion Energy Transmission,
Inc. I believe there is an inherent conflict of interest in its preparation.
The report should be reviewed and evaluated for methodology and
reliability by a truly independent agency, organization, or person with
expertise in these matters.
FERC should publicly comment, and require action to protect the public
health and the environment until such time that an independent expert
analysis confirms that there are no negative impacts to the public health or

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the environment from the coating, if that is what independent expert
analysis concludes.
My comments are generally in a format listing statements in the report
followed by a critique, comment, or question pertaining to that statement in
bold.

1

Introduction and Update

Chalking is caused by a reaction between the FBE coating constituents and
ultraviolet (UV) light (i.e., sunlight), resulting in a layer of chalky substance
adhering to the pipe surface.
The chalky material can disadhere from the pipe surface. Per coating
manufacturer 3M in a Technical Brief, UV Protection of Coated
Pipe…”Thickness loss is caused by alternate chalking and removal of
this loose surface material by wind, rain, tidal splash, or blowing
particulate.”
This (chalky) layer is thousandths of an inch in thickness.
Nevertheless, due to the large size of the pipes this is a large volume
of chalky material. Per the above mentioned 3M Technical Brief a
yearly loss of 0.375 mil to 1.5 mils can occur. The pipes at this storage
yard and others have been left exposed to the sun for over 4 years at
this time. Therefore, these pipes could have lost more than 6 mils of
coating at this time. Six mils(or 6/1000 of an inch) of chalky coating on
the top half of a typical 42 inch by 40 foot pipe equates to 95 cubic
inches of chalky coating. Given the very large number of pipes on
this, and other sites, this is a large amount of potentially polluting
material that is being removed from these pipes.
No impact on human health or the environment.
This report fails to prove that there are no impacts due to
questionable methodology and assumptions.

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Filed Date: 09/18/2020

The study was conducted at the Morgantown, WV pipe storage yard, but
the results should be the same as the other pipe storage yards.
The Morgantown site is unique from the other ACP pipe storage
yards.
I have been advised that the Morgantown site was previously used for
two fracking pads and a RCRA site. Background soils and dust at this
site are likely already be contaminated. Other sites in Virginia and
North Carolina are warmer and receive more UV from sunlight. Per the
3M technical brief quoted above warmer temperatures and increased
UV would tend to degrade the coating quicker. Other sites may have
areas of human habitation closer to the pipe storage location,
especially the Culpeper storage site, which has a residential housing
development nearby.
Background soil samples were taken upwind of the pipe storage site.
The stated upwind location from where soil samples were taken to the
northwest of the pipe stockpile contradicts information presented in
the AERMOD study. The AERMOD study indicates that the highest
levels of degraded coating would be blown in the approximate area of
the background soil samples. This indicates that the background soil
sample site is a downwind location. This invalidates the background
soil sample results, since that soil may have been contaminated by
blowing coating degradation material. See figures 5 and 6 AERMOD
results, and compare to figure 3.
The background soil sampling location may also have been
previously contaminated by prior industrial activities on this site,
including those mentioned above. It is likely that the background
sampling location has been affected by human activity.
Additionally the aerial photograph shows the background soil
sampling as cleared land, with what appear to be tracks through it,
and therefore affected by human activity in the near past.
2

Identification of Chemicals of Potential Concern

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Silicon was identified as a chemical of potential concern (COPC) per
Section 2.3
Silica is listed as a COPC in Section 2.5. Silicon is not included.
Neither silica nor silicon was sampled in the wipe samples or soil
samples as specifically requested in Enclosure A of David
Swearingen’s letter to Matthew Bley of June 30, 2020.
Epoxy Resin - Amine Condensate was not considered as a COPC.
The following sources indicate that cured epoxy resins, like the cured
coating on the ACP pipes, is likely not toxic. However, UV degraded
epoxy resin, as found on the ACP pipes should not be considered
cured. The degraded coating is in fine particulate matter form, and is
no longer encapsulated in the remaining intact coating.
Based on this information, I believe that epoxy Resin - Amine
Condensate should have been studied as a COPC.
From British Journal of Industrial Medicine, Bourne, Milner, and
Alberman 8/18/58…There is no doubt that epoxy resins/amine curing
systems can now be considered as toxic. Amines are more chemically
reactive than epoxy resins and are capable of producing considerable
pathological disturbance although the resins are less likely to do so.
From Wikipedia…The primary risk associated with epoxy use is often
related to the hardener component and not to the epoxy resin itself.
Amine hardeners in particular are generally corrosive, but may also
be classed as toxic or carcinogenic/mutagenic. Aromatic amines
present a particular health hazard (most are known or suspected
carcinogens), but their use is now restricted to specific industrial
applications, and safer aliphatic or cycloaliphatic amines are
commonly employed.
From Nils Malmgren AB Safety…When working with epoxy and
Hardener Most uncured epoxies and curing agents are toxic or
harmful to aquatic organisms and may cause long term adverse
effects in the aquatic environment. Therefore, it is important to

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remember not to throw uncured residues in household rubbish.
Uncured residue shall be submitted as hazardous waste at the
nearest waste facility. Cured epoxy is to be regarded as harmless.
3M’s material declaration for its product states:
In the case of chalking, the resulting molecules will be aldehydes (which
react with water to make carboxylic acids), amides (which further degrade
into amines and carboxylic acids), various aromatics similar in structure to
either xylene, substituted phenols, bisphenol A, aniline, methylated anilines
and water.
This quote excludes the 3M statement in same document that “a few
of the photo-degradation products will be toxic to aquatic life.”

3

Sampling and Analysis

Records indicate that the pipes sampled have been exposed to direct
sunlight since at least September 2017.
Pipes were first delivered to ACP storage yards in June of 2016, and
they were stored in the sun at the Dura Bond plant prior to that. The
pipes have been exposed to sunlight for well over 4 years at this time.
Figure 1 - On site soil sampling locations are shown at the end of the pipe
rows
Soil contaminant concentrations would be lower at the end of the pipe
rows than at the center of pipe rows, and therefore these are
unrepresentative sampling locations. The soil samples should have
been taken under the pipe in the center of the rows.
Furthermore, based on the position of the pipe stacks and the
sediment trap shown in Figure 3, runoff from the pipe rows would
bypass most of the soil sampling locations.
Figure 2 - Typical sampling location

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This does not show wipe sample from pipe at top of stack as stated.
The pipe is resting on or near the ground. The top of a pipe at the top
of the stack is where the most UV damage and chalking occurs. If this
pipe was moved off the top of the stack it may have been rotated, and
the area wiped may have been at the bottom of the pipe. There is no
verification that the wipe samples were taken from the top portion of a
pipe at the top of the stack.
The soil sample location shown in this figure is not under a stack of
pipes. It is next to a single pipe, and is not representative of the soil
under the middle of a stack of pipes.
Figure 3 - Sampling locations during July 17, 2020 event
The same soil sampling locations as in the 2019 sampling are again at
end of pipe rows, in unrepresentative locations, rather than the
middle of the pipe rows.
The background soils sampling locations are located in an area that
has previously been disturbed, with visible disturbed ground and
tracking. Contradictory to the report, this area has been previously
affected by man’s activities.
Please note that there is another unidentified pipe storage yard to the
east of this storage yard that is shown on aerial photographs. It is
unclear if these are ACP pipes, or pipes from another project. It is also
unclear how this unidentified pipe yard would potentially contribute to
pollution in this area.
In the July 17, 2020 soil sampling, different techniques were used at the off
site and on site sampling locations. At the off site sampling locations no
photoionization detector (PID) was used, and samples were taken from 2
inches to 6 inches below the surface. At the on site sampling location a PID
test was conducted showing no response above 0.0 ppm, and soil samples
were taken from 6 inches to 12 inches below the surface.
Scientific justification for the disparate techniques needs to be made.

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An accurate comparison of findings may not be obtainable under this
methodology. Pollutant levels may be highest closer to the soil
surface.
Results of the wipe sample blanks from 2019 appear to have been
contaminated by dust at the site.
This contaminated dust indicates that the entire site or other parts of
the site may be contaminated. Background soil sample locations may
be contaminated as well. Further investigation is warranted given this
finding.
4

Sampling Results

Wipe and soil samples did not test for silica or silicon
Both silica and silicon are listed as COPC’s. Scientific justification for
not sampling for silica and silicon is warranted.
The results in Table 2, Table 3, and Table 4 show that no bisphenol A,
benzene, toluene, ethylbenzene, xylenes, MIBK, VOCs, or any of the
SVOCs identified as potential COPCs associated with FBE were detected
in any of the wipe or soil samples. These chemicals are not present in the
chalky residue on the pipes nor are they present in soils beneath the stored
pipes.
These chemicals may have been present in the samples in levels
below the sampling limit of detection. As previously stated, the on site
soil samples were not collected from soil beneath the pipes. They
were collected from soil next to the ends of the pipe stacks, and
therefore are not an accurate sample of soil below the pipe stacks.
Table 2 shows low limit of detection for VOC’s and SVOC’s as 5 ug/sample,
except for m,p-Xylenes with a low limit of detection as 10ug/sample.
I believe that lower limits of detection are available, and if so, why
were they not used?

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Tables 3, 4, and 6 show variable detection limits for the same substance
sampled.
Scientific justification for the different detection levels is warranted.
Wipe sample results are presented by the laboratory as micrograms (μg)
per sample. For each wipe sample, a 10-centimeter (cm) x 10-cm square
area (100 cm2) was marked on the side of the pipe. The area inside the
marked square was wiped carefully with a single wipe. This represents a
single wipe sample. Therefore, the μg/sample is equivalent to units of μg/
100 cm2; the units of μg/cm2 used in the impact assessment (see Section
5.1) were calculated by dividing the μg/sample results by 100.
In order for this conversion to be accurate each square centimeter in
the wipe area would have to be wiped, and this would be difficult to
achieve, especially in the corners of the wipe area.
5

Impact Assessment

In addition to the COPCs, arsenic, barium, and lead were detected in wipe
samples. These metals may be related to dust on the pipes rather than
FBE chalky residue as these elements were not detected by the elemental
analysis of FBE chalky residue.
This uncertainty needs to be resolved through further testing.
Such high concentrations are not expected to result from the dispersion of
pipe chalky residue into the environment because it is well-adhered to the
pipe surface.
As previously stated, the chalky material can disadhere from the pipe.
Per coating manufacturer 3M in a Technical Brief, UV Protection of
Coated Pipe…”Thickness loss is caused by alternate chalking and
removal of this loose surface material by wind, rain, tidal splash, or
blowing particulate.”
Measurements have shown that FBE coating exposed to sunlight will
experience only 1 to 2 mils (1 mil = 0.001 inch) of loss due to ultraviolet

 Document Accession #: 20200918-5099

Filed Date: 09/18/2020

light degradation14, which indicates that the total quantity of dust available
to be released to air from exposed coated pipes is extremely limited.
Footnote 14 International Pipeline Conference – Volume 2. ASME 2000.
IPC2000-181.
Cetiner, M. et al. 2000. UV Degradation of Fusion Bonded Epoxy Coating in
Stockpiled Pipes. 2000
The Cetiner study cited as footnote 14 specifically states
“Approximately 1.0-2.0 mils loss in coating thickness and a visible
reduction in gloss were observed at the 12 o'clock position after 16-21
months exposure.” The above statement in the Tox Strategies Report
again misstates the findings in the Cetiner Report, as did the Tox
Strategies report of August 23, 2019, which was previously submitted
to FERC.
As I commented in my rebuttal to the characterization of the Cetiner
study in the August 23, 2019 Tox Strategies Report comparing coating
loss from UV degradation in the Cetiner study to the ACP pipes, a
comparison is not possible given the greatly different climatic
conditions in the pipe storage locations. The pipes in the Cetiner
study were stored near the US/Canadien border
The Cetiner study was conducted in a cold dry climate in Grovedale,
northern Alberta, Canada, and North Dakota, where degradation
would be slower, compared to the hotter, more humid, and wetter
conditions found in the mid Atlantic and Southeast U.S. ACP pipe
storage locations, where degradation would be faster.
Grovedale, Alberta has an average annual temperature of 36.2 with
18.5 inches of precipitation per year. Plymouth, North Carolina has an
average annual temperature of 62.0 with 52 inches of rain per year.
The ACP pipes have been exposed to UV degradation for over 4 years
at this time, not 16-21 months, and they have been exposed to a much
hotter, much more humid, and much wetter climate than the pipes in
the Cetiner study. Therefore it is possible that the coating has
degraded at a faster rate than did the coating in the Cetiner study.

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As previously stated, due to the large size of the pipes, a large volume
of chalky material may have already been released. Per the above
mentioned 3M Technical Brief a yearly loss of 0.375 mil to 1.5 mils can
occur. The pipes at this storage yard and others have been left
exposed to the sun for over 4 years at this time. Therefore, these
pipes could have lost more than 6 mils of coating at this time. Six
mils(or 6/1000 of an inch) of chalky coating on the top half of a typical
42 inch by 40 foot pipe equates to 95 cubic inches of chalky coating.
Given the very large number of pipes on this, and other sites, this is a
substantial amount of potentially polluting material that is being
removed from these pipes.
During a Site visit by ToxStrategies (William Rish) on July 17, 2020, it was
observed that chalky residue can only be separated from the pipe surface
by aggressive wiping. The need for “aggressive scrubbing” with felt to
obtain a sample of residue was also observed by KTA-Tator during the
elemental analysis sampling.15 This observation indicates a low physical
potential for atmospheric releases from sloughing of FBE chalky residue. In
addition, rainfall will remove loose residue, and it rains 40 percent of the
days of the year in Morgantown, WV. Residue would need to be
replenished after a rainfall to be available for atmospheric release.
These observations do not agree with 3M’s Technical Brief, UV
Protection of Coated Pipe…”Thickness loss is caused by alternate
chalking and removal of this loose surface material by wind, rain, tidal
splash, or blowing particulate.”
Further, If aggressive scrubbing or wiping is needed to remove chalky
residue how is it possible to get a valid wipe sample, much less in all
100 square centimeters of the sample square, and particularly in the
corners of that square?
The 8/27/20 report indicates that an elemental analysis indicates chalky
residue has an average silicon content of 52.8% by weight, and an average
combined silicon and oxygen content of 90% by weight/Why wasn’t this
reported in the 2019 study? Appendix 4 was not included in
information submitted to FERC docket in the 8/23/19 report.

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An air dispersion screening model recommended by US EPA (AERMOD17)
was used with 5 years of local meteorological data to predict silica
particulate concentrations in air potentially emitted from the Site.
Footnote 17 states BEEST Suite v12.00 (Providence Engineering and
Environmental Group, LLC Copyright 2019) which is based on (AERMOD
19191, AERMET 19191, AERMINUTE 15272, AERMAP 18081,
AERSURFACE 13016, ISC3 02035, BPIPRM 04274, ISC-PRIME 04269)
The model used may not be an AERMOD model, but rather, based on
an AERMOD model.
Scientific justification for the use of this model should be presented.
The meteorological model used should be the most accurate model
available for this study.
The method by which the 5 years of meteorological data was used in
the modeling should be presented as well.
The following worst case assumptions were used:
2. Pipe degradation and the formation of residue available for atmospheric
release occurs at a constant daily rate, i.e., depletion of loose source
material by precipitation wash off or atmospheric release is assumed to be
replenished at a rate that maintains a constant atmospheric emission rate.
Based on Morgantown climate data, it rains 40 percent of the days per
year, thus air emissions are assumed to occur on 60 percent of the days.
These are not worse case assumptions. They are invalid
assumptions.
Atmospheric release at a constant daily rate is unrealistic. Varying
atmospheric conditions, like wind, and blowing particulate matter will
create varying release rates. During periods of heavy wind, and
especially with wind blown particulate matter, emission rates would
be substantially higher than the average emission rate. Additionally,
the degraded coating that is emitted during high wind events would

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travel much further than during average wind speeds
Air emissions can occur on a day with rain or other precipitation. In
fact, air emissions will likely be higher and travel further as a
rainstorm approaches due to increased wind, and blowing particulate
matter.
Attachment C AERMOD Model Parameterization Emission Rate - OTHER,
0.062 g/s
What does “other” mean, and how was 0.062 g/s determined?
Scientific justification for the stated emission rate is warranted.
Note that measurements of particle sizes performed during the elemental
analysis of chalky residual material showed an average particle size of 3.5μ
for samples taken from the Morgantown site and an average of 5.2μ for
samples from all pipe yard sites (Plymouth, NC; Fuquay-Varina, NC;
Clarksville, VA; Morgantown, WV).18 Thus, the PM2.5 particulate criterion
is not appropriate for comparison purposes (i.e., too low), although the
predicted maximum annual average concentration is below this criterion.
Particulate size from elemental analysis cannot be compared to
particulate size from wind removal. These are two distinctly different
physical coating removal processes.
The AERMOD worst case assumptions do not specify particulate size,
although the study states that the PM 2.5 particulate criterion is not
appropriate for comparison purposes. The PM 2.5 size should be used
as a worse case scenario, because the PM 2.5 size is most damaging
to human health.
All ACP pipe yards were not mentioned. Culpeper, VA and Bealeton,
VA were left out.
Table 8 compares predicted AERMOD silica concentrations to US EPA
PM2.5 and PM10 long term particulate matter exposure for the general
public.

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These comparisons are not valid. Silica inhalation is much more
dangerous than inhalation of most other substances, and silica is a
carcinogen by inhalation. An inhaled particle of silica at 2.5 is much
more dangerous than a general particle at 2.5.
Table 8 shows an OSHA 8 hour PEL level of 50 ug/cubic meter and
compares it to modeled maximum 8 hour average of 23.6 ug/cubic meter.
This comparison is not valid. OSHA limits are set for worker exposure
on the job, which is 8 hours per day, 5 days per week, for about 240
days per year, which equals 1,920 hours exposure per year. A
residential exposure rate would be much lower, based on full time
occupancy or 8,760 hours per year. Additionally, the OSHA level does
not take into account vulnerable populations, including the young, the
aged, and those with existing compromising health issues. This
would further further lower than residential exposure rate.
Due to the danger from breathing silica, and the fact that the EPA level
does not take into account vulnerable populations, some states have
substantially lower standards than the EPA regional screening level.
These include:
- Texas 2 PM
- Vermont 0.12 PM 10
- New York 0.06 PM 10.
At this time, and for the foreseeable future, persons living and
working near these pipe storage yards are at grave risk for Covid-19,
as are all of us. Any health impairment from breathing air borne silica
and other pollutants from a pipe storage yard makes them more
vulnerable to death, permanent disability, hospitalization, or severe
illness should they contract Covid-19.
6

Findings

These findings are not reliable due to the questionable methodology
and assumptions, previously stated, that were used in this study.
Below is information from two scientific sources regarding health

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impacts from breathing silica dust.
From Public Lab
Silica dust less than 10 μm is light enough and has enough surface
area to stay airborne long enough to travel beyond occupational
zones. A fraction of these smaller dust particles are also the most
damaging to the lungs.
Silica dust less than 5 μm in diameter is respirable, meaning it can
travel into the bronchial region and deposit in the gas-exchange zone
of the lungs. There, they can cause scarring, swelling, and the growth
of fibroids in alveoli, the deepest parts of the lungs.
The concentration of particulate matter that is cause for concern in
non-occupational exposure is much lower than in occupational
exposure. A person is at work typically only one-third of the day, and
usually spends more hours at home than work, including sleep. Also,
the exposed population in a non-occupational setting includes more
vulnerable people, such as children and the elderly, than the
workforce (which is often estimated as healthy young-adult and
middle-aged men in exposure risk studies). Children breathe more
deeply than adults, and their smaller body mass means that their
relative exposure to pollutants is much higher.
For all of these reasons, non-occupational exposure limits are set
lower than occupational exposure limits to protect human health. For
respirable crystalline silica, the difference between the two types of
exposure limits can be orders of magnitude, as OSHA’s occupational
exposure guidelines are to avoid exposures above 10 milligrams per
cubic meter, while Vermont’s non-occupational exposure guideline is
0.12 micrograms per cubic meter.
The nonprofit organization Environmental Working Group wrote an
expository piece on ambient airborne silica, in which they urged more
states to adopt respirable silica regulations and make the standards
no higher than 0.3 μm/m3 in order to protect vulnerable populations.

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From Environmental Working Group September 25, 2014 Danger In
The Air: Health Concerns For Silica In Outdoor Air
Silica-related lung disease is incurable and can be fatal, killing
hundreds of workers in the U.S. each year. The National Institute for
Occupational Safety and Health (NIOSH) has estimated that at least
2.2 million workers in the mining and construction industries are
exposed to inhalable silica each year. However, the Institute noted,
“There are no surveillance data in the U.S. that permit us to estimate
accurately the number of individuals with silicosis. The true extent of
the problem is probably greater than indicated by available
data” (Weissman and Schulte 2011).
In addition to the severe damage silica dust does to the lungs and
respiratory system, studies of miners have linked it to diseases such
as rheumatoid arthritis, systemic lupus erythematosus, scleroderma
and kidney damage (Makol 2011; Parks 1999). Exposure to high levels
has also been linked to heart problems, since the heart must work
harder when pulmonary tissues are injured.
There is no federal standard for ambient air exposure to silica outside
the workplace. Based on occupational data, the EPA came up with a
health-protective benchmark for crystalline silica in PM10 particles of
3 micrograms per cubic meter (µg/m3) (Gift 1997; US EPA 1996).
Crucially, however, EPA’s benchmark did not consider the risks of
exposure to vulnerable populations such as children or people with
respiratory disease.
EWG calculates that a truly health-based value for silica exposure in
outdoor air should be no higher than 0.3 µg/m3, and it may need to be
lower.
To date only Vermont and New York have met this threshold. Both
states have, in fact, set even more stringent silica exposure
guidelines of 0.12 µg/m3 and 0.06 µg/m3, respectively. In setting those
limits for silica in ambient air, New York and Vermont used a different
method than California or Texas. Both started from occupational

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exposure limits and applied an adjustment factor of 100 (10 x 10). This
combined factor of 100 takes into account the inherent toxicity of
silica and the variable vulnerabilities of the population.
One study of a sand and gravel facility in California found that at 750
meters (almost half a mile) downwind, the furthest point monitored,
the level of silica in the air was twice as high as at an upwind site
(Shiraki 2002). The silica content in particulate matter samples
decreased from 33 percent at the plant itself to 10 percent at 750
meters away (Shiraki 2002).

This findings indicate that silica dust is very dangerous, and that
federal and many state regulatory guidelines are not strong enough to
protect everyone, including vulnerable populations. They also
indicate that fine particulate silica dust can travel long distances
through the air.
I hereby call on FERC to require an independent expert review of the Tox
Strategies Report of August 27, 2020.
I also call on FERC to publicly comment on the potential public health and
environmental impacts of the coating used on the pipes for the Atlantic
Coast Pipeline.
I also call on FERC to order necessary actions to protect the public health
and the environment from the coating, until such time that reliable
independent expert analysis indicates that there are no public health or
environmental threats, if that is what independent expert analysis
concludes.

William F. Limpert
wflimpert@gmail.com
4102B Garfield Road
Smithsburg, MD 21783
301-416-0571

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cc David Swearingen, FERC
Anthony Rana, FERC
Julia Yuan, FERC

Filed Date: 09/18/2020

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Filed Date: 09/18/2020

Document Content(s)
Critique of Second Dominion Pipeline Coating Report.PDF...................1