Document Accession #: 20201008-3001 Filed Date: 10/08/2020 FEDERAL ENERGY REGULATORY COMMISSION WASHINGTON, D. C. 20426 OFFICE OF ENERGY PROJECTS In Reply Refer To: OEP/DG2E/Gas Branch 4 Atlantic Coast Pipeline, LLC Atlantic Coast Pipeline Project Dominion Energy Transmission, Inc. Supply Header Project Docket Nos. CP15-554-000, CP15554-001, and CP15-555-000 Mountain Valley Pipeline, LLC Mountain Valley Pipeline Project Docket No. CP16-10-000 VIA First Class Mail October 8, 2020 Dr. M. Norman Oliver, State Health Commissioner Virginia Department of Health PO Box 2448 Richmond, VA 23218 Re: Fusion Bonded Epoxy (FBE) Coating for Pipes in the Atlantic Coast and Mountain Valley Pipeline Projects Dear Dr. Oliver: I am responding to the Virginia Department of Health’s (VDH) and the Virginia Department of Environmental Quality’s (VDEQ) March 21, 2019 joint letter in which the VDH and VDEQ conveyed citizen concerns over potential chalking of the FBE coating used for the Atlantic Coast and Mountain Valley Pipeline projects that may result from prolonged exposure to sunlight during storage of the pipes, and the potential impacts chalking residues may have on the environment as well as public health. Your letter also requested that the Federal Energy Regulatory Commission (FERC) provide the VDH and VDEQ with any updated information regarding the pipe coating material. On June 20, 2020, FERC staff requested that Atlantic Coast Pipeline, LLC (Atlantic) file additional information to clarify concerns that FERC staff had concerning Atlantic’s initial report on the matter, which was conducted by ToxStrategies, Inc. and Document Accession #: 20201008-3001 Filed Date: 10/08/2020 -2- filed with the FERC on August 23, 2019. On August 31, 2020, Atlantic filed a revised report, also prepared by ToxStrategies, which contained additional and clarifying information specific to the Atlantic Coast Pipeline Project (attached for your convenience). FERC staff has reviewed the revised report, along with all other pertinent materials on file, and has summarized the information in the attached memo. Specifically, the memo includes a process summary of the Atlantic Coast and Mountain Valley projects, as well as my staff’s summary of all pertinent FBE-related information filed into the project dockets by the applicants, other agencies (including that filed by the North Carolina Department of Health and Human Services and the U.S. Center for Disease Control’s Division of Community Health Investigations), as well as various citizen stakeholders. The memo also includes my staff’s conclusions regarding the FBE pipe coating. I am sending Dr. Parham Jaberi, whom you designated as a point of contact, an emailed version of this letter and enclosure, in addition to the mailed copy. If you have any questions or wish to discuss further, please call me at 202-502-6173, or via e-mail at david.swearingen@ferc.gov. Sincerely, David Swearingen, Chief Gas Branch 4 Division of Gas – Environment and Engineering Enclosures cc: Dr. Parham Jaberi, Chief Deputy Commissioner Virginia Department of Health PO Box 2448 Richmond, VA 23218 David K. Paylor, Director Virginia Department of Environmental Quality PO Box 1105 Richmond, VA 23218 Document Accession #: 20201008-3001 Filed Date: 10/08/2020 ENCLOSURE 1 March 21, 2019 letter from the Virginia Department of Health Document Accession #: 20201008-3001 Filed Date: 10/08/2020 Document Accession #: 20201008-3001 Filed Date: 10/08/2020 Document Accession #: 20201008-3001 Filed Date: 10/08/2020 ENCLOSURE 2 August 2020 revised ToxStrategies Pipe Chalking Impact Assessment Report Document Accession #: 20201008-3001 Filed Date: 10/08/2020 Pipe Chalking Impact Assessment Revision 1 AUGUST 27, 2020 Document Accession #: 20201008-3001 Filed Date: 10/08/2020 Document Accession #: 20201008-3001 Filed Date: 10/08/2020 Table of Contents 1 Introduction and Update........................................................................................... 5 2 Identification of Chemicals of Potential Concern ................................................... 6 2.1 Safety Data Sheet (SDS) for Scotchkoteä Fusion-Bonded Epoxy Coating 6233 ......................................................................................................... 6 2.2 Material Declaration on 3M EMD Products sold in the USA.......................... 6 2.3 Elemental Analysis of FBE Chalky Residue ...................................................... 7 2.4 Information from FBE Leach Testing ............................................................... 8 2.5 Summary of COPCs............................................................................................. 8 3 Sampling and Analysis .............................................................................................. 9 4 Sampling Results...................................................................................................... 16 5 Impact Assessment .................................................................................................. 23 5.1 Wipe sample assessment .................................................................................... 23 5.2 Silica inhalation assessment .............................................................................. 23 5.3 Soil assessment.................................................................................................... 28 6 Findings .................................................................................................................... 31 List of Figures Figure 1. Locations of chalky residue samples and soil samples during June 26, 2019 and August 7, 2019 events................................................................... 11 Figure 2. Typical sampling location showing five wipe panels and soil sample (orange pin flag) ........................................................................................... 12 Figure 3. Sampling locations during July 17, 2020 event ................................................ 15 Figure 4. Pipe yard as area source with fenceline and setback used in AERMOD .......... 26 Figure 5. AERMOD results – worst-case annual average silica concentrations .............. 27 Figure 6. AERMOD results – worst-case maximum 8-hour average silica concentrations ............................................................................................... 27 List of Tables Table 1. Elemental Content from Laboratory Analysis of Coating Chalk Residue. KTA-Tator, Inc. Project No. 370672-5 .......................................................... 8 Document Accession #: 20201008-3001 Filed Date: 10/08/2020 Table 2. Laboratory analysis results for pipe wipe samples .............................................. 18 Table 3. Laboratory analysis results for soils – metals, bisphenol, SVOCs ...................... 19 Table 4. Laboratory analysis results for soils – VOCs ..................................................... 20 Table 5. Laboratory results for wipe blank samples – July 17, 2020 ................................ 22 Table 6. Laboratory results for site-specific background soil samples ............................. 22 Table 7. Comparison of wipe sample results to WTC settled-dust screening levels........ 24 Table 8. Worst-case predicted silica air concentrations compared to criteria ................... 28 Table 9. Comparison of detected soil concentrations to background and screening levels ............................................................................................................. 30 Table 10. Comparison of detected sediment concentrations to background and screening levels ............................................................................................ 30 Document Accession #: 20201008-3001 1 Filed Date: 10/08/2020 Introduction and Update ToxStrategies, Inc. (ToxStrategies)1, was retained by Dominion Energy Transmission, Inc. (Dominion), on behalf of Atlantic Coast Pipeline, LLC and itself, to collect data and assess potential environmental and human health impacts from the chalky residue (chalking) present on the outside surface of some pipe that is stockpiled in storage yards. The pipe has a fusion-bonded epoxy (FBE) coating. 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. This layer is thousandths of an inch in thickness. ToxStrategies identified the chemicals of potential concern (COPCs) contained in the chalky residue, sampled chalky substance from pipes, analyzed them for COPC concentrations, and sampled and analyzed the concentrations of COPCs in soils directly beneath chalked pipe-sample locations. The results of laboratory analyses were used to assess potential environmental and human health impacts of the pipe chalky substance. Sampling was performed on pipe stored at Dominion’s Morgantown, West Virginia, storage yard (Site). Based on information from Dominion, the pipe at all locations is coated with the same composition of FBE (i.e., Scotchkoteä Fusion-Bonded Epoxy Coating 6233) from the same manufacturer (i.e., 3M). Thus, it can be reasonably expected that results from pipes at the Site will be representative of chalky residue at other pipe storage yard locations. In response to a Data Request from Federal Energy Regulatory Commission (FERC) dated July 3, 2019, DETI submitted ToxStrategies’ original Pipe Chalking Impact Assessment on August 23, 2019. That assessment indicated no impact on human health or the environment from the chalky residue. Update In a letter dated June 30, 2020, FERC requested information related to assessing the potential environmental and human health impacts of FBE pipeline coating, including information regarding the ToxStrategies impact assessment at pipeline storage yards. The updated assessment presented in this report provides the requested information and incorporates it into a revised assessment. The additional information includes, as requested by FERC: 1 . • Site specific background soil samples taken up-slope and up-wind at the Site. • An explanation of unit conversion on wipe sample results. See Attachment A for a statement of qualifications for ToxStrategies and Attachment B for William Rish, Ph.D. curriculum vitae. Document Accession #: 20201008-3001 Filed Date: 10/08/2020 • New blank wipe sample analyses, with results indicating no adjustment of wipe sample results for COPCs in blank wipes is needed. • Air quality modeling of potential silica releases to the atmosphere. • Sampling results for volatile organic chemicals (VOCs) in soils. The revised assessment continues to indicate no impact on human health or the environment from the chalky residue. 2 Identification of Chemicals of Potential Concern The following sources of information were used to identify COPCs. 2.1 Safety Data Sheet (SDS) for Scotchkoteä Fusion-Bonded Epoxy Coating 62332 Section 3 of the SDS provides the composition of the FBE, as follows: The SDS indicates that FBE consists mostly (61%–80%) of bisphenol A compounds (including bisphenol A and 4,4’- isopropylidenediphenol), calcium and silica (20%–40%), and a small percentage of titanium dioxide (0.1%–1%). Based on this composition, bisphenol A, calcium, silica, and titanium were identified as COPCs for the assessment. 2.2 Material Declaration on 3M EMD Products sold in the USA3 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 2 3M Safety Data Sheet, 3M Scotchkoteä Fusion-Bonded Epoxy Coating 6233, Section 3. 3M Company. May 10, 2019. 3 Material Declaration on 3M EMD Products sold in the USA (3Mä Scotchkoteä Fusion Bonded Epoxy Coatings and 3Mä Scotchkoteä Liquid Epoxy Coatings). 3M Electrical Markets Division. Austin, TX. October 23, 2018. Document Accession #: 20201008-3001 Filed Date: 10/08/2020 acids), various aromatics similar in structure to either xylene, substituted phenols, bisphenol A, aniline, methylated anilines and water. 3M has stated that this information is based on relevant literature4 and not testing. As such, while epoxy photodegradation may have the potential to result in these molecules and reactions, there are no data supporting their occurrence. Nevertheless, these chemicals were included as COPCs in this assessment. Exposure to aniline is associated with potential adverse health effects. Substituted phenols may include the EPA priority pollutants phenol; 2-chlorophenol; 2,4-dichlorophenol; 2,4,6-trichlorophenol; pentachlorophenol; 2-nitrophenol; 2,4-dinitrophenol; and 2-methyl4,6-dinitrophenol. Conservatively, based on this information about potential degradation products, xylenes, bisphenol A, aniline, phenol, 2-chlorophenol, 2,4-dichlorophenol, 2,4,6-trichlorophenol, pentachlorophenol, 2-nitrophenol, 2,4-dinitrophenol, and 2-methyl-4,6-dinitrophenol were included as COPCs. 2.3 Elemental Analysis of FBE Chalky Residue KTA-Tator, Inc. performed an elemental analysis of chalky residue samples, including samples taken from pipe in the Site.5 Referring to Table 1, reproduced from the report, elemental scans determined that the chalky residue contains silicon and oxygen as major elements, calcium and titanium as minor elements, and occasional occurrences of aluminum, iron, phosphorus, potassium, and sulfur. Based on these findings, aluminum, iron, calcium, potassium, silicon, and titanium were identified as COPCs. The elemental analysis indicated that the chalky residue is generally 80 to 90 weight percent silicon and oxygen. Phosphorus and sulfur were identified as “occasional occurrences,” not major or minor elements in the residue. Further, these elements were present in only two of the twelve samples. Phosphorus was not selected as a COPC, because it was determined to be minor element in chalk residue and has low toxicity, unless it is white phosphorus (it is not). Phosphorus is an essential nutrient and is typically consumed in food.6 Like phosphorus, sulfur is of low toxicity and poses very little, if any, concern for human health.7 After 4 S. C. Lin, B. J. Bulkin, and E. M. Pearce. 1979. Application of Fourier Transform IR to Degradation Studies of Epoxy Systems. Journal of Polymer Science: Polymer Chemistry Edition, Vol. 17,3121-3148. John Wiley & Sons, Inc. 5 Laboratory Analysis of Coating Chalk Residue. KTA-Tator, Inc. Project No. 370672-5. KTA-Tator, Inc., Pittsburgh, PA. April 18, 2019. 6 Razzaque MS. 2011. Phosphate toxicity: New insights into an old problem. Clin Sci (Lond) 120(3):91– 97. doi: 10.1042/CS20100377. 7 EXTOXNET. 1995. Extension Toxicology Network. Sulfur. September. Document Accession #: 20201008-3001 Filed Date: 10/08/2020 calcium and phosphorus, sulfur is the most abundant mineral in the human body. It is obtained through the diet.8 Sulfur was also not selected as a COPC. Table 1. Elemental Content from Laboratory Analysis of Coating Chalk Residue. KTA-Tator, Inc. Project No. 370672-5 2.4 Information from FBE Leach Testing In 1989, the results of leaching tests for various pipe coating materials showed methyl isobutyl ketone (MIBK) and xylenes in leachate from FBE-coated storage tanks filled with water.9 The study indicated rapid leaching, with 77% of leaching complete after 30 days in water, at which point, leachate concentrations of MIBK and xylenes were orders of magnitude below Safe Drinking Water Act Maximum Contaminant Levels (MCLs). In spite of such low potential leachate concentrations, MIBK and xylenes were selected as COPCs. 2.5 Summary of COPCs In summary, the following COPCs were identified for laboratory analysis and inclusion in the assessment: 8 Nimni ME, Han B, Cordoba F. 2007. Are we getting enough sulfur in our diet? Nutrition Metabolism (London) 4:24. 9 Alben K, Bruchet A, Shpirt E. 1989. Leachate from organic coating materials used in potable water distribution systems. Prepared for American Water Works Association, Denver, Colorado. Document Accession #: 20201008-3001 Filed Date: 10/08/2020 Bisphenol A MIBK Xylenes Aniline Phenol 2-chlorophenol 2,4-dichlorophenol 2,4,6-trichlorophenol Pentachlorophenol 2-nitrophenol 2,4-dinitrophenol 2-methyl-4,6-dinitrophenol Aluminum Calcium Iron Potassium Silica Titanium In addition, because standard laboratory analytical methods include a longer list of metals (including the RCRA metals—arsenic, barium, cadmium, chromium, lead, mercury, selenium, and silver) and BTEX (benzene, toluene, ethylbenzene, and xylenes), these constituents were included in the laboratory analyses. 3 Sampling and Analysis On June 26, 2019 and August 7, 2019, sampling of pipe chalky residue and soils was performed at the Site. Sample locations were selected to ensure adequate spatial distribution across the Site, ensure that soil was present beneath the selected pipes, and avoid highly saturated soil from recent precipitation events. Ten (10) sampling locations (S-1 through S-10) were chosen, as shown on Figure 1. At each location, during the June 2019 event, five separate wipe samples of pipe chalky residue were collected; one each for metals, mercury, bisphenol A, BTEX and MIBK, and one QA wipe sample. Each set of wipe samples was collected from a different pipe surface at the approximate center of the pipe length. A single soil sample was collected from the soil located immediately beneath the section of pipe from which the wipe samples were collected. During the August 2019 event, a wipe sample and soil sample were taken from the same ten locations and analyzed for aniline, phenol, 2-chlorophenol, 2,4dichlorophenol, 2,4,6-trichlorophenol, pentachlorophenol, 2-nitrophenol, 2,4dinitrophenol, and 2-methyl-4,6-dinitrophenol. Figure 2 is a photograph of a typical wipe sampling location. Wipe samples were taken at the top layer of stacked pipe where direct exposure to sunlight (i.e., ultraviolet light) occurs. Records indicate that the pipes sampled have been exposed to direct sunlight since at least September 2017. Document Accession #: 20201008-3001 Filed Date: 10/08/2020 Laboratory analytical methods used were: Wipes Mercury Metals Bisphenol A BTEX and MIBK SVOCs NIOSH 9103 Mod. NIOSH 7300 Mod. by ICP-MS P&CAM 333 Solvent Panel Scan (GC/MS) EPA 8270D Soils Metals Extraction (prep) Metals Mercury Bisphenol A SVOCs EPA 3050 SW 6020A Method 7471B P&CAM 333 EPA 8270D The wipe samples were collected in accordance with laboratory-provided procedures. A clean, unused 10- by 10-centimeter cardboard square template was used to demarcate the sample area. Each sample was collected by wiping first in a vertical direction within the cardboard template, then folding the wipe to expose a fresh surface and wiping in a horizontal direction. Completed wipes were placed in clean sampling jars/vials supplied by the laboratory, and the jars were labeled and immediately placed on ice. Document Accession #: 20201008-3001 Figure 1. Filed Date: 10/08/2020 Locations of chalky residue samples and soil samples during June 26, 2019 and August 7, 2019 events 11 Document Accession #: 20201008-3001 Filed Date: 10/08/2020 Figure 2. Typical sampling location showing five wipe panels and soil sample (orange pin flag) 12 Document Accession #: 20201008-3001 Filed Date: 10/08/2020 Each soil sample was collected from the top 2 inches of soil, using a clean, single-use disposable plastic scoop to fill the laboratory-supplied jar. Following collection, the sample jar was labeled and immediately placed on ice. One equipment blank was collected for each matrix. A laboratory-provided trip blank was also included with the sample set. All samples were transferred to ALS Environmental (ALS) of Salt Lake City, Utah, under chain-of-custody procedures. Each sampling location was recorded using a portable sub-foot global positioning system unit and marked in the field using a pin flag (see Figure 2). Photo documentation of each sampling location was also collected. On July 17, 2020, additional sampling was performed at the Site in response to the request from FERC (see Section 1). Sample locations are shown on Figure 3. • Ten (10) background soil samples were obtained from an area up-wind and upslope of the Site and unaffected by human activity (see Figure 3). A single soil sample was collected at each location between 2 and 6 inches below surface grade. Surface vegetation was removed prior to sampling at each location. • To analyze soils for VOCs, a total of ten (10) soil samples (see Figure 3) were collected at the Site from directly under a section of pipe at the same locations as the June and August 2019 sampling events. These soil samples were collected from between 6 and 12 inches below surface grade. Prior to sampling, excavated soil was screened with a 10.6 electron volt (eV) photoionization detector (PID) from the surface to 6 inches below surface grade, and then at 3inch intervals from 6 to 12 inches below grade. No PID responses greater than 0.0 parts per million (ppm) were detected within any soil interval. Due to the lack of PID responses, soil samples were collected from the interval just above the terminal depth of each location (e.g. 9 to 12-inch interval). Three location (S-1, S-8, and S-9) could not be advanced to the target depth due to the presence of compacted gravel subbase material. In these locations, the sample was collected just above the terminal depth. • Results from wipe sample blanks taken during the June 26, 2019 event appear to have been contaminated by dust at the site. As such, these blank wipe results are no longer subtracted (as background) from pipe wipe sample results in this impact assessment. To confirm that blank wipes do not contain COPCs, four (4) new wipe sample blanks (WB-1 through WB-4) were collected in the Site area at locations where the 2019 pipe wipe samples were taken, WB-1 was collected at the location of S-2; WB-2 was collected at the location of S-4; WB3 was collected at the location of S-6; and WB-4 was collected at the location of S-9. The wipe blank samples were collected by opening the wipe sample pouch provided by the laboratory, removing the sample collection wipe and immediately placing the wipe into a laboratory-provided bottle. • A total of three (3) sediment samples (SED-1 through SED-3) were collected from the stormwater sediment basin adjacent to the inflow areas of the sediment Document Accession #: 20201008-3001 Filed Date: 10/08/2020 basin, as shown on Figure 3. These samples were obtained to help assess the potential for FBE chalky residue to be carried in stormwater runoff. Document Accession #: 20201008-3001 Filed Date: 10/08/2020 Figure 3. Sampling locations during July 17, 2020 event 15 Document Accession #: 20201008-3001 Filed Date: 10/08/2020 ToxStrategies 4 Sampling Results The detected concentrations of COPCs in the wipe samples and soil samples from the combined 2019 and 2020 sampling events are presented in Table 2 (wipes), Table 3 (soils – metals, bisphenol, SVOCs), and Table 4 (soils – VOCs). Table 5 presents the laboratory results for the new wipe blank samples. Table 6 presents the laboratory results for the sitespecific background soil sampling. The results can be summarized as follows: 10 • 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. • Wipe blank sample results in Table 5 show most analytes and all COPCs are below detection limits in the blank wipes, with only low levels of sodium, magnesium, and zinc detected at their reporting limits or, in the case of zinc, detected in the associated method blank (i.e., none of these are likely above detection limits). While it is common practice in interpreting analytical results to subtract the background concentration10 present in the wipe samples to determine the portion of the reported concentration that is actually associated with the medium being sampled (i.e., chalky residue), for conservatism this has not been done in the impact assessment. • 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. • Inorganic COPCs detected in wipe samples include aluminum, calcium, iron, potassium, and titanium. These detections are consistent with the findings of the elemental analysis of FBE (See Section 2.3). In addition to the inorganic 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; these elements were not detected by the elemental analysis of FBE chalky residue. • The elemental analysis results indicate that FBE chalky residue has an average silicon content of 52.8% by weight and an average combined silicon and oxygen Evaluation Guidelines for Surface Sampling Methods. Applied Industrial Hygiene Chemistry Team, Program Support Division and Methods Development Team, OSHA. T-006-01-0104-M. https://www.osha.gov/dts/sltc/methods/surfacesampling/surfacesampling.pdf 16 Document Accession #: 20201008-3001 Filed Date: 10/08/2020 content 90% by weight. These results indicate the presence of silica or other silicates (e.g., calcium silicate). • Inorganic COPCs detected in soil samples taken from under the pipe stacks include aluminum, calcium, iron, potassium, and titanium. While these elements are consistent with the findings of the elemental analysis of FBE chalky residue, these are also naturally occurring elements commonly found in soils. In addition to the inorganic COPCs, arsenic, barium, chromium, lead, and mercury were detected in soil samples. These are also naturally occurring elements found in soils. In fact, as presented in Section 5.3, concentrations in soil samples from beneath pipe stacks are less than average concentrations of metals in site-specific background soil samples, with the exception of calcium. • Table 6 presents the results of sampling and analysis for site-specific (i.e., Morgantown pipe storage area) natural background concentrations of metals. Ten (10) background soil samples were obtained from an area up-wind of the prevailing wind direction, topographically up-slope of the Site, and unaffected by human activity (see Figure 3). Document Accession #: 20201008-3001 Filed Date: 10/08/2020 ToxStrategies Table 2. Laboratory analysis results for pipe wipe samples Station Name Sample Date Field Sample ID Metals Aluminum Arsenic Barium Cadmium Chromium Iron Lead Mercury Potassium Selenium Silver VOCs 4-Methyl-2-pentanone Benzene Ethylbenzene m,p-Xylenes o-Xylene Toluene Other Bisphenol A diglycidyl ether Titanium Inorganics Calcium SVOCs 2,4,6-trichlorphenol 2,4-dichlorophenol 2,4-dinitrophenol 2-chlorophenol 2-nitrophenol 4,6-dintro-2-methylphenol aniline pentachlorophenol phenol S-1 S-2 S-3 S-4 S-5 S-6 S-7 S-8 S-9 S-10 Reporting 6/27/2019 6/27/2019 6/27/2019 6/27/2019 6/27/2019 6/27/2019 6/27/2019 6/27/2019 6/27/2019 6/27/2019 Units TOX002 S-1 TOX002 S-2 TOX002 S-3 TOX002 S-4 TOX002 S-5 TOX002 S-6 TOX002 S-7 TOX002 S- TOX002 S- TOX002 SZ062719 Z062719 Z062719 Z062719 Z062719 Z062719 Z062719 8 Z062719 9 Z062719 10 Z062719 ug/sample ug/sample ug/sample ug/sample ug/sample ug/sample ug/sample ug/sample ug/sample ug/sample ug/sample 61 0.097 1.2 <0.013 <0.13 23 0.28 <0.01 77 <0.5 <0.013 59 0.11 1.1 <0.013 <0.13 22 0.27 <0.01 74 <0.5 <0.013 25 0.2 0.57 <0.013 <0.13 26 0.16 <0.01 40 <0.5 <0.013 37 0.1 1.3 <0.013 <0.13 28 0.33 <0.01 77 <0.5 <0.013 72 0.13 1.2 0.015 <0.13 33 0.41 <0.01 100 <0.5 <0.013 46 0.23 0.53 <0.013 <0.13 32 0.31 <0.01 63 <0.5 <0.013 88 0.2 0.88 <0.013 <0.13 30 0.33 <0.01 47 <0.5 <0.013 54 0.21 0.84 <0.013 <0.13 34 0.33 <0.01 57 <0.5 <0.013 83 0.2 1.8 <0.013 <0.13 34 0.35 <0.01 67 <0.5 <0.013 34 0.18 <0.5 <0.013 <0.13 20 0.2 <0.01 39 <0.5 <0.013 ug/sample ug/sample ug/sample ug/sample ug/sample ug/sample <5 <5 <5 <10 <5 <5 <5 <5 <5 <10 <5 <5 <5 <5 <5 <10 <5 <5 <5 <5 <5 <10 <5 <5 <5 <5 <5 <10 <5 <5 <5 <5 <5 <10 <5 <5 <5 <5 <5 <10 <5 <5 <5 <5 <5 <10 <5 <5 <5 <5 <5 <10 <5 <5 <5 <5 <5 <10 <5 <5 ug/sample <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 ug/sample 0.75 0.71 0.8 0.93 1.3 1.2 1.6 1.2 1.4 0.96 ug/sample 380 370 210 550 430 270 470 640 620 540 ug/sample ug/sample ug/sample ug/sample ug/sample ug/sample ug/sample ug/sample ug/sample <5 <5 <5 <5 <5 <5 <5 <5 <5 <5 <5 <5 <5 <5 <5 <5 <5 <5 <5 <5 <5 <5 <5 <5 <5 <5 <5 <5 <5 <5 <5 <5 <5 <5 <5 <5 <5 <5 <5 <5 <5 <5 <5 <5 <5 <5 <5 <5 <5 <5 <5 <5 <5 <5 <5 <5 <5 <5 <5 <5 <5 <5 <5 <5 <5 <5 <5 <5 <5 <5 <5 <5 <5 <5 <5 <5 <5 <5 <5 <5 <5 <5 <5 <5 <5 <5 <5 <5 <5 <5 < means below detection limit value shown 18 18 Document Accession #: 20201008-3001 Filed Date: 10/08/2020 Table 3. Laboratory analysis results for soils – metals, bisphenol, SVOCs Station Name Reporting Sample Date Units Field Sample ID Sample Depth Metals Aluminum mg/kg Arsenic mg/kg Barium mg/kg Cadmium mg/kg Chromium mg/kg Iron mg/kg Lead mg/kg Mercury mg/kg Potassium mg/kg Selenium mg/kg Silver mg/kg Other Bisphenol A diglycidyl mg/kg Titanium mg/kg Calcium mg/kg SVOCs 2,4,6-trichlorphenol ug/kg 2,4-dichlorophenol ug/kg 2,4-dinitrophenol ug/kg 2-chlorophenol ug/kg 2-nitrophenol ug/kg 4,6-dintro-2-methylphenol ug/kg aniline ug/kg pentachlorophenol ug/kg phenol ug/kg S-1 6/27/2019 TOX002 S-1 0 - 0.2 ft S-2 6/27/2019 TOX002 S-2 0 - 0.2 ft S-3 6/27/2019 TOX002 S0 - 0.2 ft S-4 6/27/2019 TOX002 S-4 0 - 0.2 ft S-5 6/27/2019 TOX002 S-5 0 - 0.2 ft S-6 6/27/2019 TOX002 S-6 0 - 0.2 ft S-7 6/27/2019 TOX002 S-7 0 - 0.2 ft S-8 6/27/2019 TOX002 S-8 0 - 0.2 ft S-9 6/27/2019 TOX002 S-9 0 - 0.2 ft S-10 6/27/2019 TOX002 S-10 0 - 0.2 ft 3400 9.3 130 0.35 J 9 14000 11 0.018 J 510 0.85 J 0.25 J 6500 8.1 68 0.2 J 13 28000 16 0.03 570 <2.7 <0.54 4500 7.9 83 0.26 J 8.7 15000 10 0.0081 J 560 <2.7 <0.53 3300 7.1 59 0.33 J 6.7 12000 8.8 <0.02 560 1.3 J <0.51 4600 9.5 140 0.27 J 8.4 15000 10 <0.021 820 <2.8 <0.56 6100 7.2 140 0.17 J 13 24000 14 0.022 J 810 <2.8 <0.56 11000 1.1 290 0.31 J 17 29000 16 0.062 1100 <3.2 <0.64 5900 6.6 180 0.25 J 10 20000 15 0.019 J 760 <2.7 <0.53 4800 15 150 0.21 J 9.7 20000 14 0.016 J 530 <2.7 <0.54 6300 10 220 0.22 J 13 27000 17 0.04 770 <2.5 <0.49 <0.5 17 190000 <0.5 24 99000 <0.5 23 210000 <0.5 18 250000 <0.5 19 220000 <0.5 14 89000 <0.5 14 24000 <0.5 14 92000 <0.5 16 140000 <0.5 13 55000 <420 <420 <2100 <420 <420 <2100 <420 <2100 <420 <390 <390 <1900 <390 <390 <1900 <390 <1900 <390 <390 <390 <2000 <390 <390 <2000 <390 <2000 <390 <370 <370 <1900 <370 <370 <1900 <370 <1900 <370 <380 <380 <1900 <380 <380 <1900 <380 <1900 <380 <410 <410 <2000 <410 <410 <2000 <410 <2000 <410 <470 <470 <2400 <470 <470 <2400 <470 <2400 <470 <410 <410 <2000 <410 <410 <2000 <410 <2000 <410 <400 <400 <2000 <400 <400 <2000 <400 <2000 <400 <380 <380 <1900 <380 <380 <1900 <380 <1900 <380 < means below detection limit value shown 19 Document Accession #: 20201008-3001 Filed Date: 10/08/2020 Table 4. Laboratory analysis results for soils – VOCs Station Name S-1 S-2 S-3 S-4 S-5 S-6 S-7 S-8 S-9 S-10 Reporti Sample Date 7/17/20 7/17/20 7/17/20 7/17/20 7/17/20 7/17/20 7/17/20 7/17/20 7/17/20 7/17/20 ng Field Sample ID TOX006:S-1:S005007 TOX006:S-10:S007010 TOX006:S-2:S007010TOX006:S-3:S007010TOX006:S-4:S007010TOX006:S-5:S007010TOX006:S-6:S007010TOX006:S-7:S007010TOX006:S-8:S005006TOX006:S-9:S005007 Units Sample Depth 0.5 - 0.7 ft 0.7 - 1.0 ft 0.7 - 1.0 ft 0.7 - 1.0 ft 0.7 - 1.0 ft 0.7 - 1.0 ft 0.7 - 1.0 ft 0.7 - 1.0 ft 0.5 - 0.6 ft 0.5 - 0.7 ft VOCs by SW8260B 1,1,1,2-Tetrachloroethane ug/kg <6.3 <5.9 <6.2 <5.8 <6.3 <7.3 <6.1 <6.7 <5.9 <6.1 1,1,1-Trichloroethane ug/kg <6.3 <5.9 <6.2 <5.8 <6.3 <7.3 <6.1 <6.7 <5.9 <6.1 1,1,2,2-Tetrachloroethane ug/kg <6.3 <5.9 <6.2 <5.8 <6.3 <7.3 <6.1 <6.7 <5.9 <6.1 1,1,2-Trichloroethane ug/kg <6.3 <5.9 <6.2 <5.8 <6.3 <7.3 <6.1 <6.7 <5.9 <6.1 1,1-Dichloroethane ug/kg <6.3 <5.9 <6.2 <5.8 <6.3 <7.3 <6.1 <6.7 <5.9 <6.1 1,1-Dichloroethene ug/kg <6.3 <5.9 <6.2 <5.8 <6.3 <7.3 <6.1 <6.7 <5.9 <6.1 1,1-Dichloropropene ug/kg <6.3 <5.9 <6.2 <5.8 <6.3 <7.3 <6.1 <6.7 <5.9 <6.1 1,2,3-Trichlorobenzene ug/kg <6.3 <5.9 <6.2 <5.8 <6.3 <7.3 <6.1 <6.7 <5.9 <6.1 1,2,3-Trichloropropane ug/kg <6.3 <5.9 <6.2 <5.8 <6.3 <7.3 <6.1 <6.7 <5.9 <6.1 1,2,4-Trimethylbenzene ug/kg <6.3 <5.9 <6.2 <5.8 <6.3 <7.3 <6.1 <6.7 <5.9 <6.1 1,2-Dichloroethane ug/kg <6.3 <5.9 <6.2 <5.8 <6.3 <7.3 <6.1 <6.7 <5.9 <6.1 1,2-Dichloropropane ug/kg <6.3 <5.9 <6.2 <5.8 <6.3 <7.3 <6.1 <6.7 <5.9 <6.1 1,3-Dichloropropane ug/kg <6.3 <5.9 <6.2 <5.8 <6.3 <7.3 <6.1 <6.7 <5.9 <6.1 2,2-Dichloropropane ug/kg <6.3 <5.9 <6.2 <5.8 <6.3 <7.3 <6.1 <6.7 <5.9 <6.1 2-Butanone ug/kg <63 <59 <62 <58 <63 <73 <61 <67 <59 <61 2-Chlorotoluene ug/kg <6.3 <5.9 <6.2 <5.8 <6.3 <7.3 <6.1 <6.7 <5.9 <6.1 2-Hexanone ug/kg <6.3 <5.9 <6.2 <5.8 <6.3 <7.3 <6.1 <6.7 <5.9 <6.1 4-Chlorotoluene ug/kg <6.3 <5.9 <6.2 <5.8 <6.3 <7.3 <6.1 <6.7 <5.9 <6.1 4-Methyl-2-pentanone ug/kg <6.3 <5.9 <6.2 <5.8 <6.3 <7.3 <6.1 <6.7 <5.9 <6.1 Acetone ug/kg <63 <59 <62 <58 <63 <73 <61 <67 <59 <61 Benzene ug/kg <6.3 <5.9 <6.2 <5.8 <6.3 <7.3 <6.1 <6.7 <5.9 <6.1 Bromobenzene ug/kg <6.3 <5.9 <6.2 <5.8 <6.3 <7.3 <6.1 <6.7 <5.9 <6.1 Bromochloromethane ug/kg <6.3 <5.9 <6.2 <5.8 <6.3 <7.3 <6.1 <6.7 <5.9 <6.1 Bromodichloromethane ug/kg <6.3 <5.9 <6.2 <5.8 <6.3 <7.3 <6.1 <6.7 <5.9 <6.1 Bromomethane ug/kg <6.3 <5.9 <6.2 <5.8 <6.3 <7.3 <6.1 <6.7 <5.9 <6.1 Carbon Disulfide ug/kg <6.3 <5.9 <6.2 <5.8 <6.3 <7.3 <6.1 <6.7 <5.9 <6.1 Carbon Tetrachloride ug/kg <6.3 <5.9 <6.2 <5.8 <6.3 <7.3 <6.1 <6.7 <5.9 <6.1 Chlorobenzene ug/kg <6.3 <5.9 <6.2 <5.8 <6.3 <7.3 <6.1 <6.7 <5.9 <6.1 Chloroethane ug/kg <6.3 <5.9 <6.2 <5.8 <6.3 <7.3 <6.1 <6.7 <5.9 <6.1 Chloroform ug/kg <6.3 <5.9 <6.2 <5.8 <6.3 <7.3 <6.1 <6.7 <5.9 <6.1 Chloromethane ug/kg <6.3 <5.9 <6.2 <5.8 <6.3 <7.3 <6.1 <6.7 <5.9 <6.1 < means below detection limit value shown 20 Document Accession #: 20201008-3001 Filed Date: 10/08/2020 Table 4 (continued). Laboratory analysis results for soils – VOCs Station Name S-1 S-2 S-3 S-4 S-5 S-6 S-7 S-8 S-9 S-10 Reporti Sample Date 7/17/20 7/17/20 7/17/20 7/17/20 7/17/20 7/17/20 7/17/20 7/17/20 7/17/20 7/17/20 ng Field Sample ID TOX006:S-1:S005007 TOX006:S-10:S007010 TOX006:S-2:S007010TOX006:S-3:S007010TOX006:S-4:S007010TOX006:S-5:S007010TOX006:S-6:S007010TOX006:S-7:S007010TOX006:S-8:S005006TOX006:S-9:S005007 Units Sample Depth 0.5 - 0.7 ft 0.7 - 1.0 ft 0.7 - 1.0 ft 0.7 - 1.0 ft 0.7 - 1.0 ft 0.7 - 1.0 ft 0.7 - 1.0 ft 0.7 - 1.0 ft 0.5 - 0.6 ft 0.5 - 0.7 ft VOCs by SW8260B cis-1,2-Dichloroethene ug/kg <6.3 <5.9 <6.2 <5.8 <6.3 <7.3 <6.1 <6.7 <5.9 <6.1 cis-1,3-Dichloropropene ug/kg <6.3 <5.9 <6.2 <5.8 <6.3 <7.3 <6.1 <6.7 <5.9 <6.1 Dibromochloromethane ug/kg <6.3 <5.9 <6.2 <5.8 <6.3 <7.3 <6.1 <6.7 <5.9 <6.1 Dibromomethane ug/kg <6.3 <5.9 <6.2 <5.8 <6.3 <7.3 <6.1 <6.7 <5.9 <6.1 Dichlorodifluoromethane ug/kg <6.3 <5.9 <6.2 <5.8 <6.3 <7.3 <6.1 <6.7 <5.9 <6.1 Ethylbenzene ug/kg <6.3 <5.9 <6.2 <5.8 <6.3 <7.3 <6.1 <6.7 <5.9 <6.1 m,p-Xylenes ug/kg <13 <12 <12 <12 <13 <15 <12 <13 <12 <12 Methyl tert-Butyl Ether (MTBE) ug/kg <6.3 <5.9 <6.2 <5.8 <6.3 <7.3 <6.1 <6.7 <5.9 <6.1 Methylene Chloride ug/kg <25 <23 <25 <23 <25 <29 <24 <27 <24 <24 n-Butylbenzene ug/kg <6.3 <5.9 <6.2 <5.8 <6.3 <7.3 <6.1 <6.7 <5.9 <6.1 o-Xylene ug/kg <6.3 <5.9 <6.2 <5.8 <6.3 <7.3 <6.1 <6.7 <5.9 <6.1 p-Isopropyltoluene ug/kg <6.3 <5.9 <6.2 <5.8 <6.3 <7.3 <6.1 <6.7 <5.9 <6.1 Propylbenzene ug/kg <6.3 <5.9 <6.2 <5.8 <6.3 <7.3 <6.1 <6.7 <5.9 <6.1 sec-Butylbenzene ug/kg <6.3 <5.9 <6.2 <5.8 <6.3 <7.3 <6.1 <6.7 <5.9 <6.1 Styrene ug/kg <6.3 <5.9 <6.2 <5.8 <6.3 <7.3 <6.1 <6.7 <5.9 <6.1 tert-Butylbenzene ug/kg <6.3 <5.9 <6.2 <5.8 <6.3 <7.3 <6.1 <6.7 <5.9 <6.1 Tetrachloroethene ug/kg <6.3 <5.9 <6.2 <5.8 <6.3 <7.3 <6.1 <6.7 <5.9 <6.1 Toluene ug/kg <6.3 <5.9 <6.2 <5.8 <6.3 <7.3 <6.1 <6.7 <5.9 <6.1 trans-1,2-Dichloroethene ug/kg <6.3 <5.9 <6.2 <5.8 <6.3 <7.3 <6.1 <6.7 <5.9 <6.1 trans-1,3-Dichloropropeneug/kg <6.3 <5.9 <6.2 <5.8 <6.3 <7.3 <6.1 <6.7 <5.9 <6.1 Trichloroethene ug/kg <6.3 <5.9 <6.2 <5.8 <6.3 <7.3 <6.1 <6.7 <5.9 <6.1 Trichlorofluoromethane ug/kg <6.3 <5.9 <6.2 <5.8 <6.3 <7.3 <6.1 <6.7 <5.9 <6.1 Vinyl Chloride ug/kg <6.3 <5.9 <6.2 <5.8 <6.3 <7.3 <6.1 <6.7 <5.9 <6.1 Xylenes ug/kg <19 <18 <19 <17 <19 <22 <18 <20 <18 <18 1,2,4-Trichlorobenzene ug/kg <6.3 <5.9 <6.2 <5.8 <6.3 <7.3 <6.1 <6.7 <5.9 <6.1 1,2-Dichlorobenzene ug/kg <6.3 <5.9 <6.2 <5.8 <6.3 <7.3 <6.1 <6.7 <5.9 <6.1 1,3,5-Trimethylbenzene ug/kg <6.3 <5.9 <6.2 <5.8 <6.3 <7.3 <6.1 <6.7 <5.9 <6.1 1,3-Dichlorobenzene ug/kg <6.3 <5.9 <6.2 <5.8 <6.3 <7.3 <6.1 <6.7 <5.9 <6.1 1,4-Dichlorobenzene ug/kg <6.3 <5.9 <6.2 <5.8 <6.3 <7.3 <6.1 <6.7 <5.9 <6.1 Bromoform ug/kg <6.3 <5.9 <6.2 <5.8 <6.3 <7.3 <6.1 <6.7 <5.9 <6.1 Hexachlorobutadiene ug/kg <6.3 <5.9 <6.2 <5.8 <6.3 <7.3 <6.1 <6.7 <5.9 <6.1 Isopropylbenzene ug/kg <6.3 <5.9 <6.2 <5.8 <6.3 <7.3 <6.1 <6.7 <5.9 <6.1 Naphthalene ug/kg <6.3 <5.9 <6.2 <5.8 <6.3 <7.3 <6.1 <6.7 <5.9 <6.1 Dibromochloropropane (DBCP) ug/kg <6.3 <5.9 <6.2 <5.8 <6.3 <7.3 <6.1 <6.7 <5.9 <6.1 Ethylene Dibromide (EDB) ug/kg <6.3 <5.9 <6.2 <5.8 <6.3 <7.3 <6.1 <6.7 <5.9 <6.1 < means below detection limit value shown 21 Document Accession #: 20201008-3001 Filed Date: 10/08/2020 ToxStrategies Table 5. Laboratory results for wipe blank samples – July 17, 2020 Station Name Reporting Units Sample Date Field Sample ID WB-1 (S-2) WB-2 (S-4) WB-3 (S-6) 7/17/20 7/17/20 7/17/20 WB-4 (S-9) 7/17/20 TOX006: WB-1: Z071720 TOX006: WB-2: Z071720 TOX006: WB-3: Z071720 TOX006: WB-4: Z071720 Metals by SW6020A Aluminum mg/wipe <0.005 <0.005 <0.005 <0.005 Antimony mg/wipe <0.0025 <0.0025 <0.0025 <0.0025 Arsenic mg/wipe <0.0025 <0.0025 <0.0025 <0.0025 Barium mg/wipe <0.0025 <0.0025 <0.0025 <0.0025 Beryllium mg/wipe <0.001 <0.001 <0.001 <0.001 Cadmium mg/wipe <0.001 <0.001 <0.001 <0.001 Chromium mg/wipe <0.0025 <0.0025 <0.0025 <0.0025 Cobalt mg/wipe <0.0025 <0.0025 <0.0025 <0.0025 Copper mg/wipe <0.0025 <0.0025 <0.0025 <0.0025 Iron mg/wipe <0.04 <0.04 <0.04 <0.04 Lead mg/wipe <0.0025 <0.0025 <0.0025 <0.0025 Magnesium mg/wipe 0.13 0.12 0.13 0.13 Manganese mg/wipe <0.0025 <0.0025 <0.0025 <0.0025 Nickel mg/wipe <0.0025 <0.0025 <0.0025 <0.0025 Potassium mg/wipe <0.1 <0.1 <0.1 <0.1 Selenium mg/wipe <0.0025 <0.0025 <0.0025 <0.0025 Silver mg/wipe <0.0025 <0.0025 <0.0025 <0.0025 Sodium mg/wipe 0.12 <0.1 0.11 0.12 Thallium mg/wipe <0.0025 <0.0025 <0.0025 <0.0025 Vanadium mg/wipe <0.0025 <0.0025 <0.0025 <0.0025 Zinc mg/wipe 0.057 0.052 0.056 0.058 Titanium mg/wipe <0.0025 <0.0025 <0.0025 <0.0025 Calcium SW7471A mg/wipe <0.25 <0.25 <0.25 <0.25 Mercury ug/wipe <0.05 <0.05 <0.05 <0.05 Table 6. Laboratory results for site-specific background soil samples Station Name Sample Date Field Sample ID BG-01 BG-02 BG-03 BG-04 BG-05 BG-06 BG-07 BG-08 BG-09 BG-10 7/17/20 7/17/20 7/17/20 7/17/20 7/17/20 7/17/20 7/17/20 7/17/20 7/17/20 7/17/20 Reporting Units TOX006: BG-01: S000005 TOX006: BG-02: S000005 TOX006: BG-03: S000005 TOX006: BG-04: S000005 TOX006: BG-05: S000005 TOX006: BG-06: S000005 TOX006: BG-07: S000005 TOX006: BG-08: S000005 TOX006: BG-09: S000005 TOX006: BG-10: S000005 Sample Depth Metals by SW6020A 0.0 - 0.5 ft 0.0 - 0.5 ft 0.0 - 0.5 ft 0.0 - 0.5 ft 0.0 - 0.5 ft 0.0 - 0.5 ft 0.0 - 0.5 ft 0.0 - 0.5 ft 0.0 - 0.5 ft 0.0 - 0.5 ft Aluminum mg/kg 12,000 12,000 10,000 12,000 9,000 14,000 10,000 13,000 13,000 12,000 Antimony mg/kg <0.45 0.58 <0.41 <0.5 <0.46 <0.44 <0.57 <0.54 <0.44 <0.43 Arsenic mg/kg 7.1 8.6 9.1 7.5 7.3 2.9 5.1 9.2 8.8 15 Barium mg/kg 180 170 120 110 69 120 170 220 140 100 Beryllium mg/kg 1.5 1.6 1.2 1.6 0.91 1.4 2.8 1.7 1.4 1 Cadmium mg/kg 0.32 0.58 0.36 <0.2 <0.19 <0.18 0.54 0.43 <0.18 <0.17 Chromium mg/kg 17 21 19 21 19 18 13 15 27 25 Cobalt mg/kg Copper mg/kg 15 23 34 31 25 27 19 40 19 34 Iron mg/kg 30,000 35,000 33,000 41,000 44,000 38,000 18,000 29,000 45,000 43,000 Lead mg/kg 32 49 25 21 16 16 30 34 23 Magnesium mg/kg 1,200 1,200 1,600 1,200 800 2,700 1,300 950 1,500 790 Manganese mg/kg 3,400 2,500 1,300 2,200 630 1,900 1,600 3,300 2,200 1,200 Nickel mg/kg 18 25 22 24 13 46 38 15 29 53 Potassium mg/kg 790 860 950 830 810 1,200 1,200 730 1,100 660 Selenium mg/kg 0.71 0.98 0.79 0.71 0.6 <0.44 0.8 0.61 <0.44 <0.43 Silver mg/kg <0.45 <0.38 <0.41 <0.5 <0.46 <0.44 <0.57 <0.54 <0.44 <0.43 Sodium mg/kg <27 <23 <25 <30 <28 <26 <34 <33 <26 <26 Thallium mg/kg <0.45 <0.38 <0.41 <0.5 <0.46 <0.44 <0.57 <0.54 <0.44 <0.43 Vanadium mg/kg 27 29 28 30 28 17 22 30 34 34 Zinc mg/kg 52 67 74 56 48 86 67 63 56 Titanium mg/kg 71 74 71 75 66 51 74 110 70 78 Calcium SW7471A mg/kg 1,300 1,700 2,000 700 570 1,500 1,500 1,100 1,000 690 Mercury mg/kg 0.3 0.42 0.24 0.21 0.25 0.44 0.44 0.44 0.3 0.33 23 26 15 24 13 21 15 18 22 43 24 35 22 Document Accession #: 20201008-3001 Filed Date: 10/08/2020 ToxStrategies 5 Impact Assessment 5.1 Wipe sample assessment As summarized in Section 4, 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 pipe wipe samples. As shown in Table 5, inorganic COPCs detected in wipe samples include aluminum, calcium, iron, potassium, and titanium. These detections are consistent with the findings of the elemental analysis of FBE (See Section 2.3). 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. Note that the elemental analysis results also indicate that FBE chalky residue has an average silicon content of 52.8% by weight. While silicon was not included as an analyte by the laboratory, this percent content is used in the assessment of potential silica inhalation exposure presented in Section 5.2 below. In Table 7 the laboratory results averaged across the ten wipe sample locations are compared to settled-dust wipe-sample screening levels developed as health-based benchmarks for cleanup of residences affected by the World Trade Center (WTC) disaster.11 As shown in Table 7, the concentrations of chemicals detected in the FBE chalky residue wipe samples (including COPCs aluminum and iron) are orders of magnitude lower than the WTC settled-dust screening levels. This indicates that, if it is unrealistically (as a worst case) assumed that the dust in a residence is undiluted chalky residue directly from the pipe surface, constituents for which there are WTC screening levels (i.e., aluminum, arsenic, barium, copper, iron, lead, manganese, nickel, and zinc) would not present a significant risk to human health. Note that EPA did not develop a WTC screening level for calcium, based on it being a nutrient essential to human health. Rare toxic intake levels of calcium are associated only with the excessive use of calcium dietary supplements.12 5.2 Silica inhalation assessment A potential pathway for exposure to FBE chalky residue is sloughing of chalky residue from the pipe surface into the atmosphere with subsequent inhalation of respirable particles. Of particular interest is potential inhalation of silica particles. Silicon represents 11 World Trade Center indoor environment assessment: Selecting contaminants of potential concern and setting health-based benchmarks. Prepared by the Contaminants of Potential Concern (COPC) Committee of the World Trade Center Indoor Air Task Force Working Group (U.S. EPA, ATSDR, OSHA, New York City Department of Health and Mental Hygiene, New York State Department of Health). May 2003. 12 Ross AC, Taylor CL, Yaktine AL, et al. (Eds). 2011. Dietary reference intakes for calcium and vitamin D. Chapter 6 in: Tolerable Upper Intake Levels: Calcium and Vitamin D. Institute of Medicine (US) Review Press (US). 23 Document Accession #: 20201008-3001 Filed Date: 10/08/2020 ToxStrategies Table 7. Comparison of wipe sample results to WTC settled-dust screening levels Element Aluminum Arsenic Barium Copper Iron Lead Manganese Nickel Zinc Identified in Average elemental analysis of Concentration in Morgantown chalk Wipes residue (microgram/ cm2) Occasional occurrence Occasional occurrence WTC Settled Dust Screening Levels (micrograms/cm2) 0.56 0.0017 0.010 0.016 0.280 0.003 0.008 0.0010 0.840 157 0.04 11.0 6.3 94.1 0.03 3.1 3.1 47 a large portion of the chalky residue (52.8% by weight)13. Silicon and oxygen combined represents approximately 90% by weight. This indicates that the residue is largely silica (silicon dioxide) or some other silicate (family of anions consisting of silicon and oxygen). Silica is toxic by inhalation at percent concentrations in airborne dust. 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. 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 light degradation14, which indicates that the total quantity of dust available to be released to air from exposed coated pipes is extremely limited. 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, WV16. Residue would need to be replenished after a rainfall to be available for atmospheric release. To the extent that residue may slough into the atmosphere, there is a potential for inhalation exposure to silicate particles entrained and dispersed in air. An unrealistic worst-case assessment was performed to evaluate this potential exposure pathway. An air dispersion 13 See Appendix 4 of Laboratory Analysis of Coating Chalk Residue. KTA-Tator, Inc. Project No. 370672-5. KTA-Tator, Inc., Pittsburgh, PA. April 18, 2019. 14 Cetiner, M. et al. 2000. UV Degradation of Fusion Bonded Epoxy Coating in Stockpiled Pipes. 2000 International Pipeline Conference – Volume 2. ASME 2000. IPC2000-181. 15 See page 2 of Laboratory Analysis of Coating Chalk Residue. KTA-Tator, Inc. Project No. 370672-5. KTA-Tator, Inc., Pittsburgh, PA. April 18, 2019. 16 https://www.currentresults.com/Weather/West-Virginia/average-yearly-precipitation.php 24 Document Accession #: 20201008-3001 Filed Date: 10/08/2020 ToxStrategies 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. Details of this modeling are provided in Attachment C. The following worstcase assumptions were used: 1. The entire Site is an area source that is releasing at 12 feet 8 inches above the ground (height of 4 stacked 42-inch diameter pipes), as depicted in Figure 4. 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. 3. It is conservatively assumed, based on the combined silicon and oxygen weight percentages, that 90 percent of emitted chalky residue is silica, and all of this is in the respirable particle size range. To the extent the residue may contain calcium silicate, calcium silicate is not hazardous. 4. No reduction of modeled air concentrations due to wet or dry particle deposition loss is included. 5. Human receptors are assumed to be located 100 meters from the property fenceline. Referring to Figure 3, this is an unrealistic worst-case assumption near a large pipe storage yard of this type. The results of the air quality modeling are shown in Figure 5 (maximum annual average concentration across five years) and Figure 6 (maximum 8-hour average concentration during the five-year period). Table 8 shows a comparison of the modeling results to several available risk-based air quality criteria. As indicated in Table 8, the predicted silica air concentrations are below applicable risk-based criteria. This finding is particularly confident since, in addition to being based on unrealistic worst-case assumptions, the predicted concentrations are at locations unlikely to have long-term residents (i.e., within 100 meters of the property boundary). Concentrations decrease rapidly beyond this distance. As shown on Figure 4, there is no public presence within 300 meters of the fence line around the Morgantown pipe laydown yard. 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 17 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) 18 See Appendix 3 of Laboratory Analysis of Coating Chalk Residue. KTA-Tator, Inc. Project No. 3706725. KTA-Tator, Inc., Pittsburgh, PA. April 18, 2019. 25 Document Accession #: 20201008-3001 Filed Date: 10/08/2020 ToxStrategies particulate criterion is not appropriate for comparison purposes (i.e., too low), although the predicted maximum annual average concentration is below this criterion. Notes: Area source (red), Fenceline (inner blue line) and Setback (outer blue line). Guides of 100m (shown as pink lines) were used to define the Setback distance. Receptors were placed starting 100m from the fenceline and out to 500 m from the fenceline with 50 m spacing (black dots) Figure 4. Pipe yard as area source with fenceline and setback used in AERMOD 26 Document Accession #: 20201008-3001 Filed Date: 10/08/2020 ToxStrategies Figure 5. AERMOD results – worst-case annual average silica concentrations Figure 6. AERMOD results – worst-case maximum 8-hour average silica concentrations 27 Document Accession #: 20201008-3001 Filed Date: 10/08/2020 ToxStrategies Table 8. Worst-case predicted silica air concentrations compared to criteria AERMOD U.S. EPA Regional Predicted Screening Level Worst-Case (residential/worker) Silica Concentration U.S. EPA U.S. EPA OSHA 8PM2.5 PM10 hour Criteria Criteria average PEL (long-term (long-term general general (workers) population) population) Maximum annual average (µg/m3) 2.4 3.1/13 12 150 None available Maximum 8-hour average (µg/m3) 23.6 None available None available None available 50 Notes 1. 2. 5.3 U.S. EPA RSL applies to crystalline, respirable silica. For comparison, it is conservatively assumed that all residue dust is crystalline and in respirable size range. PM2.5 and PM10 criteria apply to long-term exposure by the general population to particulate matter (PM) with particle sizes at or below 2.5 microns and 10 microns, respectively. Soil assessment Table 9 compares laboratory results for soil samples taken beneath pipe stacks to sitespecific natural background levels (based on data summarized in Table 6) and risk-based screening levels established by U.S. EPA19 and West Virginia20 for the protection of human health, assuming residential land use. Table 10 presents a similar comparison for sediment samples taken from the stormwater basin that collects runoff from the Site (see Figure 3). As shown in Table 3 and Table 4 in Section 4 above, no bisphenol A, benzene, toluene, ethylbenzene, xylenes, MIBK, VOCs, or any of the SVOCs identified as potential COPCs was detected in any of the soil samples. As shown in Table 9, average concentrations detected in soil samples from beneath pipe stacks are at or less than the average concentrations of corresponding metals detected in site-specific background soil samples, with the exception of calcium. Detected concentrations of calcium at the Site are elevated with respect to natural background levels. 19 20 U.S. EPA. 2019. Regional Screening Levels. Residential soil table (TR=1E-06, HQ=1). https://semspub.epa.gov/work/HQ/199934.pdf West Virginia Voluntary Remediation and Redevelopment Rule (Title 60 Code of State Rules, Series 3). Table 60-3B. 28 Document Accession #: 20201008-3001 Filed Date: 10/08/2020 ToxStrategies Also demonstrated in Table 9, no chemicals detected in soil samples exceed U.S. EPA residential soil screening levels (RSLs) or West Virginia Voluntary Remediation Program (VRP) screening levels, with the exception of arsenic. Arsenic in soil samples exceeded its screening levels but was detected at or below natural background soil levels. This is not uncommon for U.S. soils. Note that the RSLs for Virginia21 and North Carolina22 are consistent with the U.S. EPA RSLs and West Virginia VRP screening levels. Table 10 shows similar results for sedimentation basin samples (i.e., elevated calcium levels compared to background, all remaining metals similar to background levels, all except arsenic meet EPA RSLs and WV VRP standards). The driving areas within the Site are salted in winter, which may be a likely source of elevated calcium concentrations in soil and storm water catch basin sediment. No laboratory analysis of soil samples was performed for silica. This is because silica (crystalline, respirable) has an EPA Regional Soil Screening Level (RSL)23 in residential soil of 4,300,000 mg/kg (i.e., more than 100 percent) based on a residential child inhalation pathway (most sensitive receptor). EPA also has an RSL for residential ambient air of 3.1 µg/m3, which was used in Section 5.2 above in evaluating inhalation risks. The ATSDR Toxicity Profile for silica24 states that, while crystalline silica presents an inhalation concern from an occupational standpoint, “given the ubiquitous nature of c-silica in the environment, it is assumed that incidental oral exposure of humans commonly occurs. No reports of adverse effects associated with incidental oral exposure to c-silica in the environment were identified.” These findings support a conclusion that silica in soil associated with release from chalky residue will not result in adverse health effects. 21 22 23 24 Virginia Department of Environmental Quality 2019. Voluntary Remediation Program (VRP) Screening Levels. Based on EPA Region 3 RSL Update: June 2019. North Carolina Department of Environmental Quality 2018. Preliminary Soil Remediation Goals (PSRG). February 2018. Title page states “based on November 2017 USEPA Regional Screening Tables”. U.S. Environmental Protection Agency (USEPA). 2019. Regional screening levels for chemical contaminants at Superfund sites. Agency for Toxic Substances and Disease Registry (ATSDR). 2019. Toxicological profile for silica. U.S. Department of Health and Human Services. September. 29 Document Accession #: 20201008-3001 Filed Date: 10/08/2020 ToxStrategies Table 9. Comparison of detected soil concentrations to background and screening levels Station Name Sample Date Field Sample ID Reporting Units Sample Depth S-1 S-2 S-3 S-4 S-5 S-6 S-7 S-8 S-9 S-10 6/27/2019 TOX002 S-1 S000002 6/27/2019 TOX002 S-2 S000002 6/27/2019 TOX002 S3 S000002 6/27/2019 TOX002 S-4 S000002 6/27/2019 TOX002 S-5 S000002 6/27/2019 TOX002 S-6 S000002 6/27/2019 TOX002 S-7 S000002 6/27/2019 TOX002 S-8 S000002 6/27/2019 TOX002 S-9 S000002 6/27/2019 TOX002 S-10 S000002 0 - 0.2 ft 0 - 0.2 ft 0 - 0.2 ft 0 - 0.2 ft 0 - 0.2 ft 0 - 0.2 ft 0 - 0.2 ft 0 - 0.2 ft 0 - 0.2 ft Aluminum Arsenic Barium Cadmium Chromium Iron Lead Mercury Potassium Selenium Silver Titanium Calcium mg/kg mg/kg mg/kg mg/kg mg/kg mg/kg mg/kg mg/kg mg/kg mg/kg mg/kg mg/kg mg/kg 3,400 9.3 130 0.35 J 9.0 14,000 11.0 0.018 J 510 0.85 J 0.25 J 17 190,000 6,500 8.1 68 0.2 J 13.0 28,000 16.0 0.03 570 <2.7 <0.54 24 99,000 4,500 7.9 83 0.26 8.7 15,000 10.0 0.0081 J 560 <2.7 <0.53 23 210,000 Bisphenol A diglycidyl mg/kg <0.5 <0.5 <0.5 2,4,6-trichlorphenol 2,4-dichlorophenol 2,4-dinitrophenol 2-chlorophenol 2-nitrophenol 4,6-dintro-2-methylphenol aniline pentachlorophenol phenol ug/kg ug/kg ug/kg ug/kg ug/kg ug/kg ug/kg ug/kg ug/kg <420 <420 <2100 <420 <420 <2100 <420 <2100 <420 <390 <390 <1900 <390 <390 <1900 <390 <1900 <390 <390 <390 <2000 <390 <390 <2000 <390 <2000 <390 3,300 7.1 59 0.33 J 6.7 12,000 8.8 <0.02 560 1.3 J <0.51 18 250,000 Other <0.5 SVOCs <370 <370 <1900 <370 <370 <1900 <370 <1900 <370 4,600 9.5 140 0.27 J 8.4 15,000 10.0 <0.021 820 <2.8 <0.56 19 220,000 0 - 0.2 ft Metals 6,100 7.2 140 0.17 J 13.0 24,000 14.0 0.022 J 810 <2.8 <0.56 14 89,000 11,000 1.1 290 0.31 J 17.0 29,000 16.0 0.06 1,100 <3.2 <0.64 14 24,000 5,900 6.6 180 0.25 J 10.0 20,000 15.0 0.019 J 760 <2.7 <0.53 14 92,000 4,800 15.0 150 0.21 J 9.7 20,000 14.0 0.016 J 530 <2.7 <0.54 16 140,000 On-Site Samples Background Soil Average 7/17/2020 Average 6,300 10.0 220 0.22 J 13.0 27,000 17.0 0.04 770 <2.5 <0.49 13 55,000 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <380 <380 <1900 <380 <380 <1900 <380 <1900 <380 <410 <410 <2000 <410 <410 <2000 <410 <2000 <410 <470 <470 <2400 <470 <470 <2400 <470 <2400 <470 <410 <410 <2000 <410 <410 <2000 <410 <2000 <410 <400 <400 <2000 <400 <400 <2000 <400 <2000 <400 <380 <380 <1900 <380 <380 <1900 <380 <1900 <380 EPA RSL WV VRP 0-0.5 ft 5,640 8.2 146 0.13 10.9 20,400 13.2 0.02 699 0.5 0.12 17 136,900 11,700 8.1 140 0.45 19.5 35,600 27.0 0.34 913 0.74 <0.38 74 1,206 77,000 0.68 15,000 71 120,000 55,000 400 7.8 na 390 390 na na 77,000 0.43 15,000 37 120,000 55,000 400 3.1 na 390 390 na na Table 10. Comparison of detected sediment concentrations to background and screening levels Station Name Sample Date Field Sample ID Sample Depth Aluminum Arsenic Barium Cadmium Chromium Iron Lead Mercury Potassium Selenium Silver Titanium Calcium Reporting Units SED-1 7/17/20 SED-2 7/17/20 Background 7/17/2020 TOX006: SED-1: D000005 TOX006: SED-2: D000005 TOX006: SED-3: D000005 0.0 - 0.5 ft mg/kg mg/kg mg/kg mg/kg mg/kg mg/kg mg/kg mg/kg mg/kg mg/kg mg/kg mg/kg mg/kg SED-3 7/17/20 0.0 - 0.5 ft 11,000 13 190 <0.23 17 25,000 15 0.29 2,000 0.95 <0.57 78 84,000 0.0 - 0.5 ft 11,000 15 160 <0.38 16 27,000 18 0.28 2,000 3 <0.95 91 40,000 EPA RSL Average WV VRP 0 - 0.5 ft 11,000 8.8 170 <0.21 15 33,000 19 0.15 1,500 <0.54 <0.54 65 33,000 11,700 8.1 140 0.45 19.5 35,600 27.0 0.34 913 0.74 <0.38 74 1,206 77,000 0.68 15,000 71 120,000 55,000 400 7.8 na 390 390 na na 77,000 0.43 15,000 37 120,000 55,000 400 3.1 na 390 390 na na 30 Document Accession #: 20201008-3001 Filed Date: 10/08/2020 ToxStrategies 6 Findings The following findings are supported by the assessment presented above, based on sampling and laboratory analysis of chalky residue from stored pipe, soil samples collected beneath the pipe, samples from the site runoff sediment basin, and worst-case air modeling of silica. 1. The assessment indicates no impact on human health or the environment from the chalky residue resulting from UV degradation of FBE coated pipe in outdoor storage. 2. Chalky residue appears to consist largely (about 90 percent by weight) of silicon and oxygen. The extent to which these elements are bonded in chalky residue to form silica or silicates is undetermined. The inhalation assessment conservatively assumes all 90 percent is silica. 3. No bisphenol A, benzene, toluene, ethylbenzene, xylenes, MIBK, VOCs, or any of the SVOCs identified as potential COPCs was detected in any of the ten wipe samples or ten soil samples. These chemicals are not present in the chalky residue or the soil beneath the stored pipe. 4. Concentrations of chemicals detected in the wipe samples are orders of magnitude lower than corresponding available WTC settled-dust screening levels. This indicates that the chalky residue meets standards set to protect human health for exposures to settled dust in a residence, for those chemicals detected in chalky residue and for which WTC screening levels are available (i.e., aluminum, barium, copper, iron, lead, manganese, nickel, and zinc). 5. Among the COPCs potentially associated with chalky residue, only calcium was found above natural background levels in soils sampled directly under the chalked pipe. This finding is consistent with the predominance of calcium detected in the wipe samples and the likely presence of calcium silicate. Calcium itself is a nutrient essential to human health as well as plant and animal growth25. Rare toxic intake levels of calcium are associated only with the excessive use of calcium dietary supplements.26 6. All detected levels of metals in soils directly beneath stored pipe are below EPA RSLs and West Virginia VRP screening levels based on residential land use, with the exception of arsenic. However, arsenic was detected in soils at 25 U.S. EPA 2007. Framework for Metals Risk Assessment. EPA 120/R-07/001, March 2007. U.S. EPA 2007. Framework for Metals Risk Assessment. EPA 120/R-07/001, March 2007. 26 Ross AC, Taylor CL, Yaktine AL, et al. (Eds). 2011. Dietary reference intakes for calcium and vitamin D. Chapter 6 in: Tolerable Upper Intake Levels: Calcium and Vitamin D. Institute of Medicine (US) Committee to Review Dietary Reference Intakes for Vitamin D and Calcium. Washington (DC): National Academies Press (US). 31 Document Accession #: 20201008-3001 Filed Date: 10/08/2020 ToxStrategies or below site-specific natural background levels. Naturally elevated arsenic levels in background soils is not uncommon across the United States. 7. Based on worst-case assumptions, there are no unacceptable inhalation risks presented by potential releases of chalky residual material to the air. As indicated in Table 8, the predicted silica air concentrations are well below EPA criteria for the protection of the general population. This finding is particularly confident since, in addition to being based on unrealistic worstcase assumptions, the predicted concentrations are at locations unlikely to have long-term residents (i.e., within 100 meters of the property boundary). Concentrations decrease rapidly beyond this distance. As shown on Figure 4, there is no public presence within 300 meters of the fence line around the Morgantown pipe laydown yard. 8. Because no bisphenol A, VOCs, or SVOCs were found in the chalky residue or associated soils, and all other COPC metals (with the exception of calcium) were found to be at or below natural background levels in soils located below the pipe and in sedimentation basin samples, no impacts to groundwater, surface water, or ecological receptors are expected from the chalky residue. Regarding calcium, there are no ecological screening levels for calcium because it is one of the abundant elements in the earth’s crust, its distribution is wide, and it is essential to both plant and animal growth. 32 Document Accession #: 20201008-3001 Filed Date: 10/08/2020 ToxStrategies ATTACHMENT A TOXSTRATEGIES, INC. GENERAL STATEMENT OF QUALIFICATIONS 33 DO NOT INFRINGE ON WHITE SPACE WHEN PLACING LOGO. Document Accession #: 20201008-3001 Filed Date: 10/08/2020 SPOT Overview of ToxStrategies’ Qualifications PMS 363 C CMYK PMS 363 PC C . . . . 78 M. . . . . 5 Y . . . . 98 K . . . . 24 ToxStrategies is a multidisciplinary scientific consulting firm that strives to develop innovative solutions to address the scientific, technical, and regulatory challenges confronting our clients. We have a reputation for applying sound science and novel approaches tailored to meet the specific needs of our clients, whether that need be for a rapid response or a comprehensive analysis is required. ONE Our Services Toxicology Experience includes systematic literature review; risk and safety assessment; derivation of toxicity criteria; design, placement, and oversight of toxicology studies; nanotechnology; neurotoxicology; reproductive and developmental toxicology. Computational Toxicology Efficiently predict chemical toxicity and integrate high-throughput exposure and toxicity data into risk assessments. Study chemical mode of action, adverse-outcome pathways, dose-response relationships, susceptibility differences between individuals, uncertainty, and risk. Systematic Reviews and Evidence-Based Toxicology (EBT) In the emerging field of EBT, apply scientific logic and systematic data evaluation to state-of-the-science hazard identification and classification, health effects causation, and disease management and prevention. Exposure Assessment Practice areas include biomonitoring, bioaccessibility/bioavailability, dose reconstruction, exposure simulation, California Proposition 65, and exposures from natural gas exploration and development GHS: OSHA and REACH/CLP Ensure compliance with the EU’s Registration, Evaluation, Authorization and Restriction of Chemical Substances (REACH) Regulation, as well as the UN’s Globally Harmonized System (GHS), including the EU Classification, Labeling and Packaging of Substances and Mixtures (CLP) Regulation and the US OSHA’s revised Hazard Communication Standard (HCS). PBPK and IVIVE Develop, apply, and evaluate high-throughput physiologically based pharma/toxicokinetic models, and in vitro–to–in vivo extrapolation models. Apply these computational methods to quantify relationships between exposures and toxicological responses. Results can facilitate drug discovery, product development, and chemical risk assessment. Air Quality & Exposure Perform risk and hazard assessments, exposure reconstruction, and computational modeling of chemicals in air. Ensure regulatory compliance (including Prop 65), assess indoor vapor intrusion and ambient air quality, and conduct chemical fingerprinting. Risk Assessment Skill sets include deriving cleanup levels, dose-response modeling, exposure assessment, risk communication, uncertainty analyses, and quantitative microbial risk assessment. Endocrine Disruption Assess the role of endocrine disruption in tumor development, validate endocrine disruptor assays, oversee Tier 1 assays, identify “Other Scientifically Relevant Information,” place and monitor CRO assays, assess data for Tier 2 testing. Familiar with all aspects of EPA’s Endocrine Disruptor Screening Program (EDSP). IARC Cancer Evaluation Within the IARC Monograph Program, serve as meeting observer, support clients in preparing for evaluations and developing follow-up strategies, foresee data needs and develop strategies to fill gaps, and apply the Ten Key Characteristics of Carcinogens. Product Stewardship and Green Chemistry Assist in eliminating or substituting chemicals, reducing environmental impacts, and evaluating products’ end-of-life impacts. Toxic Substances Control Act (TSCA) Pre-prioritize clients’ chemicals to predict their potential for listing on “high priority” list and support challenges to new- and existingchemical and use prioritizations. Design and conduct risk evaluations, including systematic reviews of toxicology literature and weight-of-evidence analyses. www.toxstrategies.com AUSTIN, TX ASHEVILLE, NC BOSTON, MA HOUSTON, TX ORANGE COUNTY, CA RESEARCH TRIANGLE PARK, NC ROCKVILLE, MD SAN FRANCISCO BAY AREA, CA © 2019 ToxStrategies, Inc. All Rights Reserved. V3.9 KNOC DO NOT INFRINGE ON WHITE SPACE WHEN PLACING LOGO. Document Accession #: 20201008-3001 Filed Date: 10/08/2020 SPOT Overview of ToxStrategies’ Qualifications Environmental Sciences Develop and apply quantitative methods to model chemical fate and transport. Manage large data sets, integrate findings across media, use sophisticated tools to analyze data, and create data visualizations to communicate results to diverse audiences. Environmental Forensics, Cost Allocation Determine sources and timing of contaminant releases using chemical, mineralogical, isotopic, DNA, and tree-ring fingerprinting techniques; build defensible evidence base for litigation; apportion liability for mitigation among multiple contributors. Risk Communication Combine aspects of science, psychology, risk perception, and sociology to define personal consequences of a given exposure. Coordinate public outreach efforts and communicate complex scientific concepts to the lay public, media, and nontechnical parties involved in litigation. Liability Cost Analysis Use accepted methods, validated cost data, and a probabilistic approach to uncertainty in cost projections to support clients’ financial reporting, litigation and settlements, mergers & acquisitions, and corporate strategic planning. PMS 363 C Epidemiology Rigorous scientific principles that guide our research on complex health conditions. With a focus on pharmaceuticals, medical devices, nutritional products, and environmental chemicals, our scientists aid clients in the conduct, evaluation, and interpretation of epidemiological studies. Our research frequently results in peerreviewed publications and presentations at scientific conferences and is also used in numerous regulatory documents in the US and Europe. PMS 363 PC Product Safety Scientific and strategic expertise in nonclinical safety assessments of novel small-molecule and biological products and biosimilars. Includes designing/managing toxicology studies; IND, pre-IND, and BLA submissions; due diligence, and in-person and remote meetings with regulatory authorities. Toxicology Monographs Board-certified toxicologists prepare monographs to document the safety or potential health hazards of product- and process-related impurities, degradants, solvents, and novel excipients in drug ingredients and products (e.g., biologics, cell therapies, small molecules). Assist with both routine and crisis-borne safety assessments of consumer goods and packaging. Smooth product path to the marketplace, supporting safety and regulatory needs. Includes support for medical devices and pharmaceuticals, and Proposition 65 compliance. Food and Supplement Safety Support bringing new products and ingredients to the market and expanding existing uses. Develop health and technical product claims, conduct GRAS assessments, coordinate all phases of pre-clinical and clinical studies, ensure compliance with Food Safety Modernization Act. Safety assessments to bring new products or ingredients to market or expand existing uses. Assess technical product claims and navigate the regulatory maze to secure approval. Prepare food additive petitions, AAFCO petitions, GRAS determinations, and other compliance-required materials. Global Product Stewardship Synthesize regulatory compliance, human and environmental safety, and sustainability goals into responsible design, development, and management of products throughout their life cycle and value chain. California Proposition 65 California-based toxicologists calculate safe-harbor levels, conduct human-use simulations, and assess chemical exposures from food, consumer products/ packaging, and medical devices. Neurotoxicology and Neuroscience Design pre-clinical neurotoxicology protocols, oversee in vivo studies, interpret pre-clinical neurological data, and characterize the potential neurotoxicity if a drug. www.toxstrategies.com AUSTIN, T X ASHEVILLE, NC BOSTON, M A HOUSTON, TX ORANGE COUNTY, CA RESEARCH TRIANGLE PARK, NC ROCKVILLE, MD SAN FRANCISCO BAY AREA, CA © 2019 ToxStrategies, Inc. All Rights Reserved. C . . . . 78 M. . . . . 5 Y . . . . 98 K . . . . 24 ONE Animal Feed & Pet Food Biopharmaceuticals/ Pharmaceuticals CMYK V3.9 KNOC Document Accession #: 20201008-3001 Filed Date: 10/08/2020 ToxStrategies ATTACHMENT B WILLIAM RISH, PH.D. CURRICULUM VITAE 34 Document Accession #: 20201008-3001 Filed Date: 10/08/2020 William (Bill) Rish, Ph.D. PRINCIPAL ENGINEER CONTACT INFORMATION ToxStrategies, Inc. 31 College Place, Suite B118 Asheville, NC 28801 Office: (828) 348-1111 Cell: (614) 204-6467 E-mail: wrish@toxstrategies.com PROFESSIONAL PROFILE Dr. William (Bill) Rish is a Principal Engineer with ToxStrategies, and is based in Asheville, North Carolina. He has more than 35 years’ experience in exposure assessment, risk assessment, site assessment and remediation, and probabilistic uncertainty analysis. He has prepared hundreds of risk assessments and managed numerous large, complex site investigations and remediation projects, and has been active for many years in the development of federal and state rules, guidance, and policy regarding risk assessment. Dr. Rish was a pioneer in the development of probabilistic methods for evaluating uncertainty in estimating chemical and radiological human health risk from environmental impacts. Dr. Rish has worked across the nation on sites subject to CERCLA, RCRA Corrective Action and Closure, and state orders and voluntary action. He also has worked on Department of Energy and Department of Defense projects. In addition, he has a strong background in systems failure and accident analysis, including chemical and nuclear systems. Recently, he has been providing services and workshops to regulators, attorneys, and industry on communicating environmental risk to the public. At ToxStrategies, Dr. Rish is an in-house TSCA expert, including having Section 6 experience with chemical inventory, existing high-priority chemical risk evaluation, conditions-of-use development, life-cycle exposure assessment, and hazard assessment. He also has TSCA Section 5 experience with PMN submittals, new chemical safety assessment and prioritization, and obtaining CAS designations. Dr. Rish actively participates in working groups and committees. He is past chairman of the Health Risk Subcommittee of the Marcellus Shale Coalition, member of the Induced Seismicity Workgroup of state oil and gas regulators and co-author of their primer for state regulators, and is a regular invited member of the Ohio EPA workgroup on human and ecological risk assessment procedures. Dr. Rish is a regularly invited speaker on a wide range of topics related to risk assessment, uncertainty analysis, risk communication, and liability analysis. WILLIAM RISH, PH.D. OCTOBER 2019 1 Document Accession #: 20201008-3001 Filed Date: 10/08/2020 EDUCATION AND DEGREES EARNED 1982 Carnegie-Mellon University, Doctorate in Engineering and Public Policy 1974 Carnegie-Mellon University, Bachelor of Science in Metallurgy/Materials Science and Public Affairs (jointly conferred) CERTIFICATIONS 1995–2012 Certified Professional, Ohio Environmental Protection Agency, Voluntary Action Program PROFESSIONAL HONORS/AWARDS 2000 Phoenix Award for best Brownfield project in USEPA Region 5, Catholic Charities Community Center PROFESSIONAL ASSOCIATIONS 2019–present Society of Environmental Toxicology and Chemistry 2015–present American Chemical Society 1980–present Society for Risk Analysis SCIENTIFIC ADVISORY PANELS, COMMITTEES, & WORKGROUPS Present Alumni Advisory Council Chairman, Department of Engineering & Public Policy, Carnegie-Mellon University 2016-2017 Chair, Health Risk Subcommittee, Marcellus Shale Coalition 2015–2016 Member, Induced Seismicity Workgroup, States First Regulatory Initiative 2012–2019 Member, Ohio Chemistry Technology Council, Operational Excellence & Sustainability Committee 2012–2017 Chair, Hydraulic Fracturing Risk Workgroup, Marcellus Shale Coalition 2006 and 2018 Member, Workgroup: Human Health and Ecological Risk Assessment Procedures, Ohio EPA Multidisciplinary Board, Five Year Rule Review 2001 and 2018 Member, Workgroup: Generic Numerical Standards, Ohio EPA Voluntary Action Program MultiDisciplinary Board, Five Year Rule Review 1998–1999 Risk Assessment Guidance Committee, Ohio Bureau of Underground Storage Tank Regulation (BUSTR) Rulemaking, Rule 13—Corrective Action. 1995–1996 Member, Human Health Technical Advisory Committee, Regional Environmental Priorities Project, Northeast Ohio Region 1994–1995 Member, Scientific Committee 64 17, National Council on Radiation Protection and Measurements (NCRP), "Evaluating Uncertainty in Assessment of Dose in the Absence of Site Specific Data" WILLIAM RISH, PH.D. OCTOBER 2019 2 Document Accession #: 20201008-3001 Filed Date: 10/08/2020 1994–1996 Co-Coordinator, Subcommittee to Develop Cleanup Standards and Site-Specific Risk Assessment Procedure Rules, Ohio EPA Voluntary Action Program Rulemaking 1989–1990 Co-chair, Exposure/Risk Assessment Working Group, Great Lakes Program, State University of New York at Buffalo PROJECT EXPERIENCE Ri sk Assessment , Ri sk Communi cati on, and Ri sk-Based Pol i cy Devel opment Dr. Rish is a published expert in risk assessment and uncertainty analysis. He has been active for many years on numerous advisory committees and workgroups in the development of federal and state regulatory rules, guidance, and cleanup standards. He has directed human health and ecological risk assessments, including riskbased cleanup standards and strategies, at many complex and high-profile sites. In addition, Bill has a strong background in systems failure and accident analysis, including chemical and nuclear systems. Recently, he has been providing services and workshops to regulators, attorneys, and industry on communicating environmental risk to the public. Selected risk assessment projects: • Prepared external party TSCA Risk Evaluation on one of the first 10 high-priority existing chemical substances. • Air toxics risk assessment for a metal calciner, including stack emissions, fugitive dust emissions, and multiple residential exposure pathways. • Assisted with preparing probabilistic risk assessment of health risks associated with ingestion of fish and shellfish at the Newark Bay Study Area CERCLA site. • Assisted with developing risk-based remediation levels for dioxins and furans for a former wood treating facility site in Canada. • Prepared several recent radiological risk assessments, including risks associated with the use of brine for road deicing and dust suppression, and risks associated with beneficial use of alumina processing residue for cement. • Prepared a bounding policy assessment of drinking-water risks and well-pad worker risks from spills of wastewater (flowback) and fluid additives used in hydraulic fracturing of horizontal shale gas wells. • Directed the site investigations, human health and ecological risk assessments, and remedial feasibility studies at the Former Diamond Shamrock Site in Painesville, Ohio (also known as Lakeview Bluffs Brownfield Redevelopment). These risk assessments were done for more than 20 separate areas of concern under Director’s Final Findings and Orders with the Ohio EPA. The site comprises 1100+ acres, abutting Lake Erie on its northern border and with the Grand River flowing across the site. Studies and remediation plans were coordinated with extensive plans to redevelop various portions of the site. • Prepared a risk analysis of deep injection of hazardous waste for the American Chemical Council (ACC), which used probabilistic risk assessment (PRA) methods to analyze how underground injection technologies might fail to isolate waste from the environment. The study involved extensive workshops and interviews with industry and state and federal regulatory experts. Implications for regulatory requirements regarding chemical-industry injection practices were evaluated and presented to EPA. A section devoted to this study is contained in Chapter V of the EPA Office of Water report: Class I Underground Injection Control Program: Study of the Risks Associated with Class I Underground Injection Wells (March 2001). WILLIAM RISH, PH.D. OCTOBER 2019 3 Document Accession #: 20201008-3001 Filed Date: 10/08/2020 • Prepared a study of the social risks of deep injection of hazardous waste for a large international chemical handling company. The study examined public perception, acceptance, and organized resistance related to Class I hazardous waste injection wells. Identified and discussed key factors to consider when deciding whether to commercialize a Class I well. The audience was a non-U.S. corporate board of directors. • Co-Coordinator of the Ohio EPA committee that developed the Voluntary Action Program Generic Numerical Standards (Rule 3745-300-08) and Property-Specific Risk Assessment Procedures (Rule 3745-300-09). The committee was interdisciplinary, and included representatives of government, industry, real estate development, and public advocacy groups. Presented aspects of the rules—for example, the Urban Setting Designations for groundwater—at numerous public meetings. • Developed and was invited to present training sessions in Risk Communication to: Texas Commission on Environmental Quality (TCEQ), Ground Water Protection Council (GWPC), Marcellus Shale Coalition (MSC), and Ohio State Bar Association (OSBA) in 2017. Presented risk-based engineering class to Ohio Society of Professional Engineers (OSPE). • Managed a historical dose reconstruction project at Idaho National Engineering Laboratory (INEL) for the Centers for Disease Control and Prevention (CDC). The project identified, retrieved, and evaluated all documents, data, and personal accounts pertinent to the reconstruction of potential doses and risks to the population near INEL over its 40 years of operation. Included management of an extensive public outreach program. Uncertai nty and Li abi l i ty Anal ysi s Dr. Rish is a pioneer in the development and use of probabilistic methods to evaluate uncertainty and environmental liability, and to establish environmental standards. He initially developed his skills in this area while at Carnegie-Mellon University and Brookhaven National Laboratory as a graduate student. Dr. Rish’s doctoral thesis was on Characterizing Uncertainty in Estimating Impacts from Energy Systems. He also helped prepare the documents, Technological Uncertainty in Policy Analysis (Brookhaven National Laboratory, 1982), and Uncertainty: A Guide to Dealing with Uncertainty in Quantitative Risk and Policy Analysis (Morgan and Henrion, 1990), and was co-author of Technical Uncertainty in Quantitative Policy Analysis: A Sulfur Air Pollution Example (Morgan et al., 1984). Selected relevant uncertainty and liability analyses: • Assisted with preparation of the analysis of uncertainties in the US EPA pathways and health effects modeling used as the basis for standard 40 CFR 191 for high-level radioactive waste and reported the results to the Science Advisory Board (SAB). Was a technical reviewer for EPA for their study of radiological risks from naturally occurring radioactive materials (NORM) from produced water at offshore oil rigs. Also developed a program-wide guidance manual for the EPA Office of Radiation Programs staff on uncertainty in risk analysis and risk management (see publications below). • Regularly assisted corporations in analyzing environmental liabilities in support of strategic business decision making, including SEC reporting, acquisitions and divestments, insurance settlements, and setting reserves and accruals. • As an expert witness, developed the basis for determining settlement amounts in negotiations and litigation between environmental insurers and the insured, for large portfolios of assets. • Prepared a probabilistic risk evaluation of using six different coal mine sites for ash disposal. WILLIAM RISH, PH.D. OCTOBER 2019 4 Document Accession #: 20201008-3001 Filed Date: 10/08/2020 Ri sk-Based Si t e I nvest i gat i on and Remedi at i on Over a 30-year period, Dr. Rish has been project and program manager for many large, complex environmental projects across the United States under RCRA, CERCLA, state voluntary programs, and state and federal orders. Selected site investigation and remediation projects: • Acted in key role as the Certified Professional (under the Ohio Voluntary Action Program) on many large and high-profile Brownfield projects. Project for the Catholic Charities won a Phoenix Award for best Brownfield project in USEPA Region 5. Secured 14 NFA Letters and 14 Covenants Not to Sue, as well as 10 Urban Setting Designations (USDs), under the Ohio Voluntary Action Program (VAP). Wrote Chapter 25, Practical Aspects of Risk Assessment for Brownfield Development, in the American Bar Association’s Brownfields book. • Project manager for a groundwater remediation project involving vinyl chloride and 1,2-dichloroethane at an industrial facility in Hammond, Indiana. In situ chemical oxidation was used to reduce source-area concentrations, followed by use of a vapor mitigation system to manage indoor air levels. • Technical advisor for a groundwater remediation project under the Ohio VAP at an operating facility. Groundwater contains chlorinated organic compounds in dissolved phase, and dense non-aqueousphase liquid (DNAPL). The remedy includes in situ treatment, a passive reactive barrier, and vapor intrusion mitigation. • Assisted with development of the remediation work plan (RWP) for the site of a pipeline leak of petroleum condensate in Colorado. Condensate leaked over months in mountainous terrain, entered a ravine, and traveled through groundwater to a discharge point in a spring. Remediation includes well skimmers, chemical injection in the spill area, and a collection system at the spring. MANUSCRIPTS Marschke S, Rish W, Mauro J. 2019. Radiation exposures from the beneficial use of alumina production residue. J AWWA online, https://doi.org/10.1080/10962247.2019.1670281. Thompson CM, Fitch SE, Ring C, Rish W, Cullen JM, Haws LC. 2019. Development of an oral reference dose for the perfluorinated compound GenX. J Appl Toxicol 39:1267–1282. Marschke S, Rish W and Mauro J. 2019. Radiation Exposures from the Beneficial Use of Alumina Production Residue. Journal of the Air & Waste Management Association. DOI: 10.1080/10962247.2019.1670281 Rish W, Pfau EJ. 2018. Bounding analysis of drinking water health risks from a spill of hydraulic fracturing flowback water. Risk Analysis 38(4):724–754, DOI: 10.1111/risa.12884. Rish W. 1994. SEC Initiatives in environmental disclosure: How can environmental liability be estimated? Ohio Environmental Law Letter 4(6):3–4. Rish W, Patterson J, Lutkenhoff S. 1989. Use of health risk estimates in U.S. EPAa. USEPA National Center for Environmental Assessment. Proceedings of the 1989 Annual Meeting of the Society for Risk Analysis. San Francisco, California. Rish W. 1988. Approach to uncertainty in risk analysis. ORNL/TM 10746. Report to U.S. Environmental Protection Agency, Office of Radiation Programs, Analysis and Support Division.Oak Ridge National Laboratory. Rish W. 1988. Review of studies related to uncertainty in risk analysis. ORNL/TM 10776 (with R.J. Marnicio). Report to U.S. Environmental Protection Agency, Office of Radiation Programs, Analysis and Support Division. Oak Ridge National Laboratory. WILLIAM RISH, PH.D. OCTOBER 2019 5 Document Accession #: 20201008-3001 Filed Date: 10/08/2020 Rish W, Morgan MG, Morris SC, Henron D, Amaral D. 1984. Technical uncertainty in quantitative policy analysis: A sulfur air pollution example. Risk Anal: 4(3). Morgan MG, Morris SS, Meier AK, Rish W. 1981. Sulfur control in coal fired power plants: A probabilistic approach to policy analysis. J Air Pollut Control Assoc 28(10):993–997. Rish W, Morgan MG. 1979. Regulating possible health effects from AC transmission line electromagnetic fields. Proc IEEE 67:1416–1427. BOOKS Rish W. 2010. Practical aspects of risk assessment for Brownfield development. Chapter 25 in Davis T (ed.), Brownfields, Third Edition. American Bar Association. Rish W. 2005. A probabilistic risk assessment of Class I hazardous waste injection wells. Chapter 10 in Tsang CF, Apps JA (eds.), Underground injection science and technology, Developments in Water Sciences 52, Elsevier. Gillett J, Rish W (eds.). 1991. Risk and exposure assessment from toxic chemicals. Chapter 8 in Human health risks from chemical exposure: The Great Lakes ecosystem. Lewis Publishers, CRC Press. ABSTRACTS AND PRESENTATIONS Dr. Rish has presented extensively on a wide range of topics related to risk assessment, uncertainty analysis, risk communication, and liability analysis. He is regularly an invited speaker. Some recent presentations include: • Ring, Caroline L., Rish, William R., Brorby, Gregory L. Prioritization of Eight PFAS by Population Exposure and Reference-Dose Uncertainty. Poster session at SETAC North America Focused Topic Meeting “Environmental Risk Assessment of PFAS”, 12-15 August 2019, Durham, NC. • Amended TSCA Impacts on OSHA: Product Stewardship Implications. Presented at Product Stewardship 2018 Conference, Washington, DV. September 27-29, 2018. • Bounding analysis of drinking water health risks from a spill of hydraulic fracturing flowback water. Presented at the Marcellus Shale Coalition Member Meeting, Pittsburgh, PA, January 31, 2017. • New technology for measuring real-time mass emission rates of methane and VOCs from oil and gas facilities. Presented at Innovative Environmental Monitoring Technology Symposium 2016, Ohio University, October 18, 2016. • Adaptive management of remediation. Detroit Remediation Conference, Detroit, Michigan, September 2016. • Addressing the challenges of environmental risk communication. Presented at the Ohio State Bar Association Annual Environmental Conference, April 2016. • Prioritization, risk evaluation, and safety determinations under the Frank Lautenberg Chemical Safety Act for the 21st Century. Presented at Ohio Chemistry Technology Council Meeting, June 11, 2015. • Understanding induced seismicity risk from hydraulic fracturing. Presented at Ohio Oil and Gas Association Winter Meeting, March 2015. WILLIAM RISH, PH.D. OCTOBER 2019 6 Document Accession #: 20201008-3001 Filed Date: 10/08/2020 • Health risks from drinking water impacted by a flowback water spill in the Marcellus Shale region. Presented at the Ground Water Protection Council Annual UIC Conference, Austin, Texas, February 2015. • Everything old is new again: 110 years of assessing risks of underground injection of waste. Ground Water Protection Council UIC Annual Conference, Austin, Texas, February 2015. • Katona MA, Long TF, Kirman CR, Gargas ML, Rish WR. 2000. Derivation of a cancer potency factor and dermal absorption factor for benzo(a)pyrene. Toxicologist 54, abstract 873. Presented at the 39th Annual Meeting of the Society of Toxicology, Philadelphia, PA. • Rish W, Kirman CR, Hays SM, Gargas ML, Andersen ME, Reitz RH, Guengerich FP, Green T, McConnell EE, Buckpit A, Voytek P, Dugard PH. 1999. Developing a physiologically based pharmacokinetic model to describe methylene chloride kinetics at the subcellular level. Toxicologist 48, Paper No. 671. Presented at the 38th Annual Meeting of the Society of Toxicology, New Orleans, LA. WILLIAM RISH, PH.D. OCTOBER 2019 7 Document Accession #: 20201008-3001 Filed Date: 10/08/2020 ToxStrategies ATTACHMENT C AERMOD SILICA AIR MODELING DETAILS 35 Document Accession #: 20201008-3001 Filed Date: 10/08/2020 AERMOD Model Parameterization – Morgantown Pipe Storage Yard Air Dispersion Modeling Software • 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) Definition of Site, Source, Receptors and Terrain • Base map (Morgantown_basemap2.jpg) Downloaded from Google Earth a. Placeholders (Zone 17) i. SW – 587428.98 mE, 4383085.44 mN ii. NW - 588694.93 mE, 4383951.00 mN • • Definition of the Site: AreaPoly Source Source ID: AP1, Description: general poly source outlining area containing pipelines Source Area: ~ 71700 m2 (i.e. 71706.91 m2) Emission Rate – OTHER, 0.062 g/s Source base elevation – calculated using terrain files and AERMAP – 316.89m Release height (above ground) – 12.8’; assumed (stacking of 4 pipes w/ diameter = 42”) Initial vertical dimension – not specified (left blank for default) Receptors Receptors placed starting from 100m setback from Site Fenceline out to 500 m with 50 m spacing. (n= 781) Figure: Area source (red), Fenceline (inner blue line) and Setback (outer blue line). Guides of 100m (shown as pink lines) were used to define the Setback distance. Receptors were placed starting 100m from the fenceline and out to 500 m from the fenceline with 50 m spacing (black dots) Document Accession #: 20201008-3001 • Filed Date: 10/08/2020 Terrain Once source and receptors were defined, the extent of the domain was calculated in BEEST. The image below shows the calculated domain. The geo limits were identified as: § Longitude (west to east): -80.0 to 79.875 § Latitude (north to south): 39.625 to 39.5 Figure: Calculating Domain required for terrain processing Elevation data for this specified domain were obtained from viewer.nationalmap.gov. Specifically, the USGS NED 1 arc-second 3D elevation program (3DEP) data for n40w0801 and n40w0812 were downloaded. The GDAL Terrain Files converter was used to create geotiff formats for these downloaded files. This converter was downloaded (for a 32-bit machine) as per BEEST instructions and extracted into the appropriate folder. The NED output files were saved as “GDAL_n40w080.tif” and “GDAL_n40w081.tif”. AERMAP was then run using these terrain files for all receptors (n=781) and sources (n=1). Meteorology • AERMOD-ready surface and upper air meteorological datasets were available for KPKB (Mid-Ohio Valley Regional Airport in Parkersburg, WV) and KPIT (Pittsburgh International Airport in Pittsburg, PA) from Ohio EPA3. These stations were selected based on proximity to the Site as well as having similar terrain features (i.e. elevation, topography, presence of rivers). The met data files (.sfc and .pfl) were produced by Ohio EPA as described: “This meteorological data is used to predict maximum modeled concentrations for New Source Review and Prevention of Significant Deterioration air quality modeling. This meteorological data has been processed for use in the AERMOD modeling program. Ohio EPA assigns meteorological data by county, as described in Ohio Engineering 1 U.S. Geological Survey, 20181219, USGS NED 1 arc-second n40w080 1 x 1 degree ArcGrid 2018: U.S. Geological Survey. 2 U.S. Geological Survey, 2013, USGS NED n40w081 1 arc-second 2013 1 x 1 degree ArcGrid: U.S. Geological Survey. 3 https://epa.ohio.gov/dapc/model/modeling/metfiles Document Accession #: 20201008-3001 Filed Date: 10/08/2020 Guide #69. All meteorological surface data is derived from 1-hour integrated surface hourly data and one-minute ASOS data (DSI-6405) from the National Weather Service for years 2013-2017 (except as noted below). The meteorological data was processed June 2018, using version 18018 of AERMET, version 15272 of AERMINUTE and version 13016 of AERSURFACE, with a 0.5 m/s calm wind cutoff. Surface characteristics were determine for 12 sectors on a monthly basis, and monthly Bowen ratios were determined from the most recent 30-year precipitation normals for each surface station. All meteorological data was processed with the ‘‘ADJ_U*’’ option. Additional meteorological data from alternative sites are available by email request. Urban vs Rural The land use procedure in USEPA Guideline on Air Quality Models Appendix W 7.2.3 (2005) 4 classifies urban areas based on industrial, commercial, residential land use over 50% within a 3 km radius of the source. • A review of Google Map’s satellite imagery shows less than 50% industrial, commercial and residential land use over a 3km radius of the source. Therefore rural dispersion coefficients were selected for the AERMOD modeling. Figure: Review of land cover for Urban vs Rural designation Control Options Multiyear run with 2013-2017 met data; 8-hr and Annual averaging provided. Selection of multiyear provides the highest 8-hr concentrations and the average of annual averages across the 5-year met data. 4 https://www3.epa.gov/ttn/scram/guidance/guide/appw_05.pdf Document Accession #: 20201008-3001 Filed Date: 10/08/2020 Default Regulatory options were used. Deposition (i.e. wet/dry deposition) was not included in this assessment. Output Plots The highest annual average concentration of silica in air was predicted to be 2.4 ug/m3. This concentration was observed at the setback distance of 100 m from the fenceline. Figure: Silica Concentration – Annual average across 5-years (ug/m3) The maximum 8-hr average concentration of silica in air was predicted to be 23.6 ug/m3, also along the setback perimeter. Document Accession #: 20201008-3001 Filed Date: 10/08/2020 Figure: Silica Concentration – 8hr Max (ug/m3) Document Accession #: 20201008-3001 Filed Date: 10/08/2020 ENCLOSURE 3 FERC staff’s Memorandum Regarding Use of 3M Scotchkote 6233 Fusion Bonded Epoxy Coating for both the Atlantic Coast Pipeline and Mountain Valley Pipeline Projects Document Accession #: 20201008-3001 Filed Date: 10/08/2020 Memorandum Regarding Use of 3M Scotchkote 6233 Fusion Bonded Epoxy (FBE) Coating for both the Atlantic Coast Pipeline and Mountain Valley Pipeline Projects Response Topics 1. 2. 3. 4. 5. 6. 7. 8. 9. Comments of the Virginia Department of Health (VDH), and Department of Environmental Quality (VDEQ); Comments of the North Carolina Department of Health and Human Services (NCDHHS); Stakeholder comments; FERC’s initial environmental information request – July 19, 2019; Summary of Atlantic Coast Pipeline, LLC’s (Atlantic) Atlantic Coast Pipeline Project (ACP) and Mountain Valley Pipeline LLC’s (Mountain Valley) Mountain Valley Pipeline (MVP) Reply to FERC environmental information request, and testing results – July 19, 2019; FERC environmental information request to Atlantic regarding the ACP June 30, 2020; Comments provided by the Toxic Substances & Disease Registry (ATSDR) / Centers for Disease Control & Prevention (CDC) – Division of Community Health Investigations; Summary of Atlantic’s environmental information request response – July 30, 2020, including ToxStrategies revised report (August 27, 2020); and Commission staff conclusion on potential FBE impacts. Background: The Federal Energy Regulatory Commission (FERC or Commission) issued a final environmental impact statement (EIS) on July 21, 2017, for Atlantic’s proposed ACP in Docket Nos. CP15-554-000 and CP15-554-001. The ACP consists of construction, operation, and maintenance of 333.4 miles of 42-inch-diameter mainline pipeline; 186.3 miles of 36-inch-diameter mainline pipeline; 83.4 miles of 20-inch-diameter lateral pipeline; 1.4 miles of 16-inch-diameter lateral pipeline; 3 new compressor stations totaling about 130,348 horsepower (hp); 9 meter and regulating stations; 11 pig launcher and receiver facilities; and 41 mainline block valves in West Virginia, Virginia, and North Carolina. The purpose of ACP is to deliver up to 1.5 billion cubic feet per day of natural gas to customers in Virginia and North Carolina. The Commission also issued a final EIS on June 23, 2017, for Mountain Valley’s proposed MVP in Docket No. CP16-10-000. The MVP consists of construction and operation of a new 304-mile-long, 42-inch-diamter pipeline; 3 new compressor stations totaling about 171,600 hp; 4 new meter stations and an interconnection; 3 new taps; 5 new pig launchers and receivers; and 36 new mainline block valves in West Virginia and Virginia. The purpose of the MVP is to transport about 2 billion cubic feet per day of 1 Document Accession #: 20201008-3001 Filed Date: 10/08/2020 natural gas from production areas in the Appalachian Basin to markets in the MidAtlantic and Southeastern United States. The EIS documents were prepared in compliance with the requirements of the National Environmental Policy Act (NEPA), under the Council on Environmental Quality regulations for implementing NEPA (title 40 of the Code of Federal Regulations [CFR] Parts 1500–1508), and the FERC’s regulations at 18 CFR 380. Both final EIS documents stated that the project sponsors would coat the pipeline in FBE to inhibit corrosion by preventing moisture from coming into direct contact with the steel and prevent any damage or deterioration to the pipeline. The Commission issued Certificates of Public Convenience and Necessity (Certificate) for the ACP and MVP on October 13, 2017, under section 7(c) of the Natural Gas Act (NGA) and Parts 157 and 284 of the Commission’s regulations. The Commission concluded that Atlantic and Mountain Valley would minimize impacts on the natural and human environments during construction and operation of their facilities by implementing the numerous measures described in their respective construction and restoration plans, and that all of the proposed facilities would be constructed and operated in compliance with federal standards, requirements, and thresholds, including U.S. Department of Transportation materials safety requirements and U.S. Environmental Protection Agency (EPA) air emissions standards. While both Atlantic and Mountain Valley commenced construction of their respective ACP and MVP projects in January 2018, both projects subsequently shut down construction (except for stabilization activities) as a result of the loss of several major federal permits and clearances. Currently, about 3.3 miles of FBE coated pipeline is strung along the ACP rights-of-way and above grade, and Atlantic Coast has completed backfilling about 31 miles (5 percent) of this FBE coated pipeline below grade. Mountain Valley currently has about 267.8 miles (88.4 percent) of FBE coated pipeline strung along the MVP right-of-way, and it has completed backfilling nearly 237.5 miles (78.4 percent) of this FBE coated pipeline below grade. On July 5, 2020, Atlantic publicly announced cancellation of the ACP. On September 22, 2020, Mountain Valley filed a request to the Commission to recommence construction of the MVP. 2 Document Accession #: 20201008-3001 1. Filed Date: 10/08/2020 Comments of the Virginia Department of Health, and Department of Environmental Quality 1 • The VDH and VDEQ identified five degradation products (benzene, styrene, benzophenone, benzophenone acid, and benzaldehyde) that are listed in literature as being produced by photo-degradation of epoxy resins; and • The VDH and VDEQ requested an opportunity to review all applicable technical guidance or health risk information that FERC, the EPA, or 3M (the company that manufactures Scotchkote 6233 FBE coating) might have available on the toxicity and exposure pathways for this product, including the chalking substance. Specifically, the VDH and VDEQ would like to review the safety profile of FBE, the potential ability of the pipe coating and its photo-degradation byproducts to leach and impact the environment, risks to potable drinking water supplies, and any other documented health and safety hazard from the use of FBE as a pipeline coating. On May 22, 2020, FERC staff’s Dave Swearingen sent summary e-mails to the VDH and VDEQ attaching all relevant materials requested and noting himself as a point of contact for any follow up. Separate e-mails were sent for the ACP and MVP projects. No response has been received. 2. Comments of the North Carolina Department of Health and Human Services 2 The NCDHHS provided the following comments stating that several North Carolina residents have expressed concerns regarding the use of 3M Scotchkote FBE. Specifically, comments and concerns were related to: • chalking produced when FBE coating is exposed to direct sunlight during pipe storage, and the potential impacts the chalking material has on environmental and public health; • leachability of the FBE coating under conditions specific/relevant to the ACP in order to assess the environmental impacts and potential pathways for human health exposure; • Atlantic/Mountain Valley’s reply to staff’s environmental information request does not provide sufficient information to assess potential impacts of chalking residue on public health; 1 2 FERC Docket CP15-554-000, and CP16-10-000 Accession Number 20190402-0014. FERC Docket CP15-554-000 Accession Number 20191025-5088. 3 Document Accession #: 20201008-3001 Filed Date: 10/08/2020 • the ToxStrategies impact assessment, provided by Atlantic for the ACP contains several limitations and inconsistencies that make it difficult to determine the environmental and human health impact on FBE coating residue including: o concentration comparison for metals in soils – ToxStrategies uses average soil concentrations for the entire state of West Virginia for a comparison of site soil concentrations. Background soil samples (up-slope and up-wind) within the immediate geographic area should have been used for comparison of site soil metal concentrations; o wipe sample concentrations were reported in ug/sample (microgram/ sample) and then compared with impact assessment concentrations reported in ug/cm2 (micrograms per square centimeter) without a methodology for unit conversion or explanation how to compare samples with different concentrations units; o ToxStrategies reports the average arsenic concentration in wipe samples as non-detect; however, arsenic was detected in all wipe samples; o arsenic was detected in soil samples at more than 10 x the EPA screening level; however, ToxStrategies concludes that arsenic was detected below natural background soil level (the comparison of background soil concentrations to state average concentrations is inappropriate and should be compared with background soil samples collected from the immediate geographic area). On October 8, 2020, Dave Swearingen responded via letters to the NCDHHS as well as the VDH and VDEQ, attaching this memo and the revised ToxStrategies report (dated August 27, 2020--see item 8, below), and noting himself as a point of contact for any follow up. 3. Stakeholder Comments 3 The following stakeholder comments were also filed into the applicable dockets for the projects: • FBE coatings, specifically 3M Scotchkote 6233 contains numerous chemicals; the Material Safety Data Sheet lists carcinogens, mutagens, and other toxins that can 3 FERC Docket CP15-554-000 Accession Numbers 20190124-5178, 20190425-5197, 20190514-5153, 201906205092, 20190717-5002, 20190726-004; and Docket CP16-10-000 Accession Numbers 20180827-5016, 201901255014, 20190418-5072 and 20190604-5138. Additional stakeholder comments filed: CP15-554-000 Accession Numbers 20190923-0033; 20191024-5090; 20200326-5042; 20200116-5104; 20200615-5277; and 202006155298. FERC Docket CP16-10-000 Accession Number 20200203-5001. 4 Document Accession #: 20201008-3001 • • • • • • Filed Date: 10/08/2020 have significant negative impacts to human health, including reproductive health, development impacts, respiratory impacts, and is toxic to aquatic resources. FBE coatings and the chalking material produced during prolong exposure to sunlight, is released from the pipe surface into the natural and human environment; o Pipes stored outside are exposed to ultraviolet (UV) light, the FBE degrades and chalks off of the pipe and into the environment (“experts advise that the exposed pipe may be losing 1-2 millimeters of FBE per year); o degraded FBE material becomes airborne and inhaled, and the degraded material enters surface and subsurface soil and groundwater in the areas where the pipes are stored and when they are placed underground (buried). FBE material could dislodge and transport, which could contaminate drinking water, especially in karst environments with rapid travel times to drinking water receptors (wells and springs); and o silica, which makes up to 40 percent of the coating will become airborne and inhaled by persons downwind of pipe storage locations. FBE leaching studies have not been performed; FBE Scotchkote 6233 cannot be compared with Scotchkote 6233W, which has NSF certification, because pipeline coated with FBE 6233 would be subject to contact with soil and groundwater conditions with variable chemical properties including pH, salinity, and a variety of minerals and organisms including burrowing animals where Scotchkote 6233W is exposed to regulated, static water; stakeholders comment that the results of testing conducted by Atlantic for the ACP, in reply to FERC’s environmental information request use questionable data and methods to arrive at unreliable conclusions; Atlantic’s responses to FERC’s environmental information request dated July 22, 2019, and August 23, 2019, do not supply the necessary information and analysis on toxicity of the FBE from all potential exposure pathways including from direct and indirect human contact, ingestion or inhalation, as well as environmental pathways (leachability and mobility) in air, soils, surface water, and groundwater; Atlantic’s stated implication that “FBE 6233 constituents will be rendered harmless after application, if application is done according to explicit application guidelines, and curing” requires extensive scrutiny and rigorous testing by more than a single independent laboratory, given the extreme toxicity of the constituent ingredients and the potential extreme hazard to the aquatic life, animals and scores of humans that stand to be directly and negatively affected by the coating’s degradation into the soil and groundwater; 5 Document Accession #: 20201008-3001 Filed Date: 10/08/2020 • Atlantic’s response to FERC’s environmental information request also does not address analysis of human and environmental exposure from the degradation of FBE due to exposure to sunlight and sloughing (chalking) of the material; • stakeholders likewise provided a similar list of limitations and inconsistencies in the ToxStrategies assessment and reporting as noted by the NCDHHS; and • stakeholders request that FERC should provide studies showing scientific data used to support the assertion in the EIS that the pipeline coating would not release dangerous chemicals into the ground. 4. FERC’s July 19 2019 environmental information request to Atlantic and Mountain Valley 4 Please provide toxicological, environmental and health information for Fusion Bonded Epoxy (FBE) coatings (3M™ ScotchkoteTM Fusion Bonded Epoxy Coatings and 3M™ ScotchkoteTM Liquid Epoxy Coatings, or their equivalents) used for coating the project’s pipeline and associated utilities. Evaluate and report on the toxicity of the FBE from all potential exposure pathways including from direct and indirect human contact, ingestion or inhalation; as well as environmental pathways (leachability and mobility) in air, soils, surface water and groundwater. The evaluation should likewise include an analysis of human and environmental exposure from the degradation of FBE due to exposure to sunlight, and sloughing (chalking) of the material. 5. Summary of Atlantic’s and Mountain Valley’s Reply to FERC environmental information request, and Testing Results – July 19, 2019 5 Two categories of pipeline coatings used on the project pipeline are reported: • pre-applied epoxy coatings prior to pipe delivery; and • field-applied epoxy coatings. Pre-Applied Epoxy Coatings Prior to Pipe Delivery: 3M Scothkote 6233 is the primary coating used on 95 percent of the MVP pipeline. Other epoxy coatings are used, but at much less frequency: • 3M Scotchkote 6352 used in very rocky soils, open-cut streams and road crossings as part of a dual layer pipe coating to provide an abrasive resistant overcoat with FERC Docket CP15-554-000 Accession Number 20190703-3011; and CP16-10-000 Accession Number 20190710-3074. 5 MVP (CP16-10-000 Accession Number 20190730-5085) and ACP (CP15-554 Accession Number 20190722-5061; and 20190823-5161). 4 6 Document Accession #: 20201008-3001 Filed Date: 10/08/2020 Scotchkote 6233 (Mountain Valley estimates approximately 2 percent of the MVP total pipeline length will have this dual layer); • Powercrete DD is a solvent-free liquid coating applied with Scotchkote 6233 as part of a dual layer coating (Mountain Valley expects approximately 0.8 percent of the MVP pipeline will be coated with Powercrete DD); and • SPC SP-2888 is a liquid coating that can be pre-applied or field applied. Mountain Valley states this compound is 100 percent solids and solvent free (Mountain Valley expects 0.8 percent of the MVP pipeline would be coated with pre-applied SPC SP-2888). Field-applied Coatings: Mountain Valley expects to use four different field-applied coatings for the MVP: SPC SP-2888; Denso Protal 7200; Denso Protal 7125; and Powercrete R-95. Mountain Valley estimates use of these compounds on less than 2 percent of the total MVP pipeline length. The only two of the four products that contains organic solvents are Protal 7125 and Powercrete R-95; both used at less than 0.1 percent of the MVP pipeline. Atlantic provided a table of project coatings for the ACP, many the same as identified by Mountain Valley, but did not provide the percentage of use for the ACP project pipeline. 3M Scothkote 6233 3M Scothkote 6233 is a powder-based FBE that is applied in the factory, and cured (by heating) prior to delivery to the site. This FBE compound is predominantly comprised of polymeric materials and inorganic compounds that are fully encapsulated in the polymer mixture upon application and curing (by heat); they are expected to resist degradation and have negligible water solubility. 3M Scothkote Product Information states that FBE powder coatings are finely ground powders that react when heated, and do not contain solvents. Mountain Valley states that stakeholder comments claiming that the presence of organic solvents in the FBE compound are based on a 2015 study citing a 1989 American Water Works Association study, which looked at the leaching of solvent-based epoxy that are sprayed onto the pipe in liquid form. NSF/ANSI 61 certifies a similar compound 3M Scotchkote 6233W for use in applications involving contact with drinking water, commonly used for lining the interior of water mains and distribution pipes. NSF/ANSI 61 is a performance-based standard which tests the amount of contaminants that leach from the product into drinking water, and a toxicological evaluation of concentrations leached to ensure that they are below levels that may cause human health effects. Stakeholders comment that 3M Scothkote 6233 and 6233W are different products. A letter generated by 3M addressed to Mr. William 7 Document Accession #: 20201008-3001 Filed Date: 10/08/2020 Limpert (one of the primary stakeholder commentors) states that there is no difference in the two products other than the designation “W” for potable water applications. Safety Data Sheets (SDS) for both 3M Scotchkote 6233 (provided with filings) and 6233W (downloaded from web) show similar composition/information of ingredients (section 3 of the SDS). Mountain Valley states that the compounds shown in the SDS are for uncured (heated) powder form, and not indicative of the chemical constituents and properties of the coating when it is applied to the pipe [prior to delivery]; and that according to the manufacturer, any minor quantities of constituents that remain unreacted would be physically entrained in the cured coating with limited ability to leach into the environment. Stakeholders state that although the two materials (6233 and 6233W) are similar or identical, they are used differently. The coating applied to the exterior of pipes (3M Scotchkote 6233), is subject to UV degradation, and when buried underground is subject to different environmental stressors than the coating applied to the interior of water pipes (3M Scotchkote 6233W). Leaching Studies: Mountain Valley conducted an independent leaching analysis on its primary MVP pipe coating 3M Scotchkote 6233 using EPA Method 1311 Toxicity Characteristic Leaching Procedure (TCLP) which is an aggressive method that exposes the sample to a highly acidic solution and is normally used to test materials for leaching of contaminants from a solid mass prior to landfilling. The results of their TCLP leachability testing of a 32ounce sample (taken from pipes stored outside as a pipe yard in West Virginia) of 3M Scothkote 6233 coating showed no volatile or semi-volatile organic compounds (VOC/SVOC). Only one metal (barium) was detected above the method detection level (MDL). Barium was detected at a concentration of 0.111 milligrams per liter (mg/L), above the MDL of 0.05 mg/L. The EPA primary Drinking Water maximum contaminant level (MCL) for Barium is 2 mg/L. Atlantic provided a copy of the NSF/ANSI 61 testing of 3M Scothkote 6233W (powder material) used on the ACP pipe, which showed non-detectable (ND (below method detection level (MDL)) results for all organic and inorganic constituents tested, with the exception of low levels of Barium, Copper, Aluminum, tin, total trihalomethanes, and Chloroform. 6 Sloughing of FBE Due to Exposure to UV Light Mountain Valley and Atlantic state that photo-degradation of FBE due to exposure resulting in a chalky residue on the pipe surface is common, and what has been 6 Accession number 20190722-5061; see Attachment 3. 8 Document Accession #: 20201008-3001 Filed Date: 10/08/2020 experienced is within the industry’s expected rate 0.001 inch per year. Mountain Valley states that although it is unaware of any study that identifies environmental or human health risks, the results of the MVP leachability tests do not show the presence of any harmful substance. According to 3M product declaration, FBE photodegradation can form aldehydes, amides, various aromatics and other by products that “overall” would have minimal environmental impact. None of the photo-degradation products are anticipated to bioconcentrate. The product declaration states that photodegradation products (sloughing materials) are expected to biodegrade when the pipe is buried in the soils. Atlantic’s Evaluation of FBE Chalky Residue 7 Atlantic contracted with ToxStrategies of Asheville, North Carolina to assess potential human exposure and environmental impact from the chalky residue present on the outside of ACP natural gas pipeline stockpiled at Atlantic’s Morganton Pipe Yard in Morganton, West Virginia. On June 26th and August 7, 2019, ToxStrategies collected surface wipe samples from stored pipe, and soil samples immediately beneath the section of pipe from which the wipe samples were taken. 8 The samples were submitted for laboratory analysis of “Chemicals of Potential Concern” (COPC) identified from 3M Scotchkote FBE Coating’s (6233) SDS, 3M’s product material declaration, and from the 1989 FBE leaching test (discussed above). ToxStrategies provided the following list of COPCs that were analyzed in the assessment: Bisphenol A, Pentachlorophenol, Methyl Isobutyl Ketone (MIBK), 2-nitrophenol, Xylenes, 2,4-dinitrophenol, Aniline, 2-methyl-4,6-dinitrophenol, Phenol, Aluminum, 2chlorophenol, Calcium, 2,4-dichlorophenol, Iron, 2,4,6-trichlorophenol, Titanium. In addition, because standard laboratory analytical methods include a longer list of metals (including the Resource Conservation and Recovery Act metals of concern— arsenic, barium, cadmium, chromium, lead, mercury, selenium, and silver) and include BTEX (benzene, toluene, ethylbenzene, and xylenes) these were included in the laboratory analyses of COPCs. Accession number 20190823-5161. At each location, during the June event, five separate wipe samples of pipe chalky residue were collected; one each for metals, mercury, bisphenol A, BTEX and MIBK, and one QA wipe sample. Each set of wipe samples was collected from a different pipe surface at the approximate center of the pipe length. A single soil sample was collected from the soil located immediately beneath the section of pipe from which the wipe samples were collected. During the August event, a wipe sample and soil sample were taken from the same ten locations and analyzed for aniline, phenol, 2-chlorophenol, 2,4-dichlorophenol, 2,4,6- trichlorophenol, pentachlorophenol, 2-nitrophenol, 2,4dinitrophenol, and 2-methyl-4,6- dinitrophenol. Because vehicle use at the yard is a potential source of VOCs in soil, BTEX and MIBK were analyzed in the wipe samples only. It is assumed that if these VOCs are not present in the chalky residue, then the residue is not a source of VOCs to soils. 7 8 9 Document Accession #: 20201008-3001 Filed Date: 10/08/2020 No organics were detected from the laboratory analysis of COPCs in any of the pipe surface wipe samples or corresponding soil samples. However, it should be noted that VOCs, including BTEX, and MIBK were not analyzed in the soil samples collected during the August sampling event. ToxStrategies states that “Because vehicle use at the yard is a potential source of volatile organic compounds (VOCs) in soil, BTEX and MIBK were analyzed in the wipe samples only. It is assumed that if these VOCs are not present in the chalky residue, then the residue is not a source of VOCs to soils.” For metals, the laboratory results showed that the weight percentages detected in the wipe samples consisted of calcium (72 percent) and aluminum (11 percent), with silica also being a significant constituent but not included in the analyses. ToxStrategies reports that metal concentrations in soils sampled directly below the pipe were below natural background concentrations with the exception of calcium which was detected above natural background levels which was based on average soil concentrations for metals in West Virginia. ToxStrategies also compared metal concentrations to World Trade Center (WTC) settled dust screening levels and found them to be “orders of magnitude” lower. WTC settled dust screening levels were developed as health-based benchmarks for cleanup of residences affected by the WTC disaster. ToxStrategies concludes that based on the sampling and laboratory assessment results, no impact on human health or the environment was found. No independent analysis of the chalking material was conducted by Mountain Valley. 6. FERC Environmental Information Request to Atlantic - June 30, 2020 On June 30, 2020, a follow-up environmental information request was issued to the project docket for the ACP 9 requiring Atlantic to reply to specific questions and comments raised by stakeholders specifically, that Atlantic’s reply to FERC staff’s July 19, 2019 environmental information request does not provide sufficient information to assess potential impacts of FBE chalking residue on public health; does not provide a clear understanding of the leaching potential of the FBE coating under conditions specifically relevant to the ACP in order to allow a full assessment of the environmental impacts and potential pathways to environmental and ecological resources and human health exposure; and the data, analysis and reporting provided by Atlantic’s toxicology contractor (ToxStrategies), include a number of limitations and inconsistencies yielding questionable results, specifically: Most of the MVP pipeline is already in the ground, so the novel circumstance of pipe exposed for multiple years is not as prevalent. 9 10 Document Accession #: 20201008-3001 Filed Date: 10/08/2020 • Background soil concentrations for metals: Background soil samples (up-slope and up-wind) within the immediate geographic area should have been used for comparison of site soil metal concentrations; • Reported concentration units for wipe samples: Wipe sample concentrations were reported in ug/sample (microgram per sample) and then compared with impact assessment concentrations reported in ug/cm2 (micrograms per square centimeter) without a methodology for unit conversion or an explanation how to compare sample results with different concentrations units; • Arsenic concentrations reported for wipe samples: Arsenic for wipe samples was reported as non-detect; however, arsenic was detected in all wipe samples collected from stored pipe surfaces. • Silica was not tested in the sloughing material: Silica is a carcinogen by inhalation. Commentors suggest that the sloughing material may become airborne, inhaled by persons, and cause cancer; and • VOCs were not tested in soil samples: ToxStrategies should have screened soils with a photoionization detector at a depth below 6 inches and collected soil samples for laboratory analysis of VOCs, based on these screening results in order to evaluate the potential for leaching of VOCs from the sloughing material. 7. Comments provided by the Toxic Substances & Disease Registry (ATSDR) / Centers for Disease Control & Prevention (CDC) – Division of Community Health Investigations10,11 On August 27, 2020, the ATSDR/CDC Division of Community Health replied to Mr. William Limpert’s emails to its Region 3 office a request that ATSDR evaluate public health concerns with the stockpiled ACP pipe. Specifically: • contact with potentially contaminated soil at or near the pipe storage/stockpile locations; • using drinking water potentially contaminated from the pipe storage/stockpile locations; and • breathing in air potentially contaminated with chemicals off gassing or degrading from the pipe coatings at the storage/stockpile locations. Reply to Mr. William Limpert’s July 14, 2020 petition to the ATSDR regarding potential environmental pathways of exposure and possible health risks from exposed storage of unused pipe for the ACP. Accession number 20200903-3035. 11 ATSDR’s Petition Program was established by Congress in the CERCLA (Superfund) legislation. All requests are evaluated for relevance to ATSDR’s mission usually based on the available environmental and biomonitoring sampling data typically collected by the EPA, Tribes, or state and local regulatory and health agencies. 10 11 Document Accession #: 20201008-3001 Filed Date: 10/08/2020 Although the ATSDR stated that the available environmental samplings (ToxStratigies Report) are not sufficient for ATSDR to fully evaluate the public health concerns associated with the gas pipe/storage areas, it provides the following: • ATSDR reviewed the soil sampling results documented by ToxStrategies, Inc. The specific analytical methods were not included in this report. This soil sampling investigation consisted of 10 samples at one of the storage/ stockpile locations in West Virginia. The chemicals detected in these soil samples were found below ATSDR's health-based comparison values (including ATSDR's value of 16 micrograms (ug) arsenic per gram (g) of soil). Hence, this information would tend to indicate that any people regularly contacting the soil at the storage/stockpile yard are not exposed to the sampled chemicals at levels of health concern. • ATSDR consulted with the state health departments in North Carolina, Virginia, and West Virginia. We were not able to locate documentation of private well users near the six storage/stockpile locations referenced in the petition. However, there is a public water supply well nearby the BeaJeton, Virginia location. Under the Safe Drinking Water Act requirements, this public water system is regularly monitored for regulated chemicals such as arsenic (https://fcwsa.org/water-quali ty-reports). No violations were noted for the Bealeton public water system in its 2019 Consumer Confidence report. However, the wells in this public system were noted by the state Department of Health to be of high susceptibility for contamination per the state's source water assessment program. • ATSDR did not identify any sampling data that would allow us to evaluate the potential for community members to be exposed to airborne contaminants offgassing or degrading from the pipe storage/stockpile locations. The Commonwealth of Virginia identified five degradation products (benzene, styrene, benzophenone, benzophenone acid, and benzaldehyde) that are listed in literature as being produced by photo-degradation of epoxy resins on these pipes. Further, silica makes up to 40 percent of the coating used on these pipes. It is unclear if degradation of the coating could produce airborne concentrations of respirable silica or other contaminants at levels of concern for community members downwind of these pipe storage/stockpile locations. 8. Summary of Atlantic’s environmental information request reply (August 31, 2020), and revised ToxStrategies Report (August 27, 2020). 12 ToxStrategies provided an updated report dated August 27, 2020, addressing the FERC June 30, 2020 environmental information request. The revised report assesses the potential environmental and human health impacts of ACP FBE pipeline coating 12 FERC Docket CP15-554-000 Accession Number 20200831-5258. 12 Document Accession #: 20201008-3001 Filed Date: 10/08/2020 information. On July 17, 2020, additional sampling was performed at the ACP Morgantown pipe laydown yard site. The report provides the following in reply to the FERC environmental information request: 1) Site-specific background soil samples taken up-slope and up-wind at the site Ten background soil samples were obtained from an area up-wind and up-slope of the Morgantown pipe laydown yard site and unaffected by human activity. A single soil sample was collected at each location between 2 and 6 inches below surface grade. Surface vegetation was removed prior to sampling at each location. 2) An explanation of unit conversion on wipe sample results 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 were calculated by dividing the μg/sample results by 100. 3) New blank wipe sample analyses To confirm that blank wipes do not contain COPCs, four new wipe sample blanks (WB-1 through WB-4) were collected in at locations where the 2019 pipe wipe samples were taken, WB-1 was collected at the location of S-2; WB-2 was collected at the location of S-4; WB- 3 was collected at the location of S-6; and WB-4 was collected at the location of S-9. ToxStrategies’ findings showed 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. Wipe blank sample results show most analytes and all COPCs are below detection limits in the blank wipes, with only low levels of sodium, magnesium, and zinc detected at their reporting limits or, in the case of zinc, detected in the associated method blank. Inorganic COPCs detected in wipe samples include aluminum, calcium, iron, potassium, and titanium. These detections are consistent with the findings of the elemental analysis of FBE. In addition to the inorganic COPCs, arsenic, barium, and lead were detected in wipe samples. These metals may be related to dust on the pipes rather than FBE chalky 13 Document Accession #: 20201008-3001 Filed Date: 10/08/2020 residue; these elements were not detected by the elemental analysis of FBE chalky residue. 4) Air quality modeling of potential silica releases to the atmosphere A worst-case assessment was performed to evaluate the potential exposure pathway for FBE chalky residue sloughing from the pipe surface into the atmosphere with subsequent inhalation of respirable particles. An air dispersion screening model recommended by the EPA (AERMOD17) was used with 5 years of local meteorological data to predict silica particulate concentrations in air potentially emitted from the Site. The model results show that: • the predicted silica air concentrations are below applicable risk-based criteria; • the predicted concentrations are at locations unlikely to have long-term residents (i.e., within 100 meters of the property boundary; and • concentrations decrease rapidly beyond 100 meters. Worst-case predicted silica air concentrations compared to criteria AERMOD U.S. EPA Regional Predicted Screening Level Worst-Case (residential/worker) Silica Concentration Maximum annual average (ug/m3) Maximum 8-hour average (ug/m3) Notes 1. 2. EPA EPA OSHA 8PM2.5 PM10 hour Criteria Criteria average (long-term (long-term PEL general general (workers) population) population) 2.4 3.1/13 12 150 None available 23.6 None available None available None available 50 EPA screening values apply to crystalline, respirable silica. For comparison, it is conservatively assumed that all residue dust is crystalline and in respirable size range. PM2.5 and PM10 criteria apply to long-term exposure by the general population to particulate matter, with particle sizes at or below 2.5 microns and 10 microns, respectively. 14 Document Accession #: 20201008-3001 Filed Date: 10/08/2020 5) Sampling results for volatile organic compounds in soils To analyze soils for VOCs, a total of ten soil samples were collected at the Site from directly under a section of pipe at the same locations as the June and August 2019 sampling events. These soil samples were collected from between 6 and 12 inches below surface grade. Prior to sampling, excavated soil was screened with a 10.6 electron volt (eV) photoionization detector (PID) 13 from the surface to 6 inches below surface grade, and then at 3-inch intervals from 6 to 12 inches below grade. No PID responses greater than 0.0 parts per million were detected within any soil interval. Due to the lack of PID responses, soil samples were collected from the interval just above the terminal depth of each location (e.g., 9- to 12-inch interval). Three location (S-1, S-8, and S-9) could not be advanced to the target depth due to the presence of compacted gravel subbase material. In these locations, the sample was collected just above the terminal depth. Additionally, a total of three sediment samples (SED-1 through SED-3) were collected from the stormwater sediment basin adjacent to the inflow areas of the sediment basin. These samples were obtained to help assess the potential for FBE chalky residue to be carried in stormwater runoff. As discussed above, 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. Inorganic COPCs detected in soil samples taken from under the pipe stacks include aluminum, calcium, iron, potassium, and titanium. While these elements are consistent with the findings of the elemental analysis of FBE chalky residue 14, these are also naturally occurring elements commonly found in soils. In addition to the inorganic COPCs, arsenic, barium, chromium, lead, and mercury were detected in soil samples. These are also naturally occurring elements found in soils. Concentrations in soil samples from beneath pipe stacks are less than average concentrations of metals in sitespecific background soil samples, with the exception of calcium. Detected concentrations of calcium at the Site are elevated with respect to natural background levels. No chemicals detected in soil samples exceed EPA residential soil screening levels (RSLs) or West Virginia Voluntary Remediation Program (VRP) screening levels, with Photoionization detector measure VOCs and other gases in concentrations from sub parts per billion to 10,000 parts per million. 14 The elemental analysis results indicate that FBE chalky residue has an average silicon content of 52.8 percent by weight and an average combined silicon and oxygen content 90 percent by weight. These results indicate the presence of silica or other silicates (e.g., calcium silicate). 13 15 Document Accession #: 20201008-3001 Filed Date: 10/08/2020 the exception of arsenic. Arsenic in soil samples exceeded its screening levels but was detected at or below natural background soil levels. Similar results were found for sedimentation basin samples (i.e., elevated calcium levels compared to background, all remaining metals similar to background levels, all except arsenic meet EPA RSLs and West Virginia VRP standards). ToxStrategies notes that “The driving areas within the Site are salted in winter, which may be a likely source of elevated calcium concentrations in soil and storm water catch basin sediment.” The revised ToxStrategies report, signed by William Rish, Ph.D., a Principal Engineer for ToxStrategies, Inc., provides the following summary of the findings: 1) The assessment indicates no impact on human health or the environment from the chalky residue resulting from UV degradation of FBE coated pipe in outdoor storage; 2) Chalky residue appears to consist largely (about 90 percent by weight) of silicon and oxygen. The extent to which these elements are bonded in chalky residue to form silica or silicates is undetermined. The inhalation assessment conservatively assumes all 90 percent is silica; 3) No bisphenol A, benzene, toluene, ethylbenzene, xylenes, MIBK, VOCs, or any of the SVOCs identified as potential COPCs was detected in any of the ten wipe 16 Document Accession #: 20201008-3001 Filed Date: 10/08/2020 samples or ten soil samples. These chemicals are not present in the chalky residue or the soil beneath the stored pipe; 4) Concentrations of chemicals detected in the wipe samples are orders of magnitude lower than corresponding available WTC settled-dust screening levels. This indicates that the chalky residue meets standards set to protect human health for exposures to settled dust in a residence, for those chemicals detected in chalky residue and for which WTC screening levels are available (i.e., aluminum, barium, copper, iron, lead, manganese, nickel, and zinc); 5) Among the COPCs potentially associated with chalky residue, only calcium was found above natural background levels in soils sampled directly under the chalked pipe. This finding is consistent with the predominance of calcium detected in the wipe samples and the likely presence of calcium silicate. Calcium itself is a nutrient essential to human health as well as plant and animal growth. Rare toxic intake levels of calcium are associated only with the excessive use of calcium dietary supplements; 6) All detected levels of metals in soils directly beneath stored pipe are below EPA RSLs and West Virginia VRP screening levels based on residential land use, with the exception of arsenic. However, arsenic was detected in soils at or below sitespecific natural background levels. Naturally elevated arsenic levels in background soils is not uncommon across the United States. 7) Based on worst-case assumptions, there are no unacceptable inhalation risks presented by potential releases of chalky residual material to the air. The predicted silica air concentrations are well below EPA criteria for the protection of the general population. This finding is particularly confident since, in addition to being based on unrealistic worstcase assumptions, the predicted concentrations are at locations unlikely to have long-term residents (i.e., within 100 meters of the property boundary). Concentrations decrease rapidly beyond this distance [The report states that there is no public presence within 300 meters of the fence line around the Morgantown pipe laydown yard]. 8) Because no bisphenol A, VOCs, or SVOCs were found in the chalky residue or associated soils, and all other COPC metals (with the exception of calcium) were found to be at or below natural background levels in soils located below the pipe and in sedimentation basin samples, no impacts to groundwater, surface water, or ecological receptors are expected from the chalky residue. Regarding calcium, there are no ecological screening levels for calcium because it is one of the abundant elements in the earth’s crust, its distribution is wide, and it is essential to both plant and animal growth. 17 Document Accession #: 20201008-3001 Filed Date: 10/08/2020 9. Commission Staff Conclusion on Potential FBE Impacts: Based on Commission staff’s independent review of the soil, sediment, and wipe sample results, staff concurs with the findings of ToxStrategies, Inc. that no impacts on groundwater, surface water, or ecological receptors are expected from the FBE chalky residue that may be found on the surface of the stockpiled piping in the Morgantown yard. Nor does staff find any reason to conclude that FBE chalky residue associated with the ACP or MVP aboveground or below ground pipeline would result in impacts on groundwater, surface water, or ecological receptors. Regarding air impacts, staff also does not anticipate appreciable impacts from inhalation of silica from the storage of pipe. Based on Commission staff’s review of all pertinent materials discussed above regarding FBE chalking, staff finds no bases for supplementing the EIS documents issued for the ACP and MVP. Staff bases this conclusion on the following: • no COPCs were detected in the chalky residue or associated soils; • COPC metals (with the exception of calcium) 15 were detected either at or below natural background concentrations in soils collected proximate to the pipe storage area, in soils located below the pipe, and in sedimentation basin samples; and • the air modeling is conservative and the resulting silica impact levels are below screening thresholds. Calcium is a component of 3M Scotchkote FBE Coating (calcium silicate 20 to 40 percent by weight). The detection of calcium in soils beneath the stockpiled pipe at concentrations above natural background is consistent with the predominance of calcium detected in the wipe samples and the likely presence of calcium silicate on the pipe surface. However, to the extent the chalky residue may contain calcium silicate, calcium silicate is not hazardous; and calcium is a nutrient essential to human health. We also note that there are no EPA RSLs or West Virginia VRP screening levels for calcium. 15 18 Document Accession #: 20201008-3001 Filed Date: 10/08/2020 Document Content(s) VDH VDEQ response letter_ACP MVP FBE_CP15-554.PDF.........................1