On July 3, 2019, the Federal Energy Regulatory Commission (FERC) requested that the Atlantic Coast Pipeline, LLC and Dominion Transmission, Inc. provide within 20 days toxicological environmental and health information on epoxy coatings associated with pipeline materials used in the Atlantic Coast Pipeline. (see FERC Requests Toxicological Info on ACP Coatings)

On July 22, 2019, Dominion filed a response to FERC’s request – a two page covering letter, a two page response, and 315 pages of attachments, most of which are safety data sheets (SDS) from manufacturers.

In their covering letter, Dominion says the SDS information “is based on the products’ hazards before they are reacted and cured on the pipe. The warnings are based on the presence of substances at very low amounts in the powder or liquid prior to application and cure. According to the manufacturers, these substances are expected to be encapsulated in the polymer matrix when the coating is applied and fully cured onto the pipe and would be dispersed throughout the coating and not migrate onto the surface or leach out of the coating.” We note the careful wording: safety data sheets are based on hazards before they are cured on the pipe, and the substances “are expected to be encapsulated” when fully cured.  Nothing about hazards after coatings have been exposed to UV and to weather for 3-4 years.

Continuing, the letter discusses two different 3M coatings, and says, “Although 3M has no conclusive evidence at this time to confirm their exact identity, the degradation products are generated in low quantities, have low water solubility, and are therefore not expected to enter the environment in amounts capable of producing an adverse human health effect.” Again, note the language” “no conclusive evidence at this time to confirm their exact identity,” and “not expected to enter the environment.”

Dominion says they will be doing evaluation of “composition, toxicity, and potential for environmental exposure” of the primary 3M coating, and will submit results by August 23, 2019.