Fusion Bonded Epoxy (FBE) on 42 inch Natural Gas Pipe
From the Allegheny — Blue Ridge Alliance, ABRA Update #238 – July 25, 2019
Leaching of coating chemicals used in pipe materials for the Atlantic Coast Pipeline (ACP) is “not a significant pathway and will not result in human health risks,” so stated a July 23 filing with the Federal Energy Regulatory Commission (FERC) by Dominion Energy Transmission, Inc. (DETI), managing partner for the ACP project. DETI’s filing was in response to FERC’s July 3 request for toxicological environmental and health information on the coatings used on ACP pipe.
FERC had asked DETI to:
Evaluate and report on the toxicity of the FBE (Fusion Bonded Epoxy) 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.
In summarizing its 319-page response to the FERC request, DETI stated:
According to 3M (supplier of the coating materials), chalking is a phenomenon that occurs when epoxy-based coatings are exposed to UV for an extended period of time. The chalk is a thin layer (microns thick) that adheres to the surface of the pipe that is composed of polymer degradation products (not typically known with specificity) that are created by exposure of the surface of the pipe to UV light from the sun.
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. . . . DETI is undertaking an evaluation of the FBE chalking residue including composition, toxicity, and potential for environmental exposure. The results of this evaluation will be submitted by August 23, 2019, or as soon as they are available.
The environmental and safety implications of pipe coating degradation has been raised with FERC and other regulatory agencies for over a year by William Limpert, a Bath County landowner impacted by the approved ACP route and a member of ABRA’s Steering Committee. Mr. Limpert and others within ABRA are evaluating the DETI response. It is not clear at this time what further action FERC might now take on the issue.
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Atlantic Coast Pipeline, LLC and Dominion Energy Transmission, Inc. Docket Nos. CP15-554-000, CP15-554-001, & CP15-555-000 Response to Environmental Information Request from FERC Dated July 3, 2019
Category: Information Request Question Numbers: 1
Question 1: Please provide toxicological environmental and health information for Fusion Bonded Epoxy (FBE) coatings (3MTM ScotchkoteTM Fusion Bonded Epoxy Coatings and 3MTM 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.
Response:
Safety data sheets (SDS) for the Fusion Bonded Epoxy (FBE) and Liquid Epoxy (LE) coatings1 used or planned to be used for the projects are provided in Attachment 1. The information provided on the SDS 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.
Regarding 3M’s Scotchkote 6233 FBE coating used on the projects’ pipeline, potential environmental pathways include (1) possible leaching by contact with water into soil and groundwater and (2) possible release of chalking material from portions of pipe exposed to sunlight for extended periods of time. Regarding the potential leaching pathway, 3M’s FBE coating has obtained NSF 61 certification. This certification applies to drinking water system components and is subject to rigorous health effects criteria. (See Scope of NSF/ANSI Standard 61 – Attachment 2). The results of 3M’s Scotchkote 6233 NSF 61 certification are provided. (See Attachment 3.)2 Likewise, 3M’s LE coating, Scotchkote 323, is also NSF 61 certified. (See Attachment 4.)
These results demonstrate that leaching into groundwater is not a significant pathway and will not result in human health risks.
According to 3M, chalking is a phenomenon that occurs when epoxy-based coatings are exposed to UV for an extended period of time. The chalk is a thin layer (microns thick) that adheres to the surface of the pipe that is composed of polymer degradation products (not typically known with specificity) that are created by exposure of the surface of the pipe to UV light from the sun.
Footnote 1 — FBE is applied to an entire pipe segment as part of the manufacturing process whereas LE coatings are field applied only to pipe joints and for repairs, and to fittings.
Footnote 2 — Note that the NSF 61 certification is for Scotchkote 6233W. The Scotchkote 6233W product is the same product as the Scotchkote 6233 product. The W is a designation for potable water applications. See April 1, 2019 letter from 3M to William Limpert – Attachment 5. Accordingly, the Scotchkote 6233 product would also meet the rigorous NSF 61 health effects criteria.
20190722-5061 FERC PDF (Unofficial) 7/22/2019 1:42:11 PM
Atlantic Coast Pipeline, LLC and Dominion Energy Transmission, Inc. Docket Nos. CP15-554-000, CP15-554-001, & CP15-555-000 Response to Environmental Information Request Dated July 3, 2019
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. (See April 1, 2019 letter from 3M to William Limpert – Attachment 5.) DETI is undertaking an evaluation of the FBE chalking residue including composition, toxicity, and potential for environmental exposure. The results of this evaluation will be submitted by August 23, 2019, or as soon as they are available.
The other LE coatings are field applied before they are placed into the ground and are not subjected to the storage yard durations that the factory coated FBE is subjected to. These field practices mitigate potential exposure pathways and/or risks of potential exposure from degradation due to sunlight, runoff or chalking.
Response Provided By:
Carole McCoy
Director Engineering Services 804-775-5234