TOWN OF BARNSTABLE RECEIVED - Regulations.gov

TOWN OF BARNSTABLE

OFFICE OF TOWN ATTORNEY 367 Main Street

Hyannis, Massachusetts 02601-3907 Phone 508-862-4620 Fax 508-862-4724

RUTH J. WElL, Town Attorney T. DAVID HOUGHTON, 1st Assistant Town Attorney CHARLES S. McLAUGHLIN, Jr .. Assistant Town Attorney

Program Manager Office of Renewable Energy

April30, 2018

Bureau of Ocean Energy Management (V AM-OREP) 45600 Woodland Road Sterling, VA 20166

RE: Vineyard Wind COP EIS

Dear Sir/Madam:

ruth . weil@town .barnstable .ma. us [email protected] [email protected] .ma. us

RECEIVED

MAY 3 ~.18

Office of Renewable

Energy Programs

With reference to the above-entitled matter, enclosed please find :

1. Town of Barnstable's Commentary on Scoping Procedures for the Vineyard

Wind Project.

Please file and docket same.

Thank you.

CSMjr/sr

TOWN OF BARNSTABLE

OFFICE OF TOWN ATIORNEY 367 Main Street

Hyannis, Massachusetts 02601-3907

Phone 508-862-4620 Fax 508-862-4724

RUTH J . WElL, Town Attorney T. DAVID HOUGHTON, 101 Assistant Town Attorney CHARLES S. McLAUGHLIN, Jr., Assistant Town Attorney

[email protected] [email protected] [email protected]

April 30, 2018

Program Manager Office of Renewable Energy Bureau of Ocean Energy Management (V AM-OREP)

45600 Woodland Road Sterling, Virginia 20166

Re: VINEYARD WIND COP EIS

To Whom It May Concern,

This office represents the Town of Barnstable, a Massachusetts Municipal

Corporation ("Barnstable" or "the Town"). We very much appreciate the

opportunity to offer scoping comments on the Vineyard Wind ("VW") renewable

energy project. Barnstable is vitally interested in promoting responsibly sited

offshore facilities that are compatible with the highest level of environmental

stewardship both at sea and ashore. The Vineyard Wind COP is a starting point for

extensive scoping commentary, substantial additional research, and necessarily

detailed documentation before the COP could be approved.

1. INCOMPLETE ACCESS TO THE COP REQUIRES EXTENDING THE COMMENT

PERIOD.

The Town has had numerous meetings with Vineyard Wind representatives and

their counsel. We have requested on several occasions that Vineyard Wind provide

us with hard copies of all BOEM filings but, surprisingly and unfortunately,

Vineyard Wind has not provided this documentation to the Town.

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Instead, VW has directed us to the BOEM website which of course contains

posted copies of three volumes of the COP. Unfortunately; the public version of

the COP as it appears on line contains extensive redactions which appear to shield

from the Town's view many sections that are vital to the town's scoping

commentary.

As one example only, the Town is very concerned about potential accidental

releases of hazardous materials at the offshore site. To understand the threat, the

reaction times, containment options, and potential landfalls, one must understand

what Vineyard Wind's studies of on-site conditions have revealed. That

information is apparently contained in Volume II of the Draft COP in Section 2.0,

and especially 2.2 and 2.3. Unfortunately, the entirety ofVolume II as posted on

the BOEM website has been redacted.

Consequently, the Town has been deprived of the opportunity to offer any

comment on these field observations and their implications. The same

informational void results from numerous other redactions to which the Town

should have access.

Even at this early but very important stage of the proceedings, the failure to

provide access to this information is a clear violation ofNEPA and BOEM's own

regulations.

The appropriate response is to order Vineyard Wind to provide un-redacted

copies of all BOEM filings, past and future, to the Town. Meanwhile, the scoping

comment period must be extended for at least 30 days after the Town has been

supplied with such un-redacted filings.

2. SUMMARY OF THE TOWN' S TWO PRIMARY GOALS

a. PROTECT THE TOWN'S ONLY PUBLIC DRINKING WATER SUPPLY

The preferred location for the Vineyard Wind electrical-substation that will

connect VW' s output to the regional grid sits atop the sole source aquifer which is

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the sole source of drinking water for Hyannis, a village in the Town. Hyannis is the

economic center of Cape Cod as well as its medical center. It also is home to

15,000 residents who make up the Cape's most challenged economic population.

Vineyard Wind proposes up to four ( 4) transformers at this location and one

would expect that each would contain about 10,000 gallons of dielectric cooling

fluids. These fluids are highly toxic in drinking water and the Massachusetts

Department of Environmental Protection limits maximum concentration to one (1)

part in five million (5,000,000) parts. Catastrophic failure of a single transformer

could contaminate up to 50 BILLION gallons of drinking water and would require

that the entire Hyannis water system be shut down indefinitely, if not permanently.

To describe such an event as catastrophic would be a gross understatement.

The effects on the entire region, dependent as the economy is on tourism, would be

immeasurable. This risk requires the highest level of mitigation, planning, and

prevention.

b. PREVENT A RE-BIRTH OF CAPE WIND

Vineyard Wind's first choice is to bring its cable through Muske get Channel on

the east side of Martha's Vineyard, then north-northeast to a point immediately

west of Great Island, West Yarmouth, through Lewis Bay to a landfall at New

Hampshire A venue, West Yarmouth. This route will could, but need not, traverse

the federal waters in the middle ofNantucket Sound (wholly surrounded by state

waters). This unique area of federal jurisdiction is referred to as the so-called

"federal donut" in Nantucket Sound.

A successor to Cape Wind could seek to connect to VW's cable and FERC

might be able to order such a connection to be allowed. The State and local

municipalities would be relatively powerless to prevent such a connection, thereby

imperiling more than sixteen years of responsible and successful opposition to a

project whose litany of environmental risks need not be discussed in detail here.

Years of litigation would then likely ensue and could delay Vineyard Wind

indefinitely as an unintended consequence.

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3. RISK TO BARNSTABLE DRINKING WATER

Vineyard Wind reports that its proposed substation in Hyannis will have as

many as four (4) transformers. COP, Volume I, section 3.2.4, p. 3-36. From prior

actions involving transformers, we believe that each will hold about 10,000 gallons

of dielectric cooling fluids each. The fluids are highly toxic. See MSDS sheets

attached as exhibits 1 and 2.

As noted above Massachusetts' Department of Environmental Protection

maintains a list of hazardous substances that identifies maximum allowable

concentrations of fluids, including dielectric cooling fluids, in public drinking

water. That document is the Massachusetts Contingency Plan, 310 Code of

Massachusetts Regulations 40. Depending on exact chemical makeup, maximum

concentration of dielectric fluids in drinking water is 1:5,000,000.

We also know that groundwater is about 50' below the proposed substation.

Any release could be in the groundwater in as little as two days and would then

flow to nearby public wells in as little as 7 days. See preliminary opinion of

Environmental Partners, attached as Exhibit 3.

The ground beneath the proposed substation will need to be extensively tested

to determine permeability. Fluids will need to be tested for viscosity and real-life

testing will be necessary to determine rate of percolation in the subject soils. Trace

testing will be necessary to determine how quickly these fluids would travel to the

wellheads. With that information in hand, the risk can be more readily quantified.

4. MITIGATION OF RISK TO DRINKING WATER

Because the risk of a release is ever-present and because the consequences of a

worst-case scenario release would shut down the Hyannis water system

indefinitely, the only way deemed feasible to protect the water system is to move

the wellheads and treatment plant up-gradient from the proposed substation.

The cost to do so is conservatively estimated at $32,000,000 in 2018 dollars.

This outcome must be ordered by BOEM as a condition of approving the siting of

the sub-station on Barnstable land.

However, because this process will take at least 3 to 5 years to implement, and

because Vineyard Wind is contemplating being on-line well before that time,

4

interim steps must be implemented to provide temporary protection to the Hyannis

well system. This would come in the form of robust containment vessels under the

proposed substation as well as retro-fitting the adjacent Eversource sub-station and

the Eversource substation in West Barnstable. Curiously, from day one, Vineyard

Wind has, to its credit, offered to install such containment but there is no

discussion whatsoever in their COP. Detailed, state-of-the-art plans will need to be

developed and approved by Town Engineers. The on-shore cannot proceed without

such containment.

5. ALTERNATIVES ANALYSIS

Vineyard Wind proposes to bring its export cables ashore in either Barnstable

or Yarmouth and then route them to substations, first in Hyannis and, in a second

phase, to Oak Street, West Barnstable.

Vineyard Wind's competition from successful bidders for the two leaseholds

west of Vineyard Wind instead propose to run their cables to the now-retired

Brayton Point Power Station at the head ofMt. Hope Bay, Fall River, MA.

Because of the threat posed to Barnstable's drinking water supplies as noted

above, it would obviously be safer for Vineyard Wind to run its cables to Brayton

Point and a very viable alternative. However, in a presentation before the

Commonwealth's energy Facilities Siting Board on Tuesday, April 24, 2018,

Vineyard Wind representatives conceded that they did not study the Brayton Point

alternative because it was "less economic".

The accuracy of the economics analysis is very much in doubt but, more

relevantly, a solution that would eliminate such a dramatic risk to the Town's

water supply should not be rejected out of hand in order to save a sum of money

that represents a rounding error, given the capital costs and projected income to be

derived from the Vineyard Wind project.

Once again, such a cavalier approach to environmental risk analysis violates

both NEP A and BOEM' s own rules. The analysis should be mandated.

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6. FLIGHT CONTROL RADAR STUDY

Barnstable Municipal Airport is the third busiest in the Commonwealth with an

estimated 400,000 operations annually. Previous experience with the Cape Wind

Project has demonstrated that wind towers can substantially interfere with radar

tracking by creating both false contacts and by actually hiding aircraft in the

clutter.

Cape Wind was ordered to apply a digital patch to local air search radar at Otis

AFB (now, Joint Base Cape Cod). By all reports, the patch did not perform

satisfactorily.

If that result obtained, Cape Wind was ordered to install all-new advanced

digital radar but that apparently never happened because the Cape Wind project

stalled and was abandoned. However, there are reports that suggest that the

advanced system was installed elsewhere in the country and reported failed as well.

The FAA will need to thoroughly investigate these issues but BOEM should not

move this project forward without first receiving an FAA decision that

comprehensively assesses and resolves these critical public safety concerns.

7. SURFACERADARSTUDY

The proposed size of the wind towers for this project is simply massive. The

much smaller towers proposed for the Cape Wind project were found to present the

1 ikelihood of significant radar interference both for surface vessels and for SAR

helicopters. Yet even Cape Wind studies examining much smaller towers

suggested that 70% of vessels would likely see degradation in radar performance.

Page 138.

It is vital that the effects of such massive structures be fully examined and

understood so that mariners and SAR personnel may safely operate in the project

area.

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8. STRUCTUAL ENGINEERING

The COP indicates candidly that design of towers and the ESP's are not

complete. It is critical to a competent review that a full review of the towers and

ESP's assure BOEM that these structures can withstand the assault of Category 3

and higher hurricanes and of increasingly ferocious winter storms.

This is especially important because, as discussed below, these structures will

house 123,000 gallons or more of dielectric cooling fluids . Because of this massive

volume and the inherent threat to the marine environment, whales, and sea life,

robust containment that will withstand the sheering collapse of a tower or ESP is

simply paramount.

Beyond the treat of storms, BOEM must fully understand the design of the

ESP's to know how they would react to a vessel collision if one leg was

compromised. For now, it is unclear whether these facilities will be attached to the

seabed or be floating and anchored.

9. OIL SPILL RISK ANALYSIS

Table 4.2-3 of the COP indicates that the ESP's will contain 466,400 L of

"Transformer Oil" (i.e. dielectric fluid), or about 123,000 gallons of highly toxic

chemicals (see discussion above). In a worst case scenario of a Category 4 or

higher hurricane where the ESP's collapsed or sank, using a 1:5,000,000 gallon

ration per the Mass Contingency Plan discussed above, some 615 BILLION

gallons of seawater would be contaminated to a level beyond which, if were

drinking water, could not be consumed by humans.

Surely this level of contamination would be disastrous for sea life, including

potentially the endangered Right Whales which have been seen in the area.

As discussed in the opening, it is vital to understand the current strength and

direction. The project is only 14 miles south and southwest from Muskeget

Channel on the East side of Martha's Vineyard. The currents at Muskeget flow at a

high of about 4.4 knots which is as strong as the notorious Hell's Gate in New

York City's East River. If there is a release of hazardous fluids and those are

blown to the north and northeast, they will quickly be sucked into the Muskeget

"vacuum" and deposited in Nantucket Sound. Within hours of that event, the

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hazardous fluids could easily be on the beaches and marches ofMartha's Vineyard,

Nantucket, and Cape Cod while poisoning everything in between.

The magnitude of these risks mandate a thorough study of the worst case

scenario to better understand reaction and containment strategies that may be

available.

10. OIL SPILL RESPONSE PLAN

For the same reasons, a comprehensive oil spill response plan is vital.

The on-site and remote equipment needed to contain a spill at sea must

be evaluated. Response time from the yet-to-be-identified Vineyard Wind

Operations Center must be calculated in worst case weather conditions. Personnel

assignments must be realistic. Outside contractors' response time and equipment

must be evaluated in worst-case road traffic conditions, given transit from Boston,

Providence, or other remote locations.

Again, for on-shore response, the same parameters must be evaluated. Alarms,

containment, personnel, chemical composition, solubility, soil composition, etc.

are vital to protecting the aquifer.

None of these matters have apparently been examined and no ROD should issue

until all of these absolutely critical elements are studied, understood, and factored

into real-life response scenarios.

ll.EMERGENCY RESPONSE PLANS

Cape Wind famously decried the suggestion that local municipalities would be

called upon to assist with all forms of emergency at the project site and ashore.

After the ROD had issued, it became painfully apparent that Cape Wind would

indeed rely heavily on local responders.

Vineyard Wind emergency plans should be thoroughly reviewed by experts

made up largely of local responders. Every type of emergency should be studied

and responses planned out. If Vineyard Wind is to fund and staff the full response

capacity, it should so state and the ROD should so reflect.

If locals are to be relied upon, Vineyard Wind should so state and the scoping

should require a detailed plan that identifies the training and equipment necessary

8

for locals to respond to every type of emergency. Costs for that training and

equipment simply must be part of Vineyard Wind's budget and must be paid to the

local municipalities long before the project becomes operational, and annually

thereafter.

To do otherwise is to impose an unfunded financial mandate on local

governments which would be unconscionable and, worse, would expose first

responder to serious and unnecessary personal risk. Such an outcome cannot be

tolerated.

Additionally, because the environment for the project is so unforgiving, BOEM

should direct that OSHA be consulted to review all Emergency Response Plans

equipment, and training. OSHA's or OSHA-certified consultants should meet

frequently with local responders and no ROD should issue unless locals have

signed off on all such plans.

12.LEWIS BAY CABLE AND DREDGING

Lewis Bay services Hyannis Inner Harbor where all freight ferries to Nantucket

originate. As well, extensive passenger and vehicle ferry services use Hyannis

Harbor as a base of operations. There is no reason to believe that these facilities

will not continue to support service for many years to come.

It is undisputed that Lewis Bay is experiencing ecological degradation. At least

one solution will incorporate extensive dredging to facility better water flow into

and out of the Bay. It is critical, therefore, that cables be sunk to a depth that would

allow dredging to take place throughout the Bay, unhindered by a shallow cable.

Woods Hole Oceanographic or other eminently qualified consultants should review

such contingencies and their approval of final plans should be a prerequisite to a

ROD.

So, also, the ship channel into and out of Lewis Bay is vital to marine traffic,

and especially to Nantucket-bound ferries. The current depth of the channel is 12

feet but cable location should allow for deeper dredging to accommodate larger

draft vessels in the future. To that end, the cable should be set at sufficient depth

and distance from the channel edge to allow for proper sloping of the sides of a

deeper channel.

9

13. WIND TOWER AND ESP PROTECTION

Frequent tug/barge collisions with vertical members of Interstate bridges

crossing major rivers have resulted in massive loss of life and enormous property

damage. The Army Corps has mandated new and retrofitted bumper systems

designed to absorb and deflect the impact of errant vessels. Similar structures

should be considered for this project and, at the very least, for the ESP legs, given

the risks discussed above if an ESP fails.

14. FIRE FIGHTING FOAM

Vineyard wind proposes to place a considerable volume of fire-fighting foam

on the ESP's. These foams are the subject of extensive EPA warnings with respect

to chemicals known as PFOS and PFOA. Indeed, Barnstable wells have been shut

down because of unacceptable levels of these chemicals which originated at a

county fire training academy nearby.

The allowable concentrations are in trace amounts so it is vital that BOEM

mandate extensive disclosure of what foams, if any, will be allowed. It is also

important to understand how thee foams will be contained and recovered once

discharged.

15. NO SEGMENTATION

Vineyard Wind's COP is replete with gaps in information and often with no

information at all. There is much work to be done so it is understandable, to a

certain degree.

However, NEPA makes clear that projects and project components should not

be segregated or sequestered so as to avoid a comprehensive review, full

disclosure, and robust public understanding of and input concerning all effects of

the project on public interests.

The ROD should not issue until disclosure of all aspects of and solutions for the

project have been presented in a comprehensive manner. The amount of missing

information in Vineyard Winds filing suggest a high risk that NEP A mandates

might not be complied with. It would be a mistake and reversible error to rush this

project to permitting completion and violate NEPA in the process.

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We will be filing under separate cover for consideration as a consulting agency.

Thank you for considering the Town's comments.

Very truly yours,

(l~~fut__ Charles S. McLaughlin, Jr. Town ofBarnstable Assistant Town Attorney 3 67 Main Street Hyannis, MA 02601 508-862-4620

11

EXHIBIT 1

Environmental ~ Partners ( :.&~<::>-UP

A partnor•hlp for englneGrlng solutl on c .

September 5, 2014

Mr. Charles S. McLaughlin Assistant Town Attorney Town of Barnstable 367 Main Street Hyannis, MA 02601

RE: Preliminary Assessment ofNST AR Switching Station Shunt Reactors

Dear Mr. McLaughlin:

Environmental Partners Group, Inc. (Environmental Partners) has conducted a preliminary review of the potential environmental impacts of shunt reactors proposed to be installed at the NSTAR Barnstable Switching Station (the Site). We have categorized our concerns into two categories: potential environmental concerns that require a more detailed evaluation and additional information needs to adequately evaluate potential environmental impacts.

Background It is our understanding that NST AR and Cape Wind are proposing to locate four shunt reactor systems at the NST AR Barnstable Switching Station. It has been suggested that the four proposed shunt reactors could contain as much as 1,000,000 gallons of cooling oil. Given that the proposed Site is located approximately at the crest of the eastern end of the Sagamore Flow Lens aquifer, and up gradient of nearby public water supply wells, we would urge caution and the full assessment of potential impacts of releases of cooling oil on the aquifer and well fields. It would also be prudent to consider state-of-the-art spill prevention, control and containment measures to protect these water supply resources. Our rationale for this level of caution is provided in the following paragraphs.

The USGS paper Simulated Water Sources and Effects of Pumping on Surface and Ground Water, Sagamore and Monomoy Flow Lenses, Cape Cod, Massachusetts, Scientific Investigations Report 204-5181 , by Donald A. Walter and Ann T. Whealan (Walter and Whealan, 2004) provides a detailed summary of the hydrology and pumping effects for these aquifers. The Sagamore Flow Lens is a sole source aquifer for public and private water supply wells in the Towns of Yarmouth, Barnstable, Sandwich, Bourne, Mashpee and Falmouth.

The proposed Site for the shunt reactors is an un-manned substation and is located approximately 2,500 feet north of two municipal water supply wells, one owned by the Barnstable Fire District and one owned by the Hyannis Water Department. The four wells that comprise the Town of Barnstable Mary Dunn Wellfield are all located within one-mile of the proposed site. Subsurface geology at the Site and nearby wellfields is comprised of glacial outwash sands and gravels. Estimated depth to groundwater is 50 to 75 feet below ground surface.

Hyannis: 396 North Street, Hyannis, MA 02601 TL 508.568.5103 • FX 508.568.5125

! Headquarters:

1

1900 Crown Colony Drive, Suite 402, Quincy, MA 02169 TL 617.657.0200 • FX 617.657.0201

www .envpartners.com

Woburn:

18 Commerce Way, Suite 2000, Woburn, MA 01801 TL 781.281.2542 • FX 781.281.2543

Mr. Charles S. McLaughlin September 3, 2014

Environmental Concerns and Additional Information Needs

Page 2

Based on a preliminary assessment of readily available information several potential environmental concerns are identified:

1. The Site is located at the approximate crest of the Sagamore Flow Lens. A catastrophic release of oil from the shunt reactors could potentially contaminate nearby public and private water supply wells in the area to the degree that the water is no longer potable.

2. Specifications for the Siemen' s shunt reactors are not available, but cooling oil is generally of lower viscosity, and would percolate rapidly into the ground and potentially impact the water supply for the Town of Barnstable and the Barnstable Fire District.

3. In addition to the oil itself, it would be prudent to understand what additives, if any, are contained in the oil that could be problematic in the event of a release. The threats posed by emerging contaminants in a host of commercial and industrial products (e.g. 1,4 -dioxane) are only recently coming to light, and only very small quantities of these products can render wells nonpotable.

4. The NSTAR Electric Company and Cape Wind Associates, LLC, EFSB 02-2; NSTAR Electric Company and Cape Wind Associates, LLC, EFSB 02-2A/D.T.E. 02-53; Cape Wind Associates, LLC, EFSB 07-8 states that "here will be no significant environmental impacts associated with the proposed additions at the Barnstable Switching Station . . . There are no identified wetlands or endangered species habitat in the area of expansion." The DEP GIS database shows that the area to the south of the Site, in the vicinity of Flint Rock Pond, Small Pond and Israel Pond is classified as "protected open space" and "NHESP Estimated Habitat of Rare Wetland Wildlife, Certified Vernal pool or Potential Vernal Pools". A release of oil from the shunt reactors could have long term environmental effects on these environmentally sensitive receptors

5. Oil tanker trucks are needed to service the reactors. A tanker spill along the access roads to the Site could impact groundwater supplies and discharge to storm drain systems with possible discharge of oil to surface and groundwater or other environmentally sensitive receptors including nearby areas designated as "protected open space" and "NHESP Estimated Habitat of Rare Wetland Wildlife, Certified Vernal pool or Potential Vernal Pools".

6. The Site is an un-manned substation and response time could be in excess of four hours (see D.P.U. 13-64 Petition ofNSTAR Electric Company Pursuant to G.L. c. 40A, § 3 for Exemptions from the Zoning Ordinance of the Town of Barnstable) DIRECT TESTIMONY OF C. CARTER FAHY ON BEHALF OF TOWN OF BARNSTABLE. Given the anticipated quantity of cooling oil to be deployed at the Site, the lower viscosity of the oil, and the fact that the substation is not manned, this scenario should be modeled to determine the extent of impact to groundwater under site specific conditions prior to approval by the Energy Facility Siting Board (EFSB).

Environmental ~ Partners ~.;ROUI>

· Mr. Charles S. McLaughlin September 3, 2014

Page 3

7. The shunt reactor design as summarized in the NSTAR Electric Company and Cape

Wind Associates, LLC, EFSB 02-2; NSTAR Electric Company and Cape Wind

Associates, LLC, EFSB 02-2A/D.T.E. 02-53; Cape Wind Associates, LLC, EFSB 07-8

does not discuss whether there will be secondary containment for the reactors in case of

a catastrophic release. The IEEE Std. 980 design calls for every system to be designed

with site-specific considerations and analysis. The goal here is and should be complete

containment and pre-discharge treatment. At a minimum, secondary containment for

the shunt reactor systems should be sized to service a worst-case event, i.e.

simultaneous catastrophic release from all four reactor systems in a maximum 24-hour

rainfall rate during a 1 00-year storm, plus an additional safety factor of at least 10%,

and preferably more.

8. According to Walter and Whealan, 2004 the hydraulic conductivity of the fluvial

glacial deposits can range from 200 to 350 feet per day in glacial sediments of the

Sagamore Flow Lens. The hydraulic conductivity of the aquifer describes the ease with

which a fluid can move through pore spaces. It depends on the intrinsic permeability of

the material, the degree of saturation, and the density and viscosity of the fluid. The

hydraulic conductivity of the glacial material in the Sagamore Flow Lens is generally

higher in the shallow aquifer and decreases with depth. As a result, in general, a

release of oil and any associated chemical additives from the Site will be transported

more readily in the shallow aquifer, with the potential to impact nearby public water

supply wells.

9. The Site is located· at the approximate crest of the Sagamore Flow Lens and within the

Zone II for the Mary Dunn Wellfield. This location, along with the wellfield pumping

activities, makes it difficult to predict groundwater flow patterns without groundwater

modeling. Without adequate knowledge of the Site hydraulic conditions, the

consequences of a release from the shunt reactors cannot be accurately predicted.

NSTAR Electric Company and Cape Wind Associates, LLC, EFSB 02-2; NSTAR Electric

Company and Cape Wind Associates, LLC, EFSB 02-2AID.T.E. 02-53; Cape Wind Associates,

LLC, EFSB 07-8 filing with the EFSB provides little documentation of proposed Site conditions.

Additional information is needed to adequately evaluate potential environmental impacts from

the Site, including, but not limited to:

1. Detailed plans and specifications for the equipment to be installed at the Site, including

location of oil containing equipment, quantity of oil, oil characteristics including

viscosity and chemical composition, and secondary containment specifications.

2. Copy of the NST AR and Cape Wind Spill Prevention Control and Countermeasures

(SPCC) Plan for the Site is needed to determine if adequate protective measures exist at

the Site should a release occur.

3. The Site is an un-manned substation. A schedule of when personnel check and inspect

the substation is needed to determine how long a release could go un-noticed at the

property should the alarms fail.

Environmental ~ Partners ------------GROUr•

Mr. Charles S. McLaughlin September 3, 2014

Page 4

4. Documentation of any groundwater flow modeling that has been performed for the Site and the results of this modeling. The USGS has developed a MODFLOW groundwater flow model for the Sagamore Flow Lens. If not already conducted, site specific groundwater modeling is needed to understand the environmental effects of a release of oil from the Site when nearby wellfields are pumping. Site specific particle tracking should be performed to determine travel time from the Site to various receptor points, including water supply wells and surface water discharge areas. If appropriate, the model should be used to evaluate contaminant concentrations in the water supply wells based on the magnitude of the release.

5. The DEP GIS database shows that the area to the south of the Site, in the vicinity of Flint Rock Pond, Small Pond and Israel Pond is classified as "protected open space" and "NHESP Estimated Habitat of Rare Wetland Wildlife, Certified Vernal pool or Potential Vernal Pools". Additional information is needed to address potential impacts to these sensitive environmental receptors, should a shunt reactor release occur at the Site.

Based on our preliminary evaluation, the proposed location for the shunt reactors is in an environmentally sensitive area should a release of oil occur, with potential long term impacts to groundwater, drinking water supplies, and wildlife habitats. Insufficient information is available at this time regarding equipment specifications and quantities of oil to be stored at the Site. Based on limited information, up to 1,000,000 gallons of oil could be stored at the Site.

The Site is located near the crest of the Sagamore Flow Lens, which is a sole source aquifer; is within the Zone II of two public water supplies; and is located near areas designated as "protected open space" and ''NHESP Estimated Habitat of Rare Wetland Wildlife, Certified Vernal pool or Potential Vernal Pools". Without adequate groundwater modeling, it is impossible to characterize how a release of oil from the shunt reactors will impact the nearby public and private water supply wells. The USGS has developed a groundwater flow model for the Sagamore Flow Lens. This publicly available model or other groundwater model should be used to adequately understand the site specific groundwater flow system and fate and transport of oil should a release occur at the Site.

Please contact Paul F. Gabriel at [email protected] (617) 657-0250 or Ann Marie Petricca at [email protected] or (617) 657-0299 if you have any questions or comments.

Very Truly Yours, ENVIRONMENTAL PARTNERS GROUP, JNC.

Paul F. Gabriel, P.E., LSP Principal

Ann Marie Petricca, C.P.G. Project Manager

Environmental ~ Partners ---------------CJ~C>lJI~

EXHIBIT 2

Edisol VI

EFSB 02-28/EFSB 07-8A Attachment RR-TOB-1 (1)

Page 1 of 6

1/6 Revision Date: January 6, 2011

1. IDENTIFICATION OF THE SUBSTANCE/PREPARATION AND OF THE COMPANY/UNDERTAKING

Product information Trade name MSDS# Company

Telephone Fax EMERGENCY CONTACT USA

2, HAZARDS IDENTIFICATION

Edisol VI CCZ175A Cooper Power Systems 2300 Badger Drive Waukesha, WI (864) 941-3142 (864) 223-0048 Chemtrec (800) 424-9300 IS TO BE USED "ONLY IN THE EVENT OF CHEMICAL EMERGENCIES INVOLVING A SPILL, LEAK, FIRE, EXPOSURE, OR ACCIDENTS INVOLVING CHEMICALS." AVAILABLE 24 HOURS.

Risk advice to man and the environment

Classification according to US OSHA Hazard Communication Standard (29 CFR 1910.1200) Target organs: skin, eyes, and lungs. Skin and eye irritant. If aspirated (liquid enters the lung), may cause lung damage due to chemical pneumonia, a condition caused by petroleum and petroleum-like solvents.

Classification according to Regulation (EC) No 1272/2008 [CLP/GHS]

Hazard Statement Hazard Class H332 Acute Tox 4 H302 Acute Tox 4 I

H319 Eve Dam. 1

Classification according to 67/548/EEC or 1999/45/EC

1~: R41

For full text of Rand H phrases, see section 16.

Label elements

Hazard pictograms according to Regulation (EC) No 1272/2008 (CLP/GHS)

¢ ~ .. ~.~: ~ .

Signal word: Danger WHMIS Symbol (Canada):

(f)

Edisol VI

5. FIRE-FIGHTING MEASURES

EFSB 02-28/EFSB 07-BA Attachment RR-TOB-1(1)

Page 3 of 6


Extinguishing Media: Water fog, carbon dioxide (C02), dry chemical Hazardous Combustion Products: Carbon monoxide, carbon dioxide

Advice for Fire Fighters: Flammability Limits: Special Fire Fighting Procedures: Unusual Fire, Explosion Hazards: Special Fire Fighting Procedure:

Unknown None Required None Known Firefighter should wear normal protective equipment (full bunker gear) and positive-pressure self-contained breathing apparatus. Water or foam may cause frothing if it gets below the surface of the liquid and turns to steam. Water can be used to cool fireexposed containers, to protect personnel and to disperse vapors and spills.

6. ACCIDENTAL RELEASE MEASURES

Personal Precautions: When responding to a release, wear protective gloves/protective clothing/eye protection/face protection. Keep spilled material away from heat or flames.

Methods and Material for Containment and Cleaning Up:

Small Spills, Leaks: Absorb spill with an inert material (e.g. clay, dry sand, socks or blankets labeled for oil spills), and then place in suitable waste container.

Large Spills: Contain with sand, earth, dikes, socks, or booms.

Environmental Precautions: Prevent material from entering storm sewers, ditches, or drains that lead to waterways.

7. HANDLING AND STORAGE

Precautions for Safe Handling

Advice on general occupational hygiene P264: Wash hands thoroughly after handling. P280: Wear protective gloves/protective clothing/eye protection/face

protection P305+P351+P338: IF IN EYES: Rinse cautiously with water for several minutes. Remove

contact lenses, if present and easy to do. Continue rinsing. P337+P313: If eye irritation persists: Get medical advice/attention. P301+P310: IF SWALLOWED: Immediately call a POISON CENTER or

doctor/physician. P331: Do NOT induce vomiting. P401 : Store in accordance with local regulations

Conditions for safe storage, including incompatibilities: • Store away from strong oxidizers and sources of ignition.


Page 4 of 6

Edisol VI 4/6 Revision Date: January 6, 2011

Technical measures and storage conditions: • Store in original containers. Keep closed.

Requirements for storage rooms and vessels: • Store in ventilated area, far from open flames and areas where

danger of fire exists.

Other Precautions: • Areas of fluid handling should be well ventilated .

Specific end uses:

• Insulating fluid for high voltage capacitors .

8. EXPOSURE CONTROLS/PERSONAL PROTECTION

Engineering Controls:

Adequate ventilation is essential for handling the fluid. Due to high vapor density, downflowing exhaust ventilation is recommended.

Personal Protective Equipment

Eye/Face Protection: Respiratory Protection :

Eye Protection: Skin Protection:

Wear full-face splash shield when pouring. None required. Use engineering controls noted above and avoid breathing vapors. If vapor exposure causes discomfort, wear respirator authorized for oil exposures, such as P95 {USA), or EN149 - FFP1 {EU) respirator. Wear safety glasses with side shields. Wear oil impervious gloves when pouring or whenever skin contact is likely. Wear long sleeved clothing. Launder contaminated clothing and shoes before reuse.

9. PHYSICAL AND CHEMICAL PROPERTIES

Appearance & Odor: Vapor Pressure: Vapor Density Solubility in Water Melting Point Flash Point

Clear non-viscous liquid with aromatic odor o.oooo5 psi@ yo•F 6.3 {Air= 1) 5 ppm -50 to- 55 C {-58- 67 F) 139°C {282°F) C.O.C.

10. STABILITY AND REACTIVITY

Stability: Stable Incompatibility {Materials to Avoid): Strong oxidizers may ignite this material Hazardous Decomposition: Carbon monoxide and asphyxiants Hazardous Polymerization: Will not occur Conditions to Avoid: None known

Edisol VI

EFSB 02-26/EFSB 07-BA Attachment RR-TOB-1 (1)

Page 5 of 6

5/6 Revision Date: January 6, 201 1

11 . TOXICOLOGICAL INFORMATION

Oral Acute Toxicity

Dermal Acute Toxicity Skin Sensitization Acute Dermal Irritation Subacute Toxicity Mutagenicity

Carcinogen List

LD50 Rat, 2.7 g/kg (male 14 days); 2.2 g/kg (female 14 days)

LD50 Rat, > 2 g/kg (male, female} Guinea pig, Bueler: Non-sensitizing . Rabbit: Moderate irritant Rat, oral, 28 days: no dead at maximum dose (1 g/kg) NOEL: 50 mg/kg/day Ames test: Negative In vivio mouse micronucleus test: negative No component of this product present at concentration > 0.1% is listed as a carcinogen by NTP, IARC, or OSHA

Information based on components, product formulation was not tested.

12. ECOLOGICAL INFORMATION

Aquatic, ecotoxicity, and bioaccumulation data are not available. This material is expected to be biodegradable under aerobic conditions.

Do not allow product to reach ground water, waterways, or sewage systems without proper government permits.

13. DISPOSAL CONSIDERATIONS

P501 : Dispose of contents in accordance with local regulations.

14. TRANSPORT INFORMATION

Not a dangerous good (hazardous material) for transportation by ground, air, or water per US DOT, Canada TOG, IMDG, ADRIRID, IATA!ICAO regulations.

15. REGULATORY INFORMATION

CERCLA Superfund:

SARA 311/312 SARA 313 TSCA DSL WHMIS

This product does not contain hazardous substances listed on 40 CFR 302.4 Classified as an immediate health hazard for skin and/or eye contact This product does not contain toxic chemicals subject to 40 CFR 372. All ingredients are listed on the Toxic Substances Control Act inventory. All ingredients are listed on the Canadian Dangerous Substances List . D2B

16. OTHER INFORMATION

Text of R Phrases

R20: Harmful by inhalation.

R23: Toxic by inhalation.

R41: Risk of serious damage to eyes.

Edisol VI

EFSB 02-28/EFSB 07-8A Attachment RR-TOB-1 (1)

Page 6 of 6

, COOPER Power Systems


Glossary of Acronyms

ADR

c EC F g CAS CERCLA CFR CLP DOT DSL GHS IARC IMDG kg LDSO NOEL NTP OSHA ppm PSI RID TOG WHMIS

European Agreement concerning the International C.arriage of Dangerous Goods by Road Celsius (centigrade) European Community Fahrenheit Gram Chemical Abstracts Service · Comprehensive Environmental Response Compensation and Liability Act Code of Federal Regulations Classification, Labeling, Packaging US Department of Transportation Canada Dangerous Substance List Globally Harmonized System International Agency for Research on Cancer International Maritime Dangerous Goods code Kilogram Lethal dose to 50% of exposed laboratory animals No observable effects limit National Toxicology Program US Occupational Safety and Health Administration Parts per million Pounds per square inch Regulations Concerning the International Carriage of Dangerous Goods by Rail Canada Transportation of Dangerous Goods Canada Workplace Hazardous Materials Information System

Further information

Date of preparation: January 6, 2011 Prepared by: Environmental Resource Center, agent on behalf of Cooper Industries,

101 Center Pointe Dr., Cary, NC 27513 +1 919-469-1585

The data provided on this document is provided in good faith and believed to be accurate. Because many factors impact workplace exposures, we recommend that you evaluate the properties and hazards provided herein together with the aspects of your specific application and make your own determinations and tests to determine the hazards in your workplace. Government regulations cited herein are subject to change and interpretation. No warranties of any kind are furnished regarding the data on this document or the product's application for your use. Cooper Industries, and its affiliates or agents assume no obligation or liability on the data and information given.

This version replaces all previous versions.

Edisol VI

EFSB 02-28/EFSB 07-8A Attachment RR-TOB-1(1)

Page 2 of6


Hazard statements according to Regulation (EC) No 1272/2008 [CLP/GHS:

H304: May be fatal if swallowed and enters airways H319: Causes serious eye irritation

Precautionary statements according to Regulation (EC) No 1272/2008 [CLP/GHS:

P264, P280, P305+P351+P338, P337+P313, P301+P310, P331 , P401,P501 :

For full text of precaution statements, see sections 7 and 13.

Other hazards: None known.

3. COMPOSITION/INFORMATION ON INGREDIENTS

Formula: Chemical Blend

Components

Chemical Name

Benzyltoluene

1, 1-Diphenylethane

1 ,2-Diphenylethane

Diphenylmethane

CAS-No./ Estimated EC-No. Concentration[%] 27776-01-8 36-50

248-654-8 612-00-0 50-60 EC: not listed 103-29-7 <2

203-096-4 101-81-5 <4

202-978-6

For the full text of the R-phrases mentioned in this Section, see Section 16.

4. FIRST AID MEASURES

General advice When symptoms develop and persist, seek medical advice

First aid Eye Contact:

Skin Contact:

Inhalation: Ingestion:

Flush with water until irritation subsides. If irritation persists, seek medical attention. Remove all contaminated clothing. Wash with soap and water. Get immediate attention if irritation exists. Remove to fresh air. Seek medical attention immediately. Do not induce vomiting. Seek medical attention immediately.

Protection of the first aider: Prevent skin exposure by wearing oil-impervious gloves. Do not inhale vapors

Notes for the doctor: If product was inhaled, treat for aspiration hazard.

EXHIBIT 3

MSDS Faradol 600

jlllll ,., .•.• EFSB 02-28/EFSB 07-8A Attachment RR-TOB-1 (2)

Page 1 of 10

Ludvika, 2013-05-29

Attached to this document is the Material Safety Data Sheet (MSDS) for Faradol 600 used as capacitor

impregnation fluid by ABB. Faradol 600 is the name used by ABB regarding this fluid, whereas the

supplier of the fluid uses the name Jarylec C 101. This MSDS is issued by the supplier and therefore

states the suppliers name Jarylec C 101 instead of the ABB name Faradol 600.

Postal address: ABBAB ABB Power Producis High Vottage Products SE-771 80 Ludvika Sweden

Visiting address: Lyviksvagen 4 Ludvika

ABBAS

Telephone: +46 240 78 20 00 Telefax: +46 240 78 32 20

Bank giro account: 223-1686

Org.no: 556018-0720 VAT no: SE S5601BOn001 Reg. Office: Ludvika

SAFETY DATA SHEET according to Regulation (EC) No. 190712006

Product: JARYLEC® C101

EFSB 02-28/EFSB 07-SA Attachment RR-TOB-1 (2)

Page 2 of 10

Page: 1 /9

SDS No.: 000548-001 (Version 3. 1 Date 19.12.2011 (Cancel and replace: 15.12.2011)

1. IDENTIFICATION OF THE SUBSTANCE/MIXTURE AND OF THE COMPANY/UNDERTAKING

Identificat ion of the mixture: JARYLEC® C 101 Use of the Substance/Mixture ·

Sector of use : Industrial use of dielectric fluids PCO: Dielectric fluid SU 3: lnduslrial Manufacturing (all) Professional use of dielectric fluids PCO: Dielectric fluid SU 22: Professional uses: Public domain (administration, education, entertainment, services, craftsmen)

Company/Undertaking Identification: Supplier

E-mail address

E-mail address : Exposure scenario

Emergency telephone number

2. HAZARDS IDENTIFICATION

Arl<ema France CHLOROCHIMIE ET PVC 420 rue d'Estienne d'Orves 92705 Colombes Cedex, France Telephone : +33 (0)1 49 oo 80 80 Telecopie : +33 (0)1 49 oo 83 96 http:llvo.ww.arl<ema.com [email protected]

ar1<ema-chlorochem-reach-uses@ar1<ema.com

+33 1 49 00 77 77 European emergency phone number : 112

Classification !Regulation CECl No 127212008!: Skin Irrita tion, 2, H315 Aspiration hazard, 1, H304 Chronic aquatic toxicity, 4, H413

Classification according t o EU Directives 1999/45/EC :

XI; R38 Xn; R65 R53

Additional Information: For the full text of the R, H, EUH-phrases mentioned in this Section, see Section 16.

Label elements !REGUL ATION CECl No 1272/2008):

Hazardous components which must be listed on the label:

Product category :

Benzyltoluene Dibenzynoluene

Hazard pictograms:

Signal word: Danger

ARKEMA 420 rue d'Estlenne d'Orves • 92700 Colombes - FRANCE

Product: JARYLEC® C1 01 SDS No.: 000546-001 (Version 3.1 )

Hazard statements: H315: Causes skin irritation. H303 : May be harmful if swallowed. H413 : May cause long lasting harmful effects to aquatic life.

Precautionary statements: Prevention: P280 : Wear protective gloves/protective clothing/eye protection/face protection. P273 : Avoid release to the environment. Response:


Page 3 of 10 Page: 2 / 9

Date 19.12.2011 (Cancel and replace : 15.12.2011)

P301 + P310: IF SWALLOWED: Immediately call a POISON CENTER or doctor/ physician. P331 : Do NOT induce vomiting. P302 + P352 : IF ON SKIN: Wash with plenty of soap and water. P333 + P313 : If skin irritation or rash occurs: Get medical advice/ attention.

Special labelling:

EUH205Contains epoxy constituents. May produce an allergic reaction.

Other hazards:

Po tential health effects: Skin contact: Repeated exposure may cause skin dryness or cracking. May cause allergic skin reaction. Eye contact Slightly irritating to eyes.

Environmental Effects: Inherently biodegradable. Potentially bioaccumulable.

Physical and chemical hazards: Thermal decomposition giving toxic products Decomposition products: See chapter 10

Other: Results of PBT and vPvB assessment : According to REACH regulation, annex XIII, this mixture contains no substance meeting PBT and vPvB criteria.

3. COMPOSITION/INFORMATION ON INGREDIENTS

Chemical nature of the mixture': Preparation based on :

Hazardous components (according to Regulation (EC) No. 1907/2006):

ClassifiCation ClassifiCation Chemical Name' & REACH Registration Number' EC-No. CA5-No. Concentration Directive

67/548/EEC Regulation (EC) No 127212008

Benzyltoluene (01-2119488215-34) 248-Qs.l-8 27776.01 - 70-80% Xi; R38 Skin lrrit. 2; H315 8 Xn; R65 Asp. Tox. 1: H304

R53 Aquatic Chronic 4; H413

Dibenzyltoluene (01-2119488667-17) 248-097-0 26898-17- 20-30% Xn; R65 Asp. Tex. 1; H304 9 R53 Aquatic Chronic 4; H413

Cycloaliphatic Epoxide (Mw < 700) 21g-207-4 2386-87.0 <1% Xi; R43 Skin Sens. 1; H317

1: See chapter 14 ·for Proper Shipping Name

' :See the text of the regulation for applicable exceptions or provisions : The transition time according to REACH Regulation, Article 23, Is still not expired. For the full text of the R, H, EUH-phrases mentioned In this Section, see Section 16.

ARKEMA 420 rue d'Estienne d'Orves- 92700 Colombes - FRANCE

Product: SDS No.: 000546.()()1 (Version 3.1 )

4. FIRST AID MEASURES

JARYLEC® C101




Description of necessarv first-aid measures, Most important symptoms/effects, acute and delayed:

General advice: Take off immediately all contaminated clothing.

Inhalation: Inhalation of vapours due to thermal decomposition : Move to fresh air. Oxygen or artificial respiration if needed. In case of problems : Consull

a physician.

Skin contact: Wash immediately, abundantly and thoroughly with soap and water.

Eye contact: Wash immediately, abundantly and thoroughly with water. If Irritation persists, consult an ophthalmologist.

Ingestion: Do NOT induce vomiting. Consult a physician.

Protection of fi rst-alders: If entering a saturated atmosphere, wear a seif contained breathing apparatus.

5. FIREFIGHTING MEASURES

Extinguishing media: Suitable extinguishing media: Dry chemical, Foam, Carbon dioxide (C02), Water

Special hazards arising f rom the substance or mixture: At high temperature :, Thermal decomposition giving toxic products:, Benzene, Toluene Carbon oxides (by combustion)

Advice for firefighters:

Specific methods: Cool containers I tanks with water spray. Ensure a system for the rapid emptying of containers. In case of fire , remove exposed containers.

Special protective actions for fire-fighters: Wear self-contained breathing apparatus and protective suit.

6. ACCIDENTAL RELEASE MEASURES

Personal precautions. protective equipment and emergency procedures: Avoid contact with the skin and the eyes. Avoid inhalation of vapours. In case of Insufficient ventilation, wear suitable respiratory equipment

Environmental precautions: Do not release into the environment. Do not let product enter drains. Dam up.

Methods and materials for containment and cleaning up:

Recovery: Pump into a labelled inert emergency tank. Absorb the remainder with an inert absorbent material. sand, vermiculite, perlite. After cleaning,

flush away traces with water. Recover waste water for processing later

Elimination: Destroy the product by Incineration (In accordance with local and national regulations).

7. HANDLING AND STORAGE

Precautions for safe handling:

Technical measures/Precautions: Storage and handling precautions applicable to products: Liquid. Irritant. Provide appropriate exhaust ventilation at machinery. Provide

showers, eye-baths. Provide self-contained breathing apparatus nearby.

Safe handling advice: Clean up puddles of product immediately. In case of insufficient vent~ation, wear suitable respiratory equipment Keep away from heat, sparks

and flames.

Hygiene measu'res: Avoid contact with the skin and I he eyes. Avoid inhalation of vapours. When using do not eat or drink.

ARKEMA 420 rue d'Esticnne d'Orves- 92700 Colombes -FRANCE


Page 5 of 10

Product: SDS No.: 000548-001 (Version 3.1 )

JARYLEC® C101 Page: 4 /9

Date 19.12.2011 (Cancel and replace : 15.12.201 1)

Wash hands after handling. Remove contaminated clothing and protective equipment before entering eating areas.

Conditions for safe storage including anv incompatibilit ies: Keep container tightly closed 1n a dry and well-ventilated place. Provide a catch-tank in a bunded area. Provide impermeable floor.

Incompatible products: Oxidizing agents

Packaging material: Recommended: Ordinary steel

Specific use(sl !End Use): None.

8. EXPOSURE CONTROLS/PERSONAL PROTECTION

CONTROL PARAMETERS: Exposure Limit Values Contains no substances with occupational exposure limit values.

Derived No Effect Level (DNEL): BENZVL TOLUENE :

End Use·. Inhalation Workers 3,5 mg/m3 (l T, SE)

Consumers 0,87 mqlm3 (l T, SE)

LE : local effects, SE : Systemic effecs, L T : long term, ST : Short term

Derived No Effect level (DNEL): OIBENZYL TOLUENE :

End Use Inhalation .-

Workers 3,5 mg/m3 (l T, SE)

Consumers 0,87 mq/m3 (lT, SE)

LE : local effects, SE : Systemic effecs, L T : long term, ST : Short term

Predicted No Effect Concentration (PNEC): BENZYL TOLUENE :

Com·partment: Effects on waste water treatment plants

Fresh water sediment

Marine sediment

Oral (Secondary Poisoning)

Soil

Predicted No Effect Concentration (PNEC): OIBENZVL TOLUENE :

Compartment: Effects on waste water treatment plants

Fresh water sediment

Marine sediment

Oral (Secondary Poisoning)

Soil

EXPOSURE CONTROLS:

Ingestion

0,25 mglkg bw/day (l T, SE)

Ingestion

0,25 mg/kg bw/day (L T, SE)

Value: 0,99 g/1

0,331 mglkg dw

0,331 mglkg dw

11,1 mg/kgfood

1 mglkg dw

Value: 1000 mgll

0,11 mglkg dw

0,11 mglkg dw

11,1 mglkg food

1 mglkg dw

General protective measures: Ensure sufficient air exchange and/or exhaust in work areas

Personal protective equipment: Respiratory protection: High concentrations or prolonged activity: Wear a mask, if necessary

Skin contact 0,5 mglkg bw/day (l T , SE)

0 ,25 rng/kg bw/day (l T, SE)

Skin~ntact

0,5 mglkg bw/day (l T, SE)

0,25 mglkg bw/day (l T , SE)

Hand protection: Eye/face protection:

Splash contac~ intermittent and prolonged PVC gloves Glove thickness: 1,2 - 1,4 mm Safety glasses

Skin and body prote'ction:

ARK EMA

At the workplace : Combination with delayed penetration

Intervention at incident: Combination with delayed penetration

420 rue d'Estienne d'Orves - 92700 Colombes- FRANCE

Product: SDS No.: 000548-001 (Version 3.1 )

DIBENZVL TOLUENE :

B loaccumulatlve ootential :

Bioaccumulation:

BENZYL TOLUENE :

DIBENZYLTOLUENE :

JARYLEC® C101




Degradation by radicals OH: Overall ha~-l~e time: 4,7 h, Method : calculated

According to its composition : , Potentially b ioaccumu lable.

PartHian coefficient: n-octanoiJIHater: log Kow: 4,31 -4,40 (Method: OECD Test Guideline 117)

Partition coefficient: n-octanollwater: log Kow: 6,3 • 6,5 (Method: OECD Test Guideline 117)

Mobility In soil • Distribution a mona environmental compartments: Surface tension: 38,24 mNim 25 'C

Absorption I desorption: BENZYLTOLUENE :

Moderate adsorption , log Koc: 3,56 • 3, 77 ( Method: measured ) DIBENZYL TOLUENE :

Strong adsorption , log Koc: 3,55-5,56 (Method: OECD Test Guideline 121 )

Results of PBT and vPvB assessment :

According to REACH regulation, anne~ XIII, this mix1ure contains no substance meeting PBT and vPvB criteria.

13. DISPOSAL CONSIDERATIONS

Waste treatment:

Disposal of product:

Disposal of packaging:

14. TRANSPORT INFORMATION

Destroy the product by incineration (in accordance with local and national regulations). Do not dispose of waste into sewer.

Do not release into the environment. Destroy packaging by incineration at an approved waste disposal site (in accordance with local and national regulations).

Not classified as dangerous in the meaning of transport regulations.

15. REGULATORY INFORMATION

Safety data sheets: according to Regulation (EC) No. 190712006

INVENTORIES: EINECS: TSCA: AICS: DSL: ENCS (JP): KECI (KR): PICCS (PH): IECSC (CN): NZIOC:

Conforms to Conforms to Conforms to All components of this product are on the Canadian DSL list. Conforms to Conforms to Does not conform Conforms to Conforms to

16. OTHER INFORMATION

Full tex1 of R, H, EUH-phrases referred to under sections 2 and 3

R38 R43 R53 R65 H304 H315 H317 H413

ARK EMA

Irritating to skin. May cause sensitization by skin contact. May cause long-term adverse effects in the aquatic environment. Harmful: may cause lung damage if swallowed. May be fatal if swallowed and enters airways. Causes skin irritation. May cause an allergic skin reaction. May cause long lasting harmful effects to aquatic life.

420 rue d'Estienne d'Orves • 92700 Colombes- FRANCE

TOWN OF BARNSTABLE RECEIVED - Regulations.gov

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