ACTION ALERT: Urge NJ DEP to Withdraw the Air Pollution Control Permit

ACTION ALERT

Urge NJDEP to withdraw the air pollution control permit (Permit Activity Number: PCP170001; PI Number: 36396) and require  Williams/Transco to submit a new air pollution permit application that will need to adhere to the new, more protective thresholds.

Use the attached letter to tell NJDEP that you want them to withdraw the Air Pollution Control Preconstruction Permit and  Certificate to Operate Construction of a New Source that was issued to Williams/Transco on September 2017.

Letter to send to NJDEP:
   –Snail Mail (docx)
–Email (docx)

  • Send it to the list of people at NJDEP provided below.
  • Review the memo that Franklin Township’s Town Manager sent to the NJDEP on August 28, 2018 for more details.

BASIS FOR REQUEST = REGULATIONS OF NJDEP

N.J.A.C. 7:27-8, “Permits and Certificates for Minor Facilities”

  • Section 8.16 – Revocation:
    (b)    The Department may withdraw its approval of a preconstruction permit or permit revision if the permittee:
    1. Does not begin the activities authorized by the permit or permit revision within one year from the date of its approval
  • Section  8.13 – Conditions of approval:
    (b)  The Department may change the conditions of approval of a certificate:
    3. At any time during the period a certificate is in effect, if the Department determines that such change is necessary to protect human health or welfare or the environment.

SEND LETTER VIA EMAIL OR SNAIL MAIL TO:

Catherine R. McCabe, NJDEP Commissioner Commissioner@dep.nj.gov
401 E. State St.
7th Floor, East Wing
P.O. Box 402
Trenton, NJ 08625-0402

Ruth W. Foster, PhD., P.G., Acting Director Ruth.Foster@dep.nj.gov
Office of Permit Coordination and Environmental Review
401 East State Street
PO Box 420
Trenton, NJ 08625

Kenneth Ratzman, Assistant Director – Air Quality Regulation & Planning Kenneth.Ratzman@dep.nj.gov
Bureau of Stationary Sources: Regulation & Planning
401 E. State Street, 2nd Floor;  P.O. Box 420
Mail Code 401-02
Trenton, NJ 08625

Office of Governor Murphy constituent.relations@nj.gov, madeline.urbish@nj.gov
P.O. Box 001
Trenton, NJ  08625

NJDEP’s commitment is to assist in preserving, sustaining, protecting and enhancing the environment to ensure the integration of high environmental quality, public health and economic vitality in partnership with the general public, businesses, environmental communities and government entities through aggressive environmental protection and conservation efforts; and

The proposed Northeast Supply Enhancement (NESE) Project is incompatible with the State’s goal to reduce emissions by 80% from the 2006 baseline by 2050 or Governor Murphy’s Executive Order 28 goal for the State to use 100% clean energy sources by January 1, 2050.

Though the NJDEP issued an air pollution control permit to Williams/Transco for the proposed Compressor Station 206 on September 7, 2017, they have the power to withdraw this permit and require Williams/Transco to submit a new application that will require adherence to stricter (more protective) air pollution standards.

Note that the NJDEP adopted stricter air pollution control standards that went into effect in February 2018 to protect human health, and the anticipated Hazardous Air Pollution (HAPs) emissions from one compressor unit for the NESE Project exceed all of them.  At this facility, there will be two compressor units.  The permit was issued under older standards, and the permitting was for each compressor unit separately.

Emissions of caustic chemicals predicted by Williams/Transco for two (2) Solar MARS 100 turbines

at proposed Compressor Station 206 with the NJDEP Reporting Thresholds (old & new)

EMITTED CHEMICAL

POUNDS PER YEAR

To be emitted

from Compressor Station 206

Reporting Thresholds (NJDEP)

new

old

from one turbine

from two turbines

N.J.A.C. 7:27-17.9

N.J.A.C. 7:27-8

(February 12, 2018)

(February 27, 2015)

Formaldehyde

334

668

3.5

400

Acetaldehyde

44

88

21

1,800

Acrolein 

7.02

14.04

1

8

Benzene

13.18

26.36

6

87.6  (0.01 lbs/hour)

Ethylbenzene

35.2

70.4

19

2,000

Naphthalene

1.428

2.856

1.4

2,000

Propylene Oxide

31.8

63.6

12

1,000

Toluene

142.5

285

2,000

Xylenes

70

140

2,000

Ammonia

14,790 *

29,580 *

* No threshold standards

Though FERC decided that there was no need to complete a Health Impact Assessment for people around the proposed Compressor Station 206 site, they still expect to issue a final Environmental Impact Statement on January 25, 2018 without:

  • Clarifying misrepresentation of emission estimates from Williams/Transco for CS206
  • Assessing toxic impact to nearby environment, human health and water pollution
  • Assessing local air quality impact on MARS 100 combustion efficiency and emissions
  • Validating actual chemical and greenhouse gas emissions using Natural Gas mixtures in Williams/Transco lines in the New Jersey/Pennsylvania area
  • Obtaining actual emissions of MARS 100 turbines in the New Jersey/Pennsylvania area.  Data used is obtained from Solar test runs in lab located in San Diego, California.
  • Revising environmental impacts from toxic chemical emissions recently issued in research studies directly correlating human health impacts and immune disorders with natural gas fired compressor turbines.

THUS, WE ARE RELYING ON THE NJDEP TO ACT TO PROTECT OUR HEALTH.

Reasons for withdrawing the air pollution control permit:

  • Transco applied for the NJDEP CS206 air compressor emissions air permit on January 6, 2017.   NJDEP approved Transco’s air permit application on September 7, 2017, based on Williams/Transco’s wording in dialogue with NJDEP with misleading emission estimates and no actual emission data.  NJDEP permit application correspondence with Williams/Transco indicates that NJDEP did not evaluate or cross reference estimates and NJDEP did not detect the emission reporting irregularities in the data provided by Williams/Transco.
  • Williams/Transco received their air pollution permit before stricter air quality standards in N.J.A.C. 7:27-17.9 were operative in February 2018.  These new, lower reporting thresholds for Hazardous Air Pollutants (HAPs) were adopted due to the rapid decrease in air quality and the urgent need to tighten air emissions in New Jersey. 
  • In the NJDEP permit application and also included in Williams/Transco’s application to FERC were test results provided by Solar for two (2) test runs on Solar Mar 100 units.  Testing was performed in Solar’s labs located in San Diego, CA.  Test run results indicate a high dependency with temperature producing a highly variable emission output.  Tests did not account for the impact of environmental factors such as relative humidity, air quality and elevation at the actual proposed site on the natural gas combustion despite having significant impact and consequential emissions of chemicals and greenhouse gasses.  Additionally, data was missing in the emissions reporting of each test run.  Additionally, Solar, FERC, and Williams/Transco did not consider or assess the difference between the location where test runs were performed (San Diego, CA) versus the target location where the Compressor Station 206 is proposed to be installed (Franklin Township, NJ).  Neglecting the factors of installation location air quality, relative humidity, temperature patterns and elevation at the proposed CS206 site means that to date, there is no legitimate estimate of emissions or chemical and greenhouse emissions for MARS 100 turbines installed at the proposed location.
  • NJDEP did not receive any actual data of existing MARS 100 turbines (CS206 proposes 2 MARS 100 turbines) from existing MARS 100 turbines deployed along Williams/Transco’s pipelines throughout Pennsylvania, which would have a much more accurate representation of emissions for the CS206 proposed location.
  • Without current air quality measures at the proposed location, the emissions estimates have no bearing or accuracy for actual emissions at the proposed location.
  • Humidity and ambient air quality directly impact combustion, yet data was only provided for 60% humidity, and the ambient air quality measures were not taken at the immediate site that is next to an air polluting facility (Trap Rock Quarry).
  • In the FERC application, Williams/Transco provided emission estimates on one table claiming estimates were for both turbines and on a table one (1) page later showing emissions represented a single turbine.  The emissions for VOCs turned out to be for one (1) turbine.  Additionally, some of the emissions were inconsistent with emission estimates provided by manufacturer emissions. 
  • Test run data and Specification Sheets provided by Solar, show that both RPM and HP are lower at higher (average: 59°F) temperatures which suggests that combustion is converting less fuel to energy.  This indicates there is a possibility that increased unburned fuel, primarily Methane, would be released as exhaust.
  • Solar does not warranty emissions for SO2, PM10, PM2.5, VOC and formaldehyde according to their Predicted Emission Performance pages.  This means that the Solar MARS 100 emissions of SO2, PM10, PM2.5, VOC and formaldehyde are highly variable and subject to environmental and variability of older combustion technology used in MARS 100 turbines.
  • Williams/Transco referenced air quality monitors used for the ambient air quality readings that were not the closest monitors to the proposed Compressor Station 206 site, and wind direction is a relevant factor.  For example, there are monitoring stations at Edison’s EPA building and at the Rutgers station at Cook College which are closer than Elizabeth, NJ or Philadelphia, PA.
  • NJDEP did not indicate any validation or analyses of the Ammonia emissions, which is estimated under San Diego generated test runs to be 29,580 pounds per year.
  • If Volatile Organic Compounds (VOCs) are higher, or other contaminants such as Particulate Matter (PM2.5 and PM10) are higher in New Jersey than where the testing occurred and the efficiency of combustion conversion to energy is reduced; then it is very likely that the MARS 100 turbines will emit more pollutants and unburned fuel in the exhaust on an ongoing basis for the expected lifetime operation of the Compressor Station 206.
  • Over the past seven years, Williams/Transco has frequently upgraded and expanded turbines at existing compressor stations throughout New Jersey.  This indicates that there is a high likelihood that Williams/Transco will attempt add more MARS 100 turbines to the CS206 location.

Attachments: