Re: CP17-101 Northeast Supply Enhancement Project
Pursuant to Senator Cory Booker’s and Senator Bob Smith’s submissions, I am hereby notifying FERC of gaps in data not submitted for CP17-101 and missing analysis required for a full and accurate Draft Environmental Impact Statement (DEIS).
Issue: Incomplete Data – Toxic Air Emissions from NESE and especially from CS206
Though Williams-Transco obtained a pre-construction air permit from the NJ Department of Environmental Protection on September 7, 2017, the health and well-being of residents and visitors to the proposed location of the Compressor Station 206 are not protected by this because:
- Without additional data, it is impossible to determine health, environment or safety impact of this project. This is a significant omission in the application, especially since natural gas infrastructure is known to have emissions of many chemicals, some of which are carcinogens. Emissions of these chemicals will have specific impact to the environment, health and safety for the surrounding area.
- Using measurements of air quality at stations like that in New Brunswick, NJ, where the reported findings are not always available online and possibly where it is not working consistently, evades the real threat of emitted toxins to those who live within a five-mile radius of the proposed Compressor Station 206.
- Emissions were reported as averages and did not account for peak emission times when, as has been found around other compressor stations, hospital visits for respiratory and other complaints increased at times that correspond to peak emissions.
- There is no accounting for the impact of their report that the two compressor units will each emit an average of 210,000 cubic feet per minute (CFM) of exhaust at a temperature of 849.2 degrees Fahrenheit at the top of the 50’ smokestacks. They report no studies about how this high temperature & velocity impact nearby vegetation, trees, wildlife and people. Additionally, Williams-Transco reports an expectation that these two smokestacks will also discharge the following amounts of toxins each year: 57 tons of Carbon Monoxide (CO), 23 tons of Oxides of Nitrogen (NOx), 9.5 tons of Volatile Organic Compounds (VOCs), 18.9 tons of Particulate Matter 2.5 micrometers (PM2.5),18.9 tons of Particulate Matter 10 micrometers (PM10), 3 tons of Sulfur Dioxide (SO2), and 0.35 tons of Formaldehyde.
- Compressor stations and associated pipeline leak, and Williams estimates that the compressor station will leak 132,720 tons of Green House Gases (GHG) every year is not apparently relevant in the NJDEP permitting process even though this translates to emissions of 132,720 tons of Natural Gas per year and 123,150.88 tons of Methane (CH4) per year.
- Though Williams-Transco provides expected emissions for VOCS, they did not provide yearly expected levels of emissions for the proposed Compressor Station 206 that include, as a separate listing, those for Methane, Benzene, Toluene, Mercury and Lead even though, in other applications like that for the Atlantic Sunrise (CP15-138), these emissions were specifically reported. This indicates that Williams has the data for the MARS 100 turbine since CP15-138 included a MARS 100 compressor, but Williams did not report these emissions to FERC or the public for the proposed CP17-101 MARS 100 turbines.
Additionally, though the draft Environmental Impact Statement (DEIS) has not yet been published, a recent ruling by the D.C. Circuit of the U.S. Court of Appeals (Aug. 22, 2017) included a recognition that Greenhouse Gases are an indirect effect of a project like NESE and that FERC has the legal authority to mitigate. To ensure that all, including FERC, make an informed decision, the DEIS should account for the emissions from the components of the proposed NESE as well as all potential leaks and downstream emissions that can be predicted from this Project if it is constructed. As was noted in the court ruling, FERC needs to either quantify and consider the project’s downstream carbon emissions or explain in more detail why it cannot do so.
Therefore, I request that the Commission require that Williams-Transco provide the following before issuance of the draft Environmental Impact Statement:
- a full analysis methane leaking and exhaust at their existing MARS compressor located at CS515 (at 19 Ridgeway Ave, White Haven, PA 18661) or any of their other MARS 100 compressor stations. This should be used to inform the analysis of downstream emissions for the proposed CS206 with all associated facilities, pipelines and end-use for the gas.
- proposed compressor station 206 total yearly emissions for Methane, Benzene, Toluene, Mercury and Lead at the site in detail. This should be done promptly and prior to issuance of the draft Environmental Impact Statement.
- studies about the impact of the velocity of emissions at this temperature on birds, bats, and nearby forests and the habitats needed for wildlife from other compressor stations with similar emissions – temperature and rate.
- air quality analysis in real time at Trap Rock Quarry and the proposed CS206 Site NOW as a mandatory data requirement for the DEIS. Note: Without real data, the impact is not fully assessed, and using the New Brunswick Air quality monitor is too far away and not always operational.
The above missing data and analysis are significant gaps for CP17-101 application. This project is meant to be a convenience, not to harm people, damage the environment or increase climate change. I urge FERC to pursue all highlighted gaps in data and analysis for this project to provide a comprehensive DEIS.
I very much appreciate your vigilance and oversight in fully assessing all potential risks, heath threats and environmental impacts that this project poses.