Groundwater – Higgins Farm NPL Superfund Site

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 – Construction and Operation of proposed Compressor Station 206 near the Higgins Farm NPL Superfund Site where contaminated groundwater continues to be monitored and mitigated.

Mitigation and monitoring efforts to address groundwater contamination at the Higgins Farm NPL Superfund continues, and this property borders that of the lot for the proposed CS206. In the EPA’s Five-Year Review Report for Higgins Farm Superfund (2/13/2014), for this site, it is noted that current protectiveness is affected and needs follow-up as specified: (1) monitor the shallow bedrock component of the bedrock VOC plume near the downgradient property boundary {which borders the CS206 lot}; (2) delineate the extent of the 1,1,2-TCA plume along the south-southwest property boundary in the bedrock aquifer; and (3) Open bedrock boreholes are prevalent across the site. Groundwater samples from these wells do not adequately reflect aquifer conditions. EPA plans to conduct another five-year review of the mitigation of groundwater contamination and spread at the Higgins Farm NPL Superfund Site in 2018.

Though Williams-Transco claims that there will be no effect on construction or operation of the proposed CS206 site from this Superfund Site, and Transco conducted a Phase I Environmental Site Assessment and Phase II Investigation in the Fall of 2016 at this Superfund site, these reports were filed with FERC as “privileged”.

Another concern is that there is no written communication from EPA’s Remedial Project Manager, the person from USACE who also has oversight of this Superfund Site, or the NJDEP that they “concur that the Project would not contribute to the spread of contaminated groundwater from the Higgins Farm National Priority List site and that the Project would not conflict with the EPA’s prescribed clean up and monitoring of this site” as the Commission requested from Williams-Transco.

Furthermore, certainty about the current plumes of contamination needs to be verified and studied before a Draft Environmental Impact Statement or NJDEP permits are considered. In addition to potential uncertainty about this, there is also the proposal by Williams-Transco that they will need to install a septic system, and the siting of the access road to the proposed CS206 has not been finalized.

Thus, I am asking the Commission to ensure that the public has access to the Phase I and Supplemental Phase II Investigation Reports for Compressor Station 206; that the NJDEP, USACE and EPA-Region 2 provide written assessments that are publically-viewable on the FERC website for CP17-101 about the potential impacts of the Higgins Farm NPL Superfund site on and/or from construction and operation of the proposed Compressor Station 206 and its access road; and that the final plans for the access road and septic system are presented by Williams-Transco as publically-viewable FERC submissions prior to issuing a DEIS.

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.