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: Missing Data & Analysis – Chemicals planned to be used in Hydrostatic Testing of Pipelines in the Raritan Bay are “proprietary” and marked as hazardous, yet no safety analysis on aquatic life was provided.
Williams-Transco did not provide a study regarding the environmental and health impact of Unidentified Chemicals used for Hydrostatic testing in the Raritan Bay.
Please have Williams specify the chemicals used in product CORRTREAT 15316, ingredient 9154, ingredient 1024 and ingredient 7514. In the toxicity reports, it indicates that toxicity to fish, algae and daphnia as “no data available”. Yet, this product is rated as acute toxicity (oral – 2,619 mg/kg, inhalation – 20 mg/l, dermal – > 5,000 mg/kg). Ingredient 9154 has been tested on rabbits and noted as an ingredient with serious damage to the eyes. Please also require Williams to specify what the overall volume of these chemicals will be used in the hydrostatic testing for the Raritan Bay overall, which locations of the Raritan Bay where chemical release is expected, and the volume of potential emissions.
Additionally, please require Williams to provide the carrier liquids used, the overall volume of the carrier liquids and concentration. Please require Williams to detail a complete breakdown of the liquid used for hydrostatic testing. How will these chemicals impact the ocean life and beaches, and how will total evapotranspiration impact air? These chemicals are marked as hazardous, yet no safety analysis on aquatic life was supplied. Without this data and additional studies, the DEIS cannot comprehensively assess the full environmental impact associated with the chemicals used in hydrostatic testing.
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.