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 – Raritan Bay Slag NPL Superfund Site and proposed construction of the Raritan Bay Loop
The Jetty Sectors 7 and 11 of the Raritan Bay Slag Superfund Site are located within the Project facility construction area in Raritan Bay according to Williams-Transco’s 9/7/17 supplemental submission in FERC Accession No. 20170907-5176(323386983), Section 2.2.5.1.2. Documentation of unacceptable levels of lead, arsenic and other heavy metals in the soils, sediment and surface water in and around this Jetty Sector area were provided in both EPA documents and the study provided by Williams-Transco. The dangers of these elements have been documented, and the possibility that workspace activities there, along with construction of a pipeline in close proximity would further spread toxins is unacceptable. Reports by the EPA about the Raritan Bay Slag NPL Superfund Site reference the erosion of particulates from the slag, leaching of metals, and the complex currents in the Jetty Sector that are factors in migration and deposits of these toxic elements.
Just because the EPA has determined that their first cleanup of the three sections of the Raritan Bay Slag Superfund Site starts with the Margaret’s Creek area and then will proceed to the Laurence Harbor Seawall and the Jetty Sectors at the Cheesequake Creek inlet does not mean that he Jetty Sectors are “study” areas and not areas of planned remediation. This change in wording in Williams-Transco’s 9/7/17 supplemental submission is alarming, and their plans for safe construction procedures near this NPL site, with confirmation from the EPA and NJDEP as to the acceptability of these methods, are needed before considering issuing a DEIS or permits for the NESE. If the EPA or NJDEP deem that it is necessary to complete and analyze more samples or specific construction and mitigation methods, these additional studies should be completed before considering issuing a DEIS or permits for the NESE.
Thus, I am requesting that the Commission require written documentation from the EPA and NJDEP that document their conclusions about the plans of Williams-Transco for construction of the Raritan Bay Loop in the Jetty Sector of the Raritan Bay Slag NPL Superfund Site. These documents should be available for public review as submissions to FERC for CP17-101. Additionally, if those in charge of reviewing the Project proposals at these agencies find that a more compressive soil core samples’ study and analysis for the entire workspace and higher granularity of samples where chemicals exceeded allowable limits is needed to ensure safety to humans and marine wildlife and habitats, then these should be completed and analyzed prior to consideration of a Draft Environmental Impact Statement or water permits. Lastly, I am requesting that Williams-Transco document the specific measures that they will take during construction to identify, avoid and mitigate the toxic elements that are already at Raritan Bay Slag Superfund sites.
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.
C: NJDEP