Tag: Transcontinental Gass Pipe Line Co. LLC

ACTION ALERT: Be Prepared!

WHY IS THE NESE PROJECT A BAD IDEA?

We’ll wait to see what is in new applications to NJDEP and NYSDEC, but the issues in these comments will likely remain relevant.

A Climate Disaster 

  • A major reason to oppose NESE is the impact it will have on accelerating climate change.  This billion dollar project will lock the region into decades of continued reliance on fossil fuels.  If approved, the project will bring climate altering methane gas to New York City, resulting in the equivalent of over 7 million tons of carbon dioxide into the atmosphere every year!

Incompatible with New Jersey and New York’s Clean Energy Agenda 

  • To address climate change, both Governor Murphy of New Jersey and Governor Cuomo of New York have unveiled progressive climate plans to significantly reduce emissions and promote a swift transition to renewable energy.  NESE creates a legacy incompatible with these goals. 

Destruction of Decades of Water Quality Improvement in the Raritan and Lower New York Bays

  • The Raritan Bay and Lower New York Bay are the oldest industrial watersheds in the nation.  Decades of pollution, dumping, and mismanagement resulted in widespread contamination.  However, environmental efforts in the last few years have significantly improved the area.  NESE threatens to reverse these improvements.  Dredging of a 23.4 mile trench through the heart of these waterways will re-suspend sediment containing harmful toxins such as PCBs, dioxin, lead, mercury and arsenic.
  • The company behind the project also plans to discharge over 690,000 gallons of drilling fluids into the water releasing untold chemicals and biocides into the marine environment.

Harm to Marine Life 

  • The area the proposed pipeline will disrupt is home to a wide variety of marine life.  The Raritan and Lower New York Bay is home to over two-hundred species of fish, sixteen species of marine mammals, including the Atlantic Right Whale, and five species of turtles. Several of these species are considered endangered or threatened. 
  • Construction of the offshore pipeline will result in widespread industrial activity which will harass and harm marine life.  The resuspension of the toxic contaminants will destroy important ecosystems such as oyster reefs, clam beds, wetlands and shallow waters.  As the toxic sediment resettles, it will also suffocate fish eggs and larva, killing the next generation of marine life.  

Ocean Dumping – Contaminating the Atlantic Ocean 

  • The company plans to not only re-suspend harmful toxic sediment, but has proposed to dump over 735,000 cubic yards of contaminated sediment into the ocean.  This will expose marine life to toxic pollutants, reintroducing toxins into the environment and allowing it to enter the food chain.

A Threat to Public Health and Safety 

  • Over the past years, pipelines and pumping stations owned and operated by the company proposing NESE have experienced over ten explosions or fires.  In the last five years, the company has continued to receive safety and risk violations from various federal agencies including penalties in New York and New Jersey.  The company has also received numerous fines from the EPA for unsafe discharges of pollutants. 
  • Compressor Station 206 is proposed to be built in a densely populated area, next to an active blasting quarry and a Superfund site. 
  • Compressor Station 206 will increase the velocity of gas through pipelines that are over 50 years old which will accelerate the rate of corrosion that leads to fires and explosion.   

Increased Air/Noise Pollution 

  • The proposed Compressor Station 206 will result in harmful emissions of toxic air pollutants such as Carbon Monoxide, Sulfur Dioxide, Nitrous Oxides, Particulate Matter 2.5, Volatile Organic Compounds, Formaldehyde, and Benzene, and some of these emissions will increase Ozone, which is unhealthy for children, the elderly, and those with respiratory ailments.
  • For the second consecutive year, the American Lung Association gave both Monmouth County and Middlesex County an F in the annual State of the Air report for ozone pollution. 
  • Low-frequency noise from compressor stations, it has been reported, is harmful to both humans and wildlife.

An Unneeded Cash-Grab

  • The billion dollar project will be paid for by ratepayers in New York. If approved, federal regulations will give Williams-Transco a mandatory 14% return on investment for the harmful project.  There are better, less harmful alternatives to this massive overbuild of a project based on profit and not need.  
  • In fact, after New York regulators previously denied the project for the environmental harm it would create, National Grid, the utility contracted to purchase the gas from the project, issued a moratorium on all new connections and urged customers to support the project.  New York regulators concluded that there was no proof that the moratorium was needed and fined the company 35 million dollars, and ordered the company to lift the moratorium.  

Comment Topics – Elaborated Points are in the attached PDF documents.

COMMENT 1: Construction of the NESE Project threatens water quality, increased stormwater flooding, and threatened & endangered species.

  • Construction of a stormwater basin at the proposed Compressor Station 206 site does not include complete plans that account for the specific soil type that exists there.
  • Impacts to the habitat for the State threatened barred owl as well as protected vernal pool habitats at the proposed Compressor Station 206 site were not adequately assessed or avoided.
  • Construction Schedule of the Raritan Bay Loop was reduced from 12 months to 7 months.
  • A shortened timeline increases the intensity of work, so the overall impacts will be magnified.  
  • Noise Impacts from Pile Drivings – It is not clear if the construction schedule for these activities has changed with the compressed construction schedule for the Raritan Bay Loop, but their requests for harassment permission have increased.
  • Dredging up toxics has not been avoided by construction of the Raritan Bay Loop, and this will likely cause long-term harm that was not accounted for in the applications.
  • To reach a conclusion that the impacts on water quality would be short-lived, temporary and localized neglects to consider the unusual tidal flows in Raritan Bay, the chain-reactions from destroyed habitat and food sources for marine life, and the contamination of food sources for marine life and people.
  • NESE’s Raritan Bay Loop’s Undisputed, Devastating Impact on Shellfish Beds and Benthic Communities 
  • Williams/Transco has not sufficiently identified permanent, temporary, and secondary/indirect impacts from onland construction, and they have not shown plans to avoid and/or mitigate these impacts.
    • Acid Producing Soils
    • Construction through or near Superfund Sites & other toxic sites
LONG COMMENT
SHORT COMMENT

COMMENT 2: Williams/Transco did not demonstrate a “compelling public need” for the NESE Project that meets requirements of NJ’s Freshwater Wetlands Protection Act Rules at N.J.A.C. 7:7A-10.4 or, alternatively, demonstrate an extraordinary hardship from denial of a permit.

The NESE Project does not serve an essential health or safety need of the municipality in which it would be constructed, and its proposed use does not serve existing needs of residents of the State.  

  • Air Quality & Health Impacts
  • Safety Risks – Fires or Explosions

Additionally, the “need” for the NESE Project has been refuted by reports, and the needs of the State that are currently focused on fighting climate change impacts would be harmed by the NESE Project despite claims by Williams/Transco about “benefits” to New Jersey.

LONG COMMENT
SHORT COMMENT

COMMENT 3: NESE is not in the Public Interest.

  • Need to preserve natural resources
  • Relative extent of the public and private need for the regulated activity
  • Practicability of using reasonable alternative locations and methods
  • Economic value
  • Ecological value of the freshwater wetlands and probable impact on public health and fish and wildlife.  
LONG COMMENT
SHORT COMMENT

COMMENT 4: Contaminants that would be unearthed, suspended and redistributed in the Raritan Bay exceed “acceptable” levels.  Exceedances were found by the NYSDEC for heavy metals (copper & mercury) in New York waters, too.   Thus, construction of the Raritan Bay Loop of the NESE Project would (a) negatively impact surface water quality, and (b) harm threatened and endangered species and their habitat.

Additionally, the shortening of the in-water construction schedule raises serious concerns about impacts from increased vessel traffic and noise as well as adhering to time-of-year restrictions to protect threatened and endangered species if the schedule needs to be altered due to unforeseen circumstances.

Furthermore, the unique tidal flows in the Raritan Bay do not seem to have been given appropriate consideration.

LONG COMMENT

COMMENT 5: Other Concerns about In-Water Construction

  • Time of Year Restrictions
  • Thermal Discharges
LONG COMMENT
SHORT COMMENT

COMMENT 6: There is a Questionable “Need” for additional natural gas in National Grid’s NY area.

LONG COMMENT
SHORT COMMENT

COMMENT 7: There is no real consideration of climate crisis-mitigating renewable alternatives by the Federal or State agencies.

Additionally, the impact of the NESE Project on climate change effects should be considered in light of the threats facing New Jersey as well as the State’s goals to reduce greenhouse gases.

LONG COMMENT
SHORT COMMENT

ACTION ALERT: Stop NESE – 3 Quick Actions You Can Take Today!

Call to Action: Stop NESE last quick action to FERC prior to FEIS issuance scheduled for 1/25/2019

As we rapidly approach the scheduled release of the FEIS for CP17-101, the question arises, “What can people do to make any impact for stopping this atrocity project from occurring?”

We are calling for the coalition to please take action and reach out to others to take action in the next 20 days leading up to the scheduled FERC FEIS (Final Environmental Impact Statement).  This is the last time where the public will have any meaningful impact on the FERC process. 

We developed 3 quick actions with sample messages that will have impact, especially with more people doing the actions.  Even New York and Pennsylvania people can voice in on these issues.  This might be NJ focused on impact, but the reality is, the more people voicing in, the more force we raise to FERC.

If NY folks have quick bullets of major FERC omissions at this point, please send them on.

Quick 5 minute actions

  1. Call and email Senator Smith (senbsmith@njleg.org, (732) 752-0770, @SenatorBobSmith).
    Bill SR94 sitting in Env & Energy committee that he chairs for more than 5 months.
    Sample message: https://drive.google.com/open?id=1dE1ROHaj94R1YK9rG3a0_XHS_mcJ1GfYSkypkBx4hv0
  2. Call and email Assemblyman Wayne DeAngelo (asmdeangelo@njleg.org, (609) 631-7501; @DeAngeloLD14).
    Bill AR164 sitting in Telecommunications & Utilities that he chairs for more than 5 months.
    Sample message: https://drive.google.com/open?id=17ZGOTMOd6GHNOwWXWJ0NCxFwqvzpFb9n7flgjnGQnII
  3. Send comment to FERC and copy your legislators urging FERC to heed impacted residents and municipalities.
    1. Reference Franklin Township 12/20/2018 FERC Submission including FTTF Memo:
      FERC: https://elibrary.ferc.gov/idmws/search/intermediate.asp?link_file=yes&doclist=14731233
      Also available on our GoogleDrive: https://drive.google.com/open?id=1FVbdYd9S_iwliWl85fjInFBKt7g_ChRV
    2. Sample Letter: 
      https://drive.google.com/open?id=1rALfYAamSenn73q1FmN8_jrBC1ZpsIUzwRtTUiypmtg

In addition to Franklin Township sending the FTTF Memo to FERC, South Brunswick sent the attached memo to FERC right at the end of 2018.  Waiting for Montgomery and Princeton to do the same, if you live in those areas, please encourage them to do so.

We have come 2 years fighting this project and we have delayed FERC twice.  That is significant.  It is from this coalition and all the actions from the public that the coalition has influenced that enabled the delays.  Let’s capitalize on that and go out with a bang prior to the issuance of the FEIS scheduled for 1/25/2019!

A number of us on FTTF have continued through the last half of 2018 sending comments to FERC, calling elected officials and actively pressing back on Transco even in Twitter.

We urge all the communities engaged to please help residents take this last set of actions prior to the FEIS (including Princeton Manor, Princeton Highlands, Princeton Walk and Princeton University teams)

The FTTF steering committee team would like to wish you Happy New Year and with your help, maybe free of the threat of NESE.

Action Alert – NJDEP Update

NJDEP has heard from us about issues with the Freshwater Wetlands Permit Application. 

  • See the attached transcript of the comments (PDF) at the November 5, 2018 hearing at Franklin High School.
  • By November 20 (the deadline to send comments to NJDEP about this permit), over 1,000 comments were sent. 

NJDEP is still reviewing the permit applications and asking Williams/Transco for more information.  Permits are needed from NJDEP for Freshwater Wetlands, Flood Hazard Area, Coastal Wetlands and Waterfront Development.

  • None of the applications have been deemed to be “technically complete”.
  • Applications were received by the NJDEP on June 20, 2018, and they have one calendar year to either grant or deny each permit.

NJDEP stated that there will be another hearing, but the details have not been publicized.  We suspect that the next hearing will be in Old Bridge or Sayreville.

ACTION ALERT: Review NJDEP Application Documents

For the NJDEP hearing, you can review application material from Williams/Transco to NJDEP at:

https://drive.google.com/drive/folders/1Bm6kTq6Fv0JJIC-ra2pOXBH5SPYGWf0c?usp=sharing

These were obtained from the NJDEP through an OPRA request.

The hearing on November 5 is for the Freshwater Wetlands application.

Application for Freshwater Wetlands

Read full ACTION ALERT for the November 5 meeting on TAPinto

Note:  Files on the Google drive with “2017” contain material from the original application that was withdrawn.  The current applications, submitted June 20, 2018, should be marked as 2018.  Not all files are clearly labeled, however.

ACTION ALERT: NJDEP Hearing Monday, November 5

NJDEP scheduled a Hearing for the Wetlands Permit Application for NESE and Compressor Station 206.  See the attached notice.

Show up to let NJDEP know what you think about the proposed Compressor Station 206 & the pipeline in Sayreville & Old Bridge that is planned to also go through Raritan Bay.

DATE:  Monday, November 5, 2018

STARTING TIME:  6:00 PM

PLACE:  Franklin Twp. High School – Auditorium – 500 Elizabeth Ave., Somerset, NJ 08873

Fact-Finding Meetings: 

  • NJDEP staff will facilitate the meeting.
  • People usually get 3 minutes to speak at a microphone in front of the group about their concerns, and a stenographer records it.  It’s not like the FERC meeting where you went into a separate room.
  • Pre-written comments can be submitted at the meeting & can be sent after the meeting.
  • We do expect that pro-NESE people will be there to voice their support (like they were at the FERC public meetings), so we want to have many concerned folks there to tell NJDEP why we do not want NESE.
  • You do not need to be there at 6:00, but if you want to speak, you’ll need to sign-up when you arrive.

Then, NJDEP will give a time period and address for sending them more written comments. 

NJDEP has 90 days after holding fact-finding meetings to issue their decision.

From another hearing, NJDEP provided the following directions:

PUBLIC HEARING RULES OF CONDUCT

The purpose of the hearing is to gather public comment from anyone who wishes to speak. Any action taken by any person that prevents the public from commenting is unacceptable and will not be tolerated. Anyone who violates these rules of conduct may be removed from the hearing.

  • No signs mounted on sticks, or otherwise attached to an object, are allowed within the auditorium
  • No food or drink is allowed within the auditorium
  • Please remain seated until called forward to provide comment
  • No interrupting when someone is speaking
  • No unruly/disruptive behavior (i.e. yelling, chanting, use of foul language)
  • Testimony will be limited to three minutes per speaker

The Department thanks you for your cooperation and participation in this public process

Send comments to the NJDEP

  • Commissioner Catherine McCabe: Commissioner@dep.nj.gov
  •  Director Ruth Foster: Ruth.Foster@dep.nj.gov

Williams/Transco submitted new applications for water permits (Freshwater Wetlands, Flood Hazard Area Control, Coastal Wetlands, & Waterfront Development) on June 19, 2018.

  • Tell NJDEP that you want them to hold two (2) public fact-finding meetings – one by the Raritan Bay (Old Bridge / Sayreville) and one by the proposed Compressor Station 206 area (Franklin Township / South Brunswick).
  • Tell NJDEP that you expect them to deny the permits unless they obtain and carefully review all needed information and actually find that the proposed project would not cause harm to the environment, people or wildlife.
  •  Tell NJDEP that an increase in reliance on fossil fuels for energy does not support New Jersey’s goal to transition to renewables and clean energy.

Sign the letter to NJDEP and either mail it or give it to a member of the Task Force to mail
Click here for link to the letter to print, sign & mail

NOTE: A request for fact-finding meetings needs to be in writing to NJDEP and received in Trenton by August 3.

NESE proposed Compressor Station 206 Chemical Emissions

NESE PROPOSED COMPRESSOR STATION 206:

Chemical Emissions & FERC’s Claim That There’s No Need To Do A Health Impact Assessment In The Area

Update of Concerns & Issues

after FERC published the Draft Environmental Impact Statement (DEIS) on March 23, 2018

FERC’s claims and conclusions in the DEIS:

  • Construction and operation of the Project would not have a significant impact on air quality and a health impact assessment for a facility of this size and limited impact is not warranted.  (DEIS – page E-7)
  • Full-capacity upper-bound (i.e., the station’s potential to emit) emissions from Compressor Station 206 would be less than the NAAQS, which were established to protect human health (including sensitive subpopulations such as children or those with chronic illnesses) and public welfare  (DEIS, page 4-292)
  • There are no national air quality standards for HAPs, but their emissions are limited through permit thresholds and technology standards.  New Jersey maintains regulations limiting emissions of HAPs. (DEIS, page ES-6)
  • The emissions from Compressor Station 206 would comply with the NAAQS, which were established to protect human health (including children, the elderly, and those with chronic illnesses) and public welfare.  Compressor Station 206 would be a minor source of air emissions under federal programs and would comply with applicable federal and state regulations intended to protect air quality. (DEIS, page 4-222)
  • Transco performed an ambient air quality modeling analysis to determine local impacts from Compressor Station 206 using the EPA’s AERMOD dispersion model (Version 16216) in screening mode, which indicated that the maximum modeling concentrations of criteria pollutants would not contribute to an exceedance of the NAAQS. (DEIS, page ES-7)   

However:

  • FERC has not published their final controls and mitigation “recommendations”.
  • Federal and New Jersey state agencies have recognized airborne chemical emissions as highly toxic to human health and causing a variety of immediate and chronic health conditions for the following that Williams/Transco already reported would be emitted from Compressor Station 206 if it is built: Formaldehyde, Ammonia, Acrolein, Acetaldehyde, Ethylbenzene, Benzene, Toluene, Propylene Oxide & Xylenes.
  • Estimated caustic chemical emissions from Compressor Station 206, in pounds per year (lbs/yr), were reported by Williams/Transco to be:
    Formaldehyde= 660lbs/yr; Ammonia = 29,580lbs/yr; Acrolein = 6lbs/yr;
    Acetaldehyde = 44lbs/yr; Ethylbenzene = 34lbs/yr; Benzene = 14lbs/yr; Toluene = 142lbs/yr; Propylene Oxide = 32lbs/yr; Xylenes = 70lbs/yr.
  • The chemicals, listed above, are not measured or regulated under the National Ambient Air Quality Standards (NAAQS) which only provide standards for seven (7) “criteria pollutants”:    ground-level ozone, carbon monoxide (CO), nitrogen dioxode (NOx), sulfur dioxide (SO2), fine particulate matter (inhalable particulate matter with an aerodynamic diameter less than or equal to 10 microns [PM10] and less than or equal to 2.5 microns [PM2.5]), and airborne lead (Pb).  

NOTE:  Ozone is not directly emitted into the atmosphere from an emissions source; it develops as a result of a chemical reaction between NOx and VOC in the presence of sunlight.  Therefore, NOx and VOCs are often referred to as ozone precursors and are regulated to control the potential for ozone formation. VOCs are defined as any compound of carbon which participates in atmospheric photochemical reactions; however, VOCs do not include CO and CO2, nor methane and ethane (among other organic compounds), which have been determined to have negligible photochemical reactivity (40 CFR Part 51.100(s)(1)).  VOCs associated with transmission-quality natural gas are limited to butane, propane, pentane, and hexane. (DEIS, page 4-277)

  • Airborne emissions from Compressor Station 206 have been identified from Williams/Transco, in their Application (Resource Report 9) as estimated to be the following in tons per year (tpy) –

CO = 56.86tpy NOx = 22.74tpy VOC = 8.35tpy; PM10 = 18.94tpy

PM2.5 = 18.94tpy SO2 = 3.07tpy GHG (natural gas) = 132,720tpy

  • Just because the reported emissions are ESTIMATED to be below the NAAQS does not mean that the emissions during blowdown or at other times would not be so high as to actually cause harm.  
  • Measurements of  these seven criteria pollutants are taken at Air Quality Monitoring Stations in Elizabeth (for carbon monoxide & sulfur dioxide) , East Brunswick (for nitrogen dioxide & ozone), North Brunswick (for particulate matter 2.5) and in Philadelphia (for particulate matter 10).  Source: Draft Air Quality Technical Report (December 2017) by Environmental Resources Management, page 6 (published on FERC docket on 12/22/17 in Accession No. 20171222-4003)
  • There was no on-site measurement of air quality that took into account the potential compounded effects of two industrial sites next to each other:  Trap Rock Quarry & the proposed Compressor Station206.
  • In the Application from Williams/Transco for NESE, they report an expectation, based on modeling,  that PM2.5 emissions for Compressor Station 206 and background air would approach the minimally “acceptable” thresholds:

Annual: 10.1 microgram/m3 (EPA-NAAQS threshold:  12 microgram/m3 )

24-hour 32.1 microgram/m3 (EPA-NAAQS threshold:  35 microgram/m3 )

  • The emitted toxins for the natural gas-fired compressor station have been known to have synergistic effects, and this was not considered by FERC in their DEIS.
  • There are current studies that report health impacts from emissions around natural gas compressor stations.  (see references below)

SOME STUDIES OF HEALTH HAZARDS OF EMISSIONS FROM NATURAL GAS-FIRED COMPRESSOR STATIONS

Bowe, B., Xie, Y., Li, T., Yan, Y., Xian, H. & Al-Aly, Z.  (2017, September 21). Particulate matter air pollution and the risk of incident CKD and progression to ESRD.  Journal of American Society of Nephrology, 29: 218-230. Retrieved from http://jasn.asnjournals.org/content/29/1/218.full.pdf+html

Compendium of scientific, medical, and media findings demonstrating risks and harms of  fracking (unconventional gas and oil extraction) (5th ed.)  (2018, March). Concerned Health Professionals of New York & Physicians for Social Responsibility.  Retrieved from http://concernedhealthny.org/compendium/

Kloczko, N.  (2015, November).  A brief review of compressor stations.   Southwest Pennsylvania Environmental Health Project.  Retrieved from http://www.environmentalhealthproject.org/files/A%20Brief%20Review%20of%20Compressor%20Stations%2011.2015.pdf

NY Compressor Station Report.  Retrieved from http://www.environmentalhealthproject-ny.org/

Russo, P.N. & Carpenter, D.O. (2017, October 12).  Health effects associated with stack chemical emissions from NYS natural gas compressor stations: 2008-2014.  Institute for Health and the Environment – A Pan American Health Organization / World Health Organization Collaborating Centre in Environmental Health, University at Albany.  

Retrieved from https://www.albany.edu/about/assets/Complete_report.pdf

Summary of Minisink Monitoring Results.  

Retrieved from http://www.environmentalhealthproject.org/resources/10/click/5

Summary on compressor stations and health impacts.  (2015, February 24). Southwestern Environmental Health Project.  Retrieved from http://www.environmentalhealthproject.org/files/Summary%20Compressor-station-emissions-and-health-impacts-02.24.2015.pdf

The hazards of a compressor station:  A town wakes up to the realities of corporate deception.  (2015,

November).   Retrieved from http://350ma-berkshires.org/the-hazards-of-a-compressor-station-a-town-wakes-up-to-the-realities-of-corporate-deception/

 

RISKS OF CHEMICALS THAT WILL BE EMITTED FROM THE PROPOSED COMPRESSOR STATION 206

AMMONIA

CS206 emission 29,580 lbs per year
  • Suspected liver, gastrointestinal, reproductive, respiratory, skin, and neurotoxicant (EDF Goodguide)
  • Exposure from inhalation may cause bronchiolitis obliterans; symptoms include cough, wheezing, obstructive/restrictive defect, chronic shortness of breath and difficulty breathing from low activity, increased inflation of lungs (HAZMAP)
  • Exposure through inhalation may cause toxic pneumonitis (acute inflammation of lungs); symptoms include burning, chest tightness, conjunctivitis, cough, dark or bluish color of skin due to oxygen deficient blood, shortness of breath and difficulty breathing from low activity, crackling when listening to breathing with stethoscope, excessive tearing of eyes, sore throat, pulmonary edema (increased fluid in lung tissues), runny nose, wheezing (HAZMAP)
  • Exposure through inhalation may cause chronic bronchitis; symptoms include coughing up phlegm, wheezing (HAZMAP)
  • TOXIC; may be fatal if inhaled, ingested or absorbed through skin; vapors are extremely irritating and corrosive (NOAA)
  • High exposure can cause a build-up of fluid in the lungs (pulmonary edema) (NJ Fsheet)
  • Strong irritant to eyes, skin, respiratory tract (HSDB)
  • Exposure to high levels of ammonia in air may be irritating to skin, eyes, throat, and lungs and cause coughing and burns; lung damage and death may occur after exposure to very high concentrations of ammonia; some people with asthma may be more sensitive to breathing ammonia than others (ASTDR)
  • Populations at increased risk include asthmatics, those hyper reactive to other respiratory irritants, and those with glaucoma, corneal disease, and chronic respiratory disease (HSDB)
  • Agency exposure limits:
    • CDC Acute Inhalation Risk Level at 1.7 Parts Per Million (PPM)
    • OSHA: 50ppm over 8 hour work shift
    • NIOSH: 25ppm over 10 hour work shift (NJ Fsheet)
FORMALDEHYDE

CS206 emission 660 lbs per year
  • Known carcinogen (HAZMAP)
  • Suspected gastrointestinal/liver, immune system, neuro, reproductive, respiratory, and skin/sense organ toxicant (EDF Goodguide)
  • Adverse effects from exposure include asthma and toxic pneumonitis (inflammation of the lungs) (HAZMAP)
  • High exposure through inhalation can cause a buildup of fluids in the lungs (NJ Fsheet)
  • Repeated exposure may cause bronchitis and an asthma like allergy (NJ Fsheet) 
  • Limited evidence that exposure may damage developing fetus and affect female fertility (NJ Fsheet)
  • Eye, skin, and respiratory tract irritant (HSDB)
  • People with asthma may be particularly sensitive to exposure (HSDB)
  • Exposure through inhalation can cause burning sensation, cough, headache, nausea, and shortness of breath (NIOSH)
  • Agency exposure limits:
    • CDC Acute Inhalation Risk Level at .04 parts per million (PPM)
    • OSHA: 0.75ppm averaged over 8 hour work shift
    • NIOSH: 0.016ppm averaged over 10 hour work shift (NJ Fsheet)

 

RISKS OF CHEMICALS THAT WILL BE EMITTED FROM THE PROPOSED COMPRESSOR STATION 206

 

BENZENE

CS206 emission
14 lbs per year
  • Listed as a known carcinogen (HAZMAP)
  • Listed as a recognized carcinogen and developmental and reproductive toxicants (EDF Goodguide)
  • Listed as a cause of anemia (decrease in number of red blood cells) (HAZMAP)
  • Listed as a neurotoxin (cause of central nervous system solvent syndrome) (HAZMAP)
  • Listed as a reproductive toxin (HAZMAP) 
  • Listed as a suspected cardiovascular/blood, endocrine, gastrointestinal/liver, immune system, neuro-, respiratory, skin/sense organ toxicant (EDF Goodguide)
  • The major effect of benzene from long-term exposure is on the blood; causes harmful effects on the bone marrow and can cause a decrease in red blood cells leading to anemia; can also cause excessive bleeding and can affect the immune system, increasing the chance for infection (ASTDR)
  • Occupational diseases associated with exposure include: leukemia and aplastic anemia (symptoms include fever, bleeding into the skin, mouth, nose, and gastrointestinal tract caused by the low platelet count of aplastic anemia and the damage to capillaries caused by viral hemorrhagic fevers, decreased white blood cell count, tiny circumscribed foci of extravagated blood in the skin); large areas of confluent petechiae are called purpura, ecchymoses, or bruises (HAZMAP)
  • Acute exposure to high concentrations of benzene in air results in neurological toxicity (headache, dizziness, drowsiness, confusion, tremors, and loss of consciousness) (HSDB)
  • Agency exposure limits:
    • CDC Acute Inhalation Risk Level at .009 Parts Per Million (PPM)
    • OSHA: 1ppm averaged over 8 hour work shift
    • NIOSH: 0.1ppm averaged over 10 hour work shift (NJ Fsheet)
ETHYLBENZENE


CS206 emission
34 lbs per year
  • Possible human carcinogen (ASTDR)
  • Listed as a suspected blood/cardiovascular, developmental, endocrine, gastrointestinal/liver, kidney, neuro, reproductive, respiratory, and skin/sense organ toxicant (EDF Goodguide)
  • Limited evidence that ethylbenzene may damage the developing fetus (NJ Fsheet)
  • Exposure to relatively low concentrations of ethylbenzene in air for several months to years causes kidney damage in animals (ASTDR)
  • High exposure can cause symptoms similar to chronic solvent encephalopathy, a syndrome with a variety of central nervous effects (HAZMAP)
  • Exposure may cause acute toxic effects such as difficulty concentrating, confusion, dizziness, fatigue, irritability, lethargy, impaired speech (HAZMAP)
  • Most severe irritant of benzene series (HSDB)
  • Exposure to high levels of ethylbenzene in air for short periods can cause eye and throat irritation; exposure to higher levels can result in dizziness (ASTDR)
  • Irreversible damage to the inner ear and hearing has been observed in animals exposed to relatively low concentrations of ethylbenzene for several days to weeks (ASTDR)
  • Inhalation may cause irritation of nose, dizziness, depression (NOAA)
  • Agency exposure limits
    • CDC Acute Inhalation Risk Level at 5 Parts Per Million (PPM)
    • OSHA: 100ppm averaged over 8 hour work shift
    • NIOSH: 100ppm averaged over 10 hour work shift (NJ Fsheet)

 

RISKS OF CHEMICALS THAT WILL BE EMITTED FROM THE PROPOSED COMPRESSOR STATION 206

 

ACETALDEHYDE

CS206 emission

44 lbs per year
  • Listed as a possible human carcinogen (HSDB)
  • Suspected developmental, immune system, kidney, neuro, respiratory, skin/sense organ toxicant (EDF Goodguide)
  • Acetaldehyde may cause birth defects in humans since it causes them in animals (NJ Fsheet)
  • Exposure can cause toxic pneumonitis (inflammation of the lungs) (HAZMAP)
  • Eye irritant at 50ppm for 15 min.; respiratory tract irritant at 134ppm for 30 min.; nose and throat irritant at 200ppm for 15 min. (HSDB)
  • Breathing vapors will be irritating and may cause nausea, vomiting, headache, and unconsciousness (NOAA)
  • Exposure to high concentrations can cause headache, dizziness, headache, light-headedness, and passing out (NJ Fsheet)
  • Higher exposures may cause a buildup of fluid in the lungs (NJ Fsheet)
  • Repeated exposure may bronchitis to develop with coughing, phlegm, and shortness of breath (NJ Fsheet)
  • Agency exposure limits:
    • CDC Acute Inhalation Risk Level – A harmful contamination of the air can be reached very quickly on evaporation of this substance at 20°C.
    • OSHA: 200ppm over 8 hour work shift
    • NIOSH: limit to lowest feasible concentration (NJ Fsheet)
NAPHTHALENE

CS206 emission

2 lbs per year
  • Listed as a possible carcinogen (HSDB)
  • Suspected cardiovascular/blood, developmental, gastrointestinal/liver, neuro, respiratory, skin/sense organ toxicant (EDF Goodguide)
  • Limited evidence that exposure may damage developing fetus (NJ Fsheet)
  • May damage red blood cells causing anemia (low blood count) (NJ Fsheet)
  • Exposure to large amounts may damage red blood cells or cause hemolytic anemiadestroy (destroys red blood cells resulting in too few red blood cells until body replaces them; symptoms include fatigue, lack of appetite, restlessness, and pale skin) (ASTDR)
  • Exposure may cause methemoglobinemia (blood disorder in which an abnormal amount of methemoglobin [form of hemoglobin–the molecule in red blood cells that distributes oxygen to the body] is produced, preventing oxygen from being effectively released to tissues in the body) (HAZMAP)
  • Naphthalene is an ocular irritant that has caused cataracts in exposed workers (HAZMAP)
  • Acute toxic effects from exposure include abdominal pain, confusion, cough, fatigue, wheezing, weakness, buildup of fluid in the lungs, nausea, and more (HAZMAP)
  • Effects from exposure through inhalation include headache, weakness, nausea, vomiting, sweating, confusion, jaundice, and dark urine (NIOSH)
  • People with blood, kidney, or liver diseases may be at a heightened risk (HSDB)
  • Agency exposure limits:
    • CDC Chronic Inhalation Risk Level at .0007 Parts Per Million (PPM)
    • OSHA: 10ppm averaged over 8 hour work shift
    • NIOSH: 10ppm averaged over 10 hour work shift (NJ Fsheet)

RISKS OF CHEMICALS THAT WILL BE EMITTED FROM THE PROPOSED COMPRESSOR STATION 206

 

TOLUENE

CS206 emission

142 lbs per year
    • Listed as a recognized developmental toxicant (EDF goodguide)
    • Listed as a suspected cardiovascular/blood, gastrointestinal/liver, immune system, kidney, neuro-, reproductive, respiratory, and skin/sense organ toxicant (EDF goodguide)
    • Inhaling high levels of toluene in a short time can make you feel light-headed, dizzy, or sleepy; can also cause unconsciousness, and even death (ASTDR)
    • High levels of toluene may affect your kidneys (ASTDR)
    • Toluene may cause birth defects in humans as it has been shown to cause them in animals (NJ Fsheet)
    • Toluene may damage developing fetus (NJ Fsheet)
    • High exposure can cause symptoms similar to chronic solvent encephalopathy (a syndrome with a variety of central nervous effects) (HAZMAP)
    • Exposure may cause acute toxic effects such as difficulty concentrating, confusion, dizziness, fatigue, irritability, lethargy, impaired speech (HAZMAP)
    • Toluene may affect the nervous system; low-to-moderate levels can cause tiredness, confusion, weakness, drunken-type actions, memory loss, nausea, loss of appetite, and hearing and color vision loss; these symptoms usually disappear when exposure is stopped (ASTDR)
    • Vapors irritate eyes and upper respiratory tract; cause dizziness, headache, anesthesia, respiratory arrest (NOAA)
    • Inhaling can irritate the nose and throat causing coughing and wheezing (NJ Fsheet)
    • People with central nervous system or liver diseases may be especially sensitive (HSDB)
    • Agency exposure limits:
  • CDC Acute Inhalation Risk Level at 4 Parts Per Million (PPM)
    • OSHA: 200ppm averaged over 8 hour work shift
    • NIOSH: 300ppm averaged over 10 shift (NJ Fsheet)
XYLENE

CS206 emission

70 lbs per year
  • Temporary memory loss, confusion, and laboratory evidence of liver injury have been reported in workers overexposed to xylene (HAZMAP)
  • Listed as a suspected cardiovascular, developmental, liver, immune system, kidney, respiratory, skin, reproductive, and immune system  toxin (EDF Goodguide)
  • Listed as a neurotoxin (EDF Goodguide)
  • People who breathe high levels may have dizziness, confusion, and a change in their sense of balance (ASTDR)
  • Exposure to high levels for short periods can also cause irritation of the skin, eyes, nose, and throat; difficulty in breathing; problems with the lungs; delayed reaction time; memory difficulties; stomach discomfort; and possibly changes in the liver and kidneys (ASTDR)
  • Inhalation can irritate the nose and throat causing coughing and wheezing (NJ Fsheet)
  • Exposure can cause headache, nausea and vomiting, dizziness, light-headedness and passing out (NJ Fsheet)
  • Repeated exposure can affect concentration, memory, vision, and muscle coordination (NJ Fsheet)
  • CDC Acute Inhalation Risk Level at 4 Parts Per Million (PPM)

 

12/22/2017 FERC Update – Notes from meeting with Transco, EPA and NJDEP

FERC issued an update regarding meeting with Transco along with Agencies EPA and NJDEP.

Click here to read the 12/22/2017 FERC Meeting note with Transco, EPA & NJDEP

Despite the Transco update, included below the meeting notes, does not address all of the stated FERC requirements, FERC has decided it will move forward with issuing the schedule soon for the DEIS.  FERC decided to decouple the General Conformity requirement from issuance of the DEIS.

What this means is that FERC does not want to bother waiting for details and specifications of the construction emissions in order to provide a more accurate environmental impact statement.  FERC is choosing to wing the DEIS instead of demanding more details from Transco.

Missing data for proposed Compressor 206

  • Emission details missing for meeting General Conformity requirements
  • No emissions data for added compressor at STA200
  • No analysis on CS206 Exhaust volume  & heat output for each 50′ smokestack
  • No evaluation of heat recovery system to reduce heat output
  • No validation of chemical emissions from CS206
  • No Health Impact analysis from chemical emissions
  • No 25 year chemical emission contamination projection and analysis for future reservoir site adjacent to proposed CS206

Included in Transco March 27 Application to FERC are the estimates that the proposed compressor will emit 29,580 lbs of Ammonia,  320 lbs of HCHO3, 44 lbs of Acetaldehyde, 6 lbs of Acrolein, 14 lbs of Benzene,  34 lbs of Ethylbenzene, 32 lbs of Propylene Oxide, 142 lbs of Toluene and 70 lbs of  Xylenes per year continually on a year over year basis.

These toxic chemicals have known impact on environment and human health.  Additionally, these are estimates from Transco with no independent validation from existing Transco Compressor stations that already have MARS 100 compressors such as STA 515, STA517 and STA520 (in PA).

What can you do today?  Send a note to EPA, NJDEP and FERC to let them know it is unacceptable to proceed with an environmental impact statement without the details and analysis to perform an accurate environmental impact statement.  Without this data and analysis, DEIS is not legitimate.  Need more information?  Contact stopftcompressor(at)yahoo(dot)com.

Our latest FERC Sample Submissions
– Compressor missing details
– Raritan Bay Missing details and analysis

 

Some Denied Permits: Hope Amid Chaos

Though there appear to be attempts in Washington D.C. to undo environmental protections and grant FERC more power through proposed legislation and actions of the EPA and Department of the Interior, there have been some encouraging developments in the courts and with state agencies that have supported protections of air and water quality.

 

FERC’S ANALYSIS OF GREENHOUSE GAS EMISSIONS WAS FOUND TO
BE INADEQUATE SINCE IT DID NOT CONSIDER EMISSIONS FROM THE PIPELINE TO THE END USE OF THE GAS

August 21, 2017 – Sierra Club v. FERC, Case No. 16-1329
A three-judge panel of the D.C. Circuit Court of Appeals ruled 2-1 that the Federal Energy Regulatory Commission had not properly analyzed the effects of burning natural gas on climate change before approving the pipeline. They ruled that FERC must consider a pipeline’s cumulative downstream greenhouse gas emissions from the combustion of the natural gas transported by the pipeline as part of its environmental review. This ruling vacated and remanded a 2016 Order by the Federal Energy Regulatory Commission that had authorized construction and operation of the Southeast Market Pipelines Project (Project) by granting Section 7 certificates to three natural gas pipelines in Alabama, Georgia and Florida that make up the Project :

  • Florida Southeast Connection, LLC (Florida Southeast Connection Project
  • Transcontinental Gas Pipe Line Company, LLC (Hillabee Expansion Project)
  • Sabal Trail Transmission, LLC (Sabal Trail Project)

Docket #s CP14-554-000, CP15-16-000, CP15-17-000

http://www.jdsupra.com/legalnews/ferc-failed-to-adequately-consider-29867/

 

NYSDEC DENIAL OF CONSTITUTION PIPELINE CWA PERMIT
WAS UPHELD BY THE SECOND CIRCUIT COURT

Constitution Pipeline (CP13-499) – NY State Department of Environmental Conservation’s Denial of Water Permit was upheld in court where, on August 18, 2017, the US Court of Appeals – 2nd Circuit concluded: “Insofar as the petition contends that the NYSDEC Decision is a nullity on the ground that it was untimely, the petition is dismissed for lack of jurisdiction; to the extent that the petition challenges the NYSDEC Decision on the merits, the petition is denied.” Note: FERC approved the Constitution Pipeline project in 2014.

https://www.pipelinelaw.com/2016/08/05/constitution-pipeline-cases-reflect-tension-in-states-roles-in-permitting-natural-gas-projects/
https://www.pipelinelaw.com/2017/08/31/second-circuit-upholds-state-veto-constitution-pipeline-project-via-denial-water-quality-certification/

 

NJDEP DENIED PENNEAST PIPELINE’S
CLEAN WATER ACT (CWA) PERMIT

6/28/17: Noting that the Clean Water Act (CWA 401 and 404) permit applications were very incomplete for PennEast, the NJDEP denied their applications for permits. PennEast (CP15-558) could not complete the surveys needed for their permit applications because over 65% of NJ’s landowners did not allow them onto their property. However, if PennEast receives a Certificate of Public Convenience and Necessity from FERC, they will then have the authority to gain access to properties for the surveying needed for these permits, and they will likely then reapply for the CWA 401 and 404 permits.

http://www.nj.com/mercer/index.ssf/2017/06/nj_dep_denies_permits_needed_for_penneast_pipeline.html

 

NJ’S RATE COUNCIL DECLARED THAT THERE IS NO NEED
FOR BUILDING THE PENNEAST PIPELINE
& THE REQUESTED RATE OF RETURN WAS EXCESSIVE

https://assets.documentcloud.org/documents/3106853/Comments-of-the-New-Jersey-Division-of-Rate.pdf
is in 9/12/16 in FERC Accession No. 20160912-6003(31683531)

 

NYSDEC DENIED A WATER PERMIT, BUT FERC DECIDED THAT NYSDEC “WAIVED” THEIR RIGHT TO ISSUE OR DENY A PERMIT SINCE THE DECISION WAS OVER A YEAR AFTER THE INITIAL APPLICATION

On 8/30/17, the NY State Department of Environmental Conservation conditionally denied Section 401 Water Quality Certification stream crossing permits for Millennium’s proposed 7.8 mile Valley Lateral pipeline project (C)P16-17). Then, at a 9/17/17 FERC hearing, it was “clarified” that the one-year period to review an application for the Water Quality Certificate started with “receipt” of application – not after determining it was “complete”.

http://www.bakerbotts.com/ideas/publications/2017/09/ferc-rules-that-new-york-state

 

WEST VIRGINIA REVOKES CWA 401 PERMIT IN WAKE OF HURRICANES HARVEY AND IRMA & WILL NOW REVIEW IT MORE THOROUGHLY UNDER WV’s STREAM ANTI-DEGRADATION POLICY

Sept. 7, 2017 – WVDEC revoked the Section 401 Water Quality Certification that they issued for the Mountain Valley Pipeline project (March 2017 & reaffirmed May 2017) one day before they would have needed to defend this in Court. (FERC Docket No. CP16-10). This came after a lawsuit by Appalachian Mountain Advocates on behalf of plaintiffs who argued the DEP’s analysis of the project’s effect on water quality in West Virginia was woefully incomplete.

http://www.huffingtonpost.com/entry/pipelines-bombshell-west-virginia-revokes-approval_us_59bb2c3ae4b06b71800c380c

October 10/11, 2017: 4th Circuit sent the WQ permit back to WVDEP for further review.

https://www.wvgazettemail.com/news/special_reports/marcellus/court-ruling-highlights-unanswered-questions-on-mountain-valley-pipeline/article_044cd2d7-83ce-5ab3-9567-00bb6e2b92fd.html

 

NORTH CAROLINA DEQ DELAYS DECISION ON
WATER QUALITY PERMIT

Sept. 14, 2017 – The North Carolina Department of Environmental Quality issued notice to the Atlantic Coast Pipeline that the project “involves numerous stream crossings that have the potential to affect downstream water quality both temporarily during construction and permanently.” (CP15-554) The department noted that “more site-specific detail is necessary to ensure that downstream water quality is protected.” The Governor delayed the Water Quality permit decision until December.

http://www.roanoke.com/news/virginia/north-carolina-environmental-agency-delays-decision-on-water-quality-permit/article_b3acc74b-2b20-5bcc-b89f-3233fe07d7d5.html

Northeast Supply Enhancement Project (NESE) Overview

Goal of Williams/Transco for the Northeast Supply Enhancement Project (NESE):

  • Deliver 400,000 dekatherms/day of natural gas to NYC
  • Williams/Transco already has a commitment from National Gas to buy this gas.

In Pennsylvania, they plan to add:

  • a 10-mile, 42-inch pipeline loop of Mainline D in Lancaster County, PA; and
  • a 21,902 horsepower electric-powered compressor unit at STA200, Chester County, PA (where there are already 13 compressor units)

Plans for New Jersey

Raritan Bay Loop Pipeline
Sayreville, NJ into Raritan Bay

Madison Loop Pipeline
Old Bridge & Sayreville, NJ
23.49-mile, 26-inch loop (0.16 mile onshore and 23.33 miles offshore) of Transco’s Lower New York Bay Lateral from Mile Post 12.00, southwest of the Morgan Meter & Regulator (M&R) Station in Sayreville, NJ to the Rockaway Transfer Point in New York State waters 3.43-mile, 26-inch loop of Transco’s Lower New York Bay Lateral from Compressor Station 207 at Mile Post 8.57 to Mile Post 12.00, southwest of the Morgan M&R Station

Compressor Station 206    Franklin Township (Somerset County)

new compressor station near Transco’s mainline,
consisting of two natural gas-powered turbine-driven compressor units
total horsepower: 32,000

Two 50-foot smokestacks where:

  • exhaust exits at 210,000 cubic feet per minute
  • exit temperature is 849.2 degrees Fahrenheit
  • Per Hour Release:  13 pounds of Carbon Monoxide

Williams/Transco:
Transcontinental Gas Pipe Line Co. LLC (Transco) is a wholly-owned subsidiary of Williams Partners Operating LLC, which is a subsidiary of Williams Partners L.P., which is a subsidiary of the Williams Companies, Inc.

 

Issues

  • The proposed compressor station would create air and noise problems that would affect Franklin Twp., South Brunswick, Montgomery & Princeton. Measurements of air quality are completed regionally and are averaged over time. Thus, monitoring of emissions in the air is not proposed to occur near the site, and measurement is not proposed to account for fluctuations where peak emissions are especially problematic. Additionally, all known carcinogenic emissions from compressor stations are not measured at nearby residences, places of workshop, etc.
  • Compressor stations pose serious health risks, especially for pregnant women, the elderly and the young, due to emissions that are planned, fugitive and accidental. Chemicals emitted from compressor stations include known carcinogens.
  • There is a history of catastrophic accidents at compressor stations and transmission pipelines, and an accident could result in deaths/injuries, destruction of property, limited potential for residents to evacuate, and devastation to the waterfront and waters of the Raritan Bay.
  • Increasing compression to transport natural gas through aging pipelines is a safety concern due to the increased velocity/heat of the moving gas and hastening of pipeline corrosion that could result in an explosion.
  • Though a segment of pipeline on Trap Rock Quarry property was replaces in the late 1980’s, there is no publicly available information about the age of the other pipeline associated with this project which, as far as it is known, were constructed in the 1950’s and 1960’s. Additionally, according to a Pipeline Safety Trust analysis of federal data, new pipelines are failing at a rate on par with gas transmission lines installed before the 1940s.
  • The NJ Buddhist Vihara & Medication Center borders the property where CS 206 is proposed. The noise, odor and emissions from the compressor station threaten their religious practice of walking meditation on trails which extend to the site of the compressor station. It is not known what effect the noise and pollution could have on their Buddha Statue which is the largest outdoor Buddha statue in the Western Hemisphere and a Cultural Landmark in Franklin Township.
  • Plans for construction of the compressor station and pipelines are near Superfund Sites.
  • There is not adequate water service in the area of the proposed compressor station to address potential accidents.
  • The habitat in/near the Bay would be disrupted during construction for marine mammals, fish, shellfish and horseshoe crabs that rely on it. Dangers of vessel strikes, accidental fluid releases, and disruption of the seafloor are concerns.
  • Sea mammals (Gray Seal, Harbor Seal, Harp Seal, North Atlantic Right Whale, Bottlenose Dolphin, Harbor Porpoise, & Short-Beaked Common Dolphin) are expected to be affected by exposure to seismic activity such that Williams/Transco will apply for an Incidental Harassment Authorization (IHA) to account for sound pressure from construction that has the potential to disturb a marine mammal or marine mammal stock in the wild by causing disruption of behavioral patterns, including, but not limited to, migration, breathing, nursing, breeding, feeding, or sheltering [Level B harassment].
  • Tourism and commercial fishing activities in the Raritan Bay area would be impacted by construction that is planned to occur for 9 months, 7 days a week, 24 hours a day (weather permitting).
  • For a project like this, there is no public vote; local ordinances can be ignored; and there is limited public input. The US Congress is working to increase the authority of FERC while lessening the rights of States to protect the public through their determinations about required air and water permits.

Learn more, read the information packet from the South Brunswick Informational Meeting held by Food and Water Watch.