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)
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| 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)
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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)
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| ETHYLBENZENE
CS206 emission
34 lbs per year
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- 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)
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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)
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| 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)
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RISKS OF CHEMICALS THAT WILL BE EMITTED FROM THE PROPOSED COMPRESSOR STATION 206
| TOLUENE
CS206 emission
142 lbs per year |
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- 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)
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- OSHA: 200ppm averaged over 8 hour work shift
- NIOSH: 300ppm averaged over 10 shift (NJ Fsheet)
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| 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)
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