ACTION ALERT – Two Virtual Ways to Help Wipe-Out NESE!

Your voice is needed NOW to help stop the Williams/Transco Northeast Supply Enhancement (NESE) Pipeline and Compressor Station! NJ Governor Murphy will decide whether to deny or approve NESE by June 5.  Please urge Governor Murphy to say “No” to NESE — the unnecessary, climate-altering, and dangerous methane gas project — and say “Yes” to a healthier future with cleaner air, land, and water by participating in these two events: 

Stop NESE Virtual NJ Rally 

Citizens of all ages are invited to join a virtual rally on May 18, at 1pm, via Zoom. While we cannot gather to rally in person, we can rally virtually!  Small signs are encouraged! 

 After registering your RSVP, you will receive further event details and a link to join the Zoom meeting. 


“Wave to Wipe-Out NESE”Facebook Event

2Citizens of all ages are invited to create and post expressions opposing NESE that are directed to NJ Governor Murphy. Post your submissions between May 18 at noon, through June 1 at noon, following the tips in the event page description. If you do not use Facebook, you can still participate in this event by sending your submissions to communications@cleanoceanaction.org.  

Please join or click “go” to the event here:

Together, we can help STOP NESE!

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

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.

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.  

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.

COMMENT 5: Other Concerns about In-Water Construction

  • Time of Year Restrictions
  • Thermal Discharges

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

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.

10/29/2019 Update

NJDEP did not issue their decision on the water permit applications on October 25, 2019 as was expected. 

Rather:

  1. Williams/Transco asked for a 30-day extension for a DEP decision on the Flood Hazard Area permit, and
  2. Williams/Transco withdrew their permit applications for Waterfront Development with Section 401 Water Quality Certification & Coastal Zone Management Consistency, and they submitted new applications three days later – October 28, 2019.

      The NJDEP does not have a 90-day decision deadline to adhere to for the Freshwater Wetlands permit application (i.e., There would be no consequences if they rendered a decision on this beyond 90 days after declaring the application to be complete for review.)

      THANK YOU!

      This is to recognize all the recent efforts to ensure that the NJDEP was aware of our concerns, issues with the applications, and recognition that the applications did not meet the stringent standards that the NJDEP was required to adhere to.  Prior to the NJDEP’s anticipated 10/25/19 decision on the June 12, 2019 applications:

      • Franklin Township Council passed a resolution urging the NJDEP to reject the June 2019 permits for the Northeast Supply Enhancement (NESE) Project at their 10/22/19 meeting.
      • Princeton Council passed a resolution urging the NJDEP to reject the June 2019 permits for the Northeast Supply Enhancement (NESE) Project at their 10/14/19 meeting.
      • Letters were sent to the Governor and NJDEP’s Commissioner McCabe from 33 elected officials and 32 organizations or their members urging the DEP to deny the permits for NESE on 10/18/19.
      • Nearly 6,000 people signed letters and/or online petitions/letters from New Jersey League of Conservation Voters, Sierra Club, Food and Water Watch, Clean Ocean Action, Central Jersey Environmental Defenders, and the Natural Resources Defense Council stating opposition to NESE and urging the DEP to deny the permits for NESE.  
      • Over 200 people called the Governor’s office to urge the DEP to deny the permits for NESE because they did not meet stringent regulatory standards
      • Many individuals sent individually-prepared comments to the NJDEP.
      • Franklin Twp. Manager sent extensive comments from the Franklin Township Task Force to the NJDEP and other officials in Trenton on 8/20/19 and 10/21/19.
      • Eastern Environmental Law Center and Princeton Hydro sent comments to the NJDEP on 8/2/19, 8/23/19, 10/21/19, and 10/24/19.
      • People rallied in Red Bank on 9/14/19 at an event organized by Clean Ocean Action.
      • And there were more actions …

      Some of the reasons cited for denying the permits were:

      1. Construction of the NESE Project threatens surface water quality, increased stormwater flooding, and threatened & endangered species and their habitats.
        • From construction in Raritan Bay –  
          • Unearthing toxics above levels acceptable in the regulations
          • Generating turbidity (clouding the water) that would interfere with designated use of the waters
        • From construction of the Madison Loop –
          • Digging in acid-producing soils would result in poor re-vegetation on steep slopes and could lead to excess runoff into wetlands (some of which are classified as “exceptional resource”).
        • From the design of the retention basin for Compressor Station 206 – 
          • This will not adequately address stormwater runoff.
          • NOTE:  Williams/Transco made similar errors that NJ DEP failed to detect and correct in the design and construction of a recent compressor station in Chesterfield Township (“Garden State Expansion” project).
      2. Construction of the Raritan Bay Loop, with its newly proposed shorter schedule, threatens the health of marine life, habitats, benthic and shellfish communities, and the economy of the region due to suspension and spreading of toxins from beneath the seafloor, noise from construction, and limited access to construction space in the Bay for commercial and recreational activities.
      3. Williams/Transco did not demonstrate that there are no practicable alternatives to avoid impacting exceptional resource value wetlands and their transition areas at the proposed CS206 site and Madison Loop.
      4. NJDEP explained that Williams/Transco did not demonstrate (1) that the proposed NESE Project serves an essential health or safety need of the municipality in which it is proposed; (2) that the proposed NESE Project serves existing needs of residents of the State; and (3) that there is no other means available to meet the established public need.
        • NESE does not meet the “public interest” criteria because: 
          • There is no “compelling public need” for it – It does not provide a public health or safety benefit, and, additionally, NY does not need this gas.  Rather, NESE:
            • threatens our air and water quality from methane and other toxic releases, 
            • negatively impacts the health of people and marine/wild life from Compressor Station 206 emissions & unearthed toxins from constructing in Raritan Bay,
            • poses safety risks (fires or explosions) from increased velocity of transporting natural gas through pipelines that are 50+ year old which will impact the rate of corrosion, and 
            • increases risks of flooding at the CS206 site from an inadequately designed retention basin.
        • It doesn’t preserve natural resources, and
          • There would be a negative impact on the shore economy by dredging up toxins from the floor of the Bay which would harm the health and safety of marine life and of Bayshore communities.
          • NOTE:  FERC’s 5/3/19 Certificate of Public Convenience & Necessity was not based on criteria NJDEP needs to use to determine public interest / compelling public need.
      5. The NESE Project’s greenhouse gas emissions and methane leaks would undercut the State’s goals to address impacts on Climate Change.  Based on the responses from the public and political leaders, there is growing support for these goals and opposition to NESE.
        • Approximately 6,000 people called the Governor and/or signed online petitions to the NJDEP and/or to Governor Murphy that included reasons for the NJDEP to deny the June 12, 2019 permit applications.  More comments were emailed or submitted in writing to the NJDEP during the comment period for this 3rd set of applications, but we do not know how many.
        • Governor Cuomo & Mayor DeBlasio, along with many other elected officials in NJ & NY, have voiced their opposition to the NESE Project.

      REMEMBER:  The NESE compressor station & pipeline can’t be built without permits from the NJDEP.

      STAY TUNED for plans for future actions.

Rally Against the NESE Project: By Land and Sea

Groups to Urge Governor Murphy to Stand Up for His Green Energy Agenda!

Saturday, September 14, 10:30am

Marine Park by the Pier, Red Bank, NJ

What:              Press conference and rally on the water and land urging Governor Murphy to deny the proposed Williams Transco Northeast Supply Enhancement Project (NESE) once and for all 

Who:               Concerned citizens and environmental, business and fishing groups, including: Central Jersey Environmental Defenders, Central Jersey Safe Energy Coalition, Clean Ocean Action, Environment New Jersey, Food and Water Watch, Indivisible Bayshore, J.T. White Clammers, Canyon Pass,  League of Women Voters of New Jersey, New Jersey League of Conservation Voters, Sierra Club, Surfrider Foundation, and Waterspirit

Where:            Marine Park by the Pier, Red Bank, NJ 07701

When:             Saturday, September 14, 2019 at 10:30am

Why:               Environmentalists, citizens and businesses are calling on Governor Murphy and the NJDEP to permanently deny the Williams NESE Project before the September 25th deadline.

Red Bank, NJ – As a critical deadline looms on the 3-year battle to stop the massive fracked natural gas project, Williams Transco Northeast Enhancement Supply (NESE), citizens are urged to attend a rally on the Navesink River to tell the Governor that the pending permits must be denied.  The NJDEP is obligated to make a final decision on the offshore pipeline section of the project by September 25, 2019, which put’s the Murphy Administration’s green energy agenda to the test.  Groups will urge that the decision be permanent, with no allowance to reapply.

NESE is the unnecessary, dirty, and environmentally destructive project designed to bring fracked natural gas from Pennsylvania to New York City.  The NJDEP denied permits this past June; however, the type of denial allowed Williams Transco to reapply, which they did. 

A coalition of environmental, fishing, business and community groups has united to fight the pipeline and is hosting a rally to urge Governor Murphy to deny the permits again, and this time to do so with provisions that prohibit reapplication.   The rally will be held by the pier at Marine Park in Red Bank from 10:30am – 12:00pm, and people of all ages are encouraged to attend and bring signs.   Immediately following the rally will be the celebration of the 44th Annual Clearwater Festival.

Cindy Zipf, Executive Director of Clean Ocean Action said,  “It’s imperative for citizens to attend this rally if they care about a healthy future.  While Governor Murphy has repeatedly promised a clean and green energy future for NJ, he needs to know we support that green vision and that his NJDEP must deny the permits.  There is nothing green about this project, in fact it is a lose, lose, lose for the Garden State, so saying no to this project is a no brainer.  We look forward to celebrating with the Governor once he sends Williams and Transco packing back to Oklahoma when his administration denies this project once and for all,” Zipf said.

“The Governor needs to do his job and stand for the environment and the people of New Jersey by denying this pipeline. We have told DEP time and time again that this is the wrong project in the wrong place. It is completely unnecessary and unneeded. The Northeast Supply Enhancement Project would cut through the already polluted and sensitive Raritan Bay and the New York Bay. This fossil fuel project would not only harm our fisheries and the ecology of the Bay but risk the safety and health of people too. Transco does not care about our safety, our clean air and water, they just want to put a dangerous compressor station and natural gas pipeline in our backyard and in our bay,” said Jeff Tittel, Director of the New Jersey Sierra Club. “DEP did their job in rejecting William Transco’s permits before, now it is their duty to reject them again.” 

“The Murphy Administration has a chance in the coming days to once again protect New Jerseyans from a dangerous source of air and water pollution and double down on its commitment to achieving a 100% clean energy future by permanently rejecting permits to the NESE project,” said Ed Potosnak, Executive Director of New Jersey League of Conservation Voters. “New Jersey has denied permits for NESE once. The Murphy administration should move to permanently reject the project and codify their strong decision made in June. I urge the public to join us on September 14th to show the governor we fully support his 100% clean energy goals and oppose NESE.”

State and local environmental organizations are not alone in their opposition to NESE. Numerous New Jersey residents have been actively opposing the project since it was first proposed. Dr. Barbara Cuthbert is a member of the Franklin Township Task Force, a group which formed three years ago to fight back and protect the communities which will be at risk from the proposed compressor station. “Governor Murphy and the DEP know that the NESE Project does not provide health or safety benefits to New Jerseyans. The laws and science, along with the clean energy goals of NJ, are on the side of NJDEP who should deny this third set of applications for good to protect our environment, health and safety from climate change impacts of fossil fuel extraction, transportation and combustion,” said Dr. Cuthbert.

Local community members along the Bayshore have expressed serious concerns over the impact the project will have on their communities and local economies. Despite the Bayshore region being on the front lines in terms of the impacts from the offshore pipeline, the DEP has failed to hold a public hearing on the project in the area. Elisabeth Eittreim, the head of Indivisible Bayshore explained that the organization, “firmly opposes the NESE Pipeline and urges our elected officials to protect our waterways before it is too late.”

Background:

NESE is an unnecessary, dirty, and environmentally destructive project designed to bring fracked natural/methane gas from Pennsylvania to New York City. To do so, Williams and their subsidiary Transco have sought permits to build both a massive new compressor station in Franklin Township and a 23.4-mile offshore pipeline through the Raritan Bay. The compressor station is being built next to an active quarry where blasting regularly occurs. Reports indicate that the compressor station will emit millions of tons of harmful pollutants annually into the air we breathe. Permits for these facilities are being evaluated separately by the NJDEP and a decision is expected in the fall. The nearly 24-mile pipeline, called the Raritan Loop, will rip Raritan Bay in half and continue all the way to the ocean spewing nearly a million tons of toxin muck and drilling mud into the waterways in which we swim and fish.  If approved, NESE will also rollback over 35 years of environmental progress for our waterways.  

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.

Keep sending comments to FERC

Send comments to FERC that request a “reset” for the DEIS by asking them to publish a revised/supplemental DEIS that addresses all new information and all concerns of the public. Tell FERC that the March 23, 2018 DEIS was missing critical information, dismissed comments of the public & elected officials, and lacked supportive studies or data for FERC’s conclusions. Additionally, Williams/Transco submitted thousands of pages of new information and reports that needs to be reviewed and analyzed in a document that FERC publishes during the time period when the public can truly provide meaningful comments. These submissions were in May and June 2018 – after the DEIS was published & after the end of the “official” time period for sending comments to FERC.

FERC claims that they consider ALL comments they receive. Many people need to let them know that the DEIS was not acceptable.

SEND COMMENTS TO FERC NOW, AND COPY NJDEP.

The DEIS was incomplete & misleading.  Tell FERC that you want a revised or supplemental DEIS and an additional comment period of at least 45 days.

When you send a comment to FERC, also forward that comment to the NJDEP –

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

You can also forward your comments to your elected officials and ask them to support the opposition to NESE.

10 days left to comment on NESE DEIS – Ends May 14, 2018

Excellent note from EELC today.  Excellent results from Princeton University team efforts, I love seeing the motions to intervene and comments cascading in my inbox.  Great news that Montgomery Township passed RESOLUTION #18-5-112 opposing CP17-101.  Now we need them to post it to FERC.

There are only 10 days including today.  Several communities have stated they will try to get comments in from their communities.  If anyone has questions or wants clarifications, send it out to the team (stopftcompressor [at] yahoo [dot] com) and you will receive a response.  Surfrider has great comment suggestions and our team has provided a few.  If you have not submitted comments and you are on this distribution list, please make those comments now.

Good attributes for comments:

  1. I oppose this project, I am a registered intervenor.
  2. How it directly impacts you – this will impact people in many different ways even people not in PA/NJ/NYC and that is completely legitimate.
  3. Highlight areas where FERC decided not to assess impact or completely missed.
  4. Identify areas where FERC acknowledges impact as rational that this is currently a Public Threat (not a public convenience) until FERC assesses and mitigates impacts.
  5. Reject the notion that this DEIS statement reflects an actual draft environmental impact statement.  It doesn’t.

Please also email NJDEP and ask why your elected officials have not sent comments after the DEIS.  This is also their critical time to take a stand to protect New Jersey.

10 days,
please make your voice count against
this imminent threat to our area.

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.  

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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

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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)