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Comments: Eastern System Upgrade Project Docket No. CP16-486-000

5/1/2017

As a general comment, Catskill Mountainkeeper objects to the Federal Energy Regulatory
Commission providing only an Environmental Assessment (EA) and not a full
Environmental Impact Statement for this project. This project is too large, with far reaching
impacts for people and the environment, to be limited to an EA, and an insufficient one at
that.

In the absence of that full information, we offer the following comments.

Section B.8.1 Air Quality

As summarized in the EA, Rockland County is in non-attainment (EA, p. 5) and at a
transmission compressor station using gas-driven compressors, the overwhelming
majority of operational emissions are criteria pollutants, particularly NOX and CO (EA, p.
132). With portions of the route of the proposed pipeline and infrastructure located in
areas of non-attainment and with all of the proposed pipeline and infrastructure likely to
emit criteria pollutants, the standard for both construction and operational phases of the
proposed project should be no increase in criteria pollutants, or alternatively, maximum
mitigation. The same standard no increase in criteria pollutants, is called for by the
recognition that the proposed project impacts communities deserving of protection on
grounds of Environmental Justice (EA, p. 5). Moreover, the need to justify the proposed
project on public benefit grounds creates a mandate to minimize public harms. Without
maximized mitigation, the expansion of the existing Hancock Compressor Station and the
construction of the new Highland Compressor Station, along with emissions from miles of
additional pipeline, on its face more than doubles the air impacts to the region of the
proposed project.
The observation in the EA, that modeling with the EPAs AERMOD program shows
that both the existing Hancock Compressor Station, with the proposed modifications, and
the proposed new Highland Compressor Station, combined with applicable background
pollutant levels, would not contribute to a violation of the NAAQS, (p. 132) sets a bar that
is too low, on several counts. First, mere compliance with NAAQS is not maximal mitigation.
Second, as detailed in the comments of the Madison County Department of Health
submitted to the FERC concerning the Dominion Transmission, Inc. project (Docket No.
CP14-497-000, October 15, 2014) [attached; hereinafter, MCDOH 2014], peak exposures,
rather than averaged long-term exposures, such as those captured by the NAAQS, are more
likely to impact relevant biological processes and therefore human and animal health (see
pp. 16-17). Since many studies now document the episodic, spiking character of emissions
from compressor stations, mitigations that address such emissions are required.
If FERC ignores the threats to the environment, water, land, air, and public health
and safety and capacity is expanded at Hancock and a new compressor station added at
Highland, during the operational phase, these facilities should be required to run with
electric-generated compression, rather than gas-fired compression. This would greatly
lower not only the emission of criteria pollutants, especially NOX and CO, but also reduce
the noise and possibly the vibration from these sources. Further, for the same reasons
(reduction in emissions, noise, and vibration), consideration should be given to requiring
that the proposed compressor stations and pipeline be serviced by electric-powered rather
than vehicles powered by fossil fuels, including gas, natural gas, and propane.
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Section B.8.1 Health risks associated with the project

As detailed in the comments of the MCDOH 2014, a growing body of evidence
documents the health hazards associated with residing in proximity to natural gas
infrastructure, and in particular, compressor stations and pipelines. A peer-reviewed
article, Investigating Links Between Shale Gas Development And Health Impacts Through
A Community Survey Project In Pennsylvania (2014) [PA Study 2014], explicitly addresses
health impacts from compressors and finds that proximity to gas wells, compressor
stations, or impoundment pits correlates with increases in reported health symptoms,
particularly in children. The symptoms that are reported are consistent with exposures to
chemicals known to be found in transmitted natural gas and include but are not limited to
headache, throat irritation, nosebleeds, sinus problems, shortness of breath, and fatigue.
Such symptoms are debilitating and costly in and of themselves, but may also point toward
more serious longer-term illnesses that can result from intense or chronic exposures to
chemicals known to be or suspected to be emitted from natural gas infrastructure. Similar
findings have been reported by Wilma Subra [Subra 2009], Earthworks [Earthworks 2012],
Bamberger & Oswald [Bamberger & Oswald 2012], Southwest Pennsylvania Environmental
Health Project [SWPA-EHP 2013], Coming Clean [Coming Clean 2014], and the Agency for
Toxic Substances and Disease Registry of the United States Department of Health and
Human Services [ATSDR 2016].
The ATSDR has concluded that sensitive subpopulations, such as patients with
asthma and elderly individuals, may experience harmful effects from exposures to
hydrogen sulfide and PM2.5 and that some individuals may also be sensitive to aldehyde
exposures, including glutaraldehyde (ATSDR, p. ii). In addition, in a study conducted by
ATSDR of the Brigich Compressor Station in Washington County, PA, Nine (9) chemicals
were detected that exceeded health-based comparison values (ATSDR, p. ii), although
none of the known carcinogenic compounds were found at levels that exceed the EPAs
target risk range for estimated excess lifetime cancer risks. The ATSDR study documented a
4-month average for Particulate Matter (PM2.5) of 12.4 g/m, which exceeds the annual
mean concentration associated with health effects (11-15 g/m), according to the World
Health Organization (WHO 2006).
In addition, Catskill Mountainkeeper has conducted air quality monitoring at the
Hancock Compressor Station, both prior to and following its coming on line in 2014. We
sampled air quality at baseline, during an announced blowdown event prior to the
compressor station coming into service, and for several months following the compressor
station entering its operational phase. Our data, not yet published, document that air
quality at baseline was pristine, while air contaminants were emitted during the blowdown
event (including benzene, acetone, 2-propanol, and various other lightweight volatile
hydrocarbons) and following the onset of operation of the compressor station (including
benzene, toluene, acetone, ethyl acetate, acetaldehyde, carbon tetrachloride, and various
lightweight volatile hydrocarbons) in line with previously reported emissions from
compressor stations and pipelines. The levels of benzene documented three months
following initiation of operations at the compressor station at sites that are 185 meters and
245 meters from the compressor station valve were 4.38 times higher than the US
Environmental Protection Agencys reference concentration (RfC) 1:1,000,000 risk for
cancer (Catskill Mountainkeeper, unpublished data).
The findings from Catskill Mountainkeepers study are validated by published
reports of methane emissions in Hancock, NY, obtained prior to the operation of the
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Hancock Compressor Station [see Payne & Ackley 2014] and following the start of
operations [see Payne & Ackley 2014 Addenda]. While release of toxic contaminants does
not universally follow leakage and emission patterns observed for methane from pipelines
and compressor stations, existing data suggest that where methane is emitted, other
contaminants will be emitted, as well.
A physician on Catskill Mountainkeepers staff - Kathleen Nolan, MD, MSL - has also
consulted with clinicians caring for patients who have symptoms believed by the patients
to be related to exposures from compressor stations. In many of these cases, patients were
able to obtain relief by temporarily or permanently moving away from their residences,
strongly suggesting a cause-and-effect relationship between the exposure and their clinical
illnesses. In one case, two children had severe symptoms (seizures and behavioral changes)
reported by the patients family to be related to compressor station emissions that they
were able to smell and sometimes to see in the air near and in their home. The family
reported a substantial level of improvement in all symptoms following their use of a high-
level, HEPA (high-efficiency particulate air) filter in their home, again suggesting a cause-
and-effect relationship between the childrens symptoms and contaminants in and
removable from the air.
The Environmental Assessment for the Eastern System Upgrade Project prepared by
the FERC [EA] claims, without supporting documentation, that The majority of the
reports/studies that were referenced by commenters [sic] are based on natural gas
production facilities that transport and process raw field gas, which typically contains more
pollutants than transmission-quality natural gas. Therefore, we do not find the referenced
studies applicable for relating health impacts from operation of the Highland and Hancock
Compressor Stations. While transmission-quality natural gas (with components similar to
so-called dry gas) may have fewer pollutants than raw field gas (with components similar
to so-called wet gas), transmission-quality natural gas may, nonetheless, contain
substantial amounts of various pollutants, including carcinogens and other toxins, as
Catskill Mountainkeepers study at the Hancock site demonstrates. Moreover, other
contaminants may be as or more important for health impacts than those contained in the
transmitted natural gas itself. In research prepared for the EPA, Michael Pring observed
that the most significant emissions from compressors stations are usually from
combustion at the compressor engines or turbines [Pring 2015], a finding that accords
with the EAs assessment: At a transmission compressor station using gas-driven
compressors, the overwhelming majority of operational emissions are criteria pollutants,
particularly NOX and CO. (EA, p. 132) In the absence of supporting documentation, we
reject the claim that all of the available studies reporting adverse health impacts related to
compressor stations are limited to sites transporting raw field gas, and further, we reject
the claim that such studies, even if limited to sites transporting raw field gas, would lack
relevance to the operation of the Highland and Hancock Compressor Stations.
We also explicitly reject the EAs claim that the EPAs criteria standards are
protective of human health (EA, p. 132). The EPAs criteria standards relate to region-
wide air quality and are not intended to serve as indicators of acceptable levels of exposure
at the individual or community level. Due to the known pattern of episodic and spiking
emissions from compressor stations, new and more protective standards need to be
identified for this type of application. Pending the development of such standards, the FERC
must insure through other mechanisms, such as denial of permits if adverse health impacts
cannot be avoided, optimal siting of facilities and pipelines, best management practices to
minimize or eliminate planned and accidental emissions, and innovative approaches, such
as limiting the use of combustion engines at compressor stations and monitoring for and
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removing air pollutants, such as fine particulate matter, which can itself adversely affect
health and which likely exacerbates exposures to volatile organic compounds (see Brown
2014).
Finally, we find no consideration in the EA of the potential harmful effects of radon
and its decay progeny. Since radon can occur with natural gas derived from the Marcellus
Shale, consideration of its levels and impacts is crucial not only for its potential harmful
impacts on the environment and wildlife but also for workers who handle the pipelines and
work in the compressor stations and potentially for nearby residents. Levels of radon and
its decay progeny should be measured in the gases transported through these proposed
facilities and especially in the scalings, where radioactive compounds may accumulate; on
the pigs used for maintenance and cleaning of such scalings; and in all waste derived from
such maintenance. The EA should address appropriate interventions to prevent exposure
to elevated levels of radon and its decay progeny.
The EA does address noise impacts but does not address potential environmental
and health impacts related to vibration or the possibility that using electrically powered
compressors rather than gas-fired compressors might mitigate either noise or vibration or
both.
We have outlined proper mitigations processes below. It must be noted, however,
that we do not believe mitigation is sufficient. We believe, with scientific and medical
support, that the expansion and building of these two compressor stations will do
significant damage to the public health and environment surrounding them and beyond.
Given that we do not expect FERC to protect the communities and the environment by
blocking this expansion, we provide mitigation measures that are the least we feel is
possible to do to minimize damage. To mitigate for potential air contamination and
possible adverse health impacts, we agree that a Health Impact Analysis, including baseline
assessments, should be conducted. In the absence of clear findings from such a study and in
the face of a likely decision by the FERC to permit the proposed project, we recommend the
following interventions to address unresolved concerns related to potentially harmful air
emissions:

1. Require electrically powered compressor engines at both Hancock and Highland;
require capture of all planned emissions, such as those produced during blowdowns;
require compliance with best management practices to reduce leaks and accidental
emissions to the lowest levels possible;
2. Conduct regular and frequent monitoring of emissions via Infrared Radiation
cameras or similar equipment;
3. Conduct air sampling (both 24-hour sampling and intermittent grab sampling)
for potential contaminates, especially at sites of increased methane emission;
4. Offer free baseline health assessments to anyone residing within three (3) miles
of the projects or working or going to school for more than 4 hours per day at sites within
three (3) miles of the projects;
5. Offer free monitoring for fine particulate matter with a Speck monitor or similar
equipment to all residents within three (3) miles of the sites and anyone exposed for more
than four (4) hours per day at work or school sites within three (3) miles of the sites or at
sites documented to have substantial methane emissions;
6. Offer free installation of HEPA and carbon filters as recommended to reduce
exposures to fine particulate matter and volatile organic compounds to all individuals
residing within three (3) miles of the projects;
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7. Provide free health assessments with an independent environmental health

specialist or toxicologist for anyone residing within three (3) miles of the projects or
experiencing prolonged exposure at sites within three (3) miles of the projects who
develops symptoms consistent with those previously reported for people residing near
natural gas infrastructure;
8. Conduct regular monitoring of radon levels in transmitted gases;
9. Conduct regular monitoring for radioactive decay products in scalings, pigging
equipment, and all waste.


Section B.3 Vegetation and wildlife

The EA describes that vegetation will revert to its pre-disturbance state, yet existing
literature documents that well-pad sites generally do not recover even decades after
remediation. This is especially troubling in the setting of a proposed project that impacts a
large amount of land available for, or currently in, agricultural use. Such sites should be
avoided or the remediation methods and their efficacy thoroughly documented.


Section B.4 Threatened and endangered species

The EA describes and addresses consequences to endangered, threatened, and
otherwise protected species primarily in terms of the construction phase of the potential
project and does not address concerns, such as air emissions and exposure to radiation,
that are more relevant to the operational phase. Some of the proposed mitigations, such as
preserving sunny, rocky areas for rattlesnakes and seasonal timing for tree-cutting to avoid
impacts on bats and eagles, are irrelevant to avoid operational exposures or may even be
potentially harmful, if wildlife is drawn into an area of potential contamination. Such areas
should not be created unless monitoring is put into place to insure absence of exposure to
potential air pollutants.


REFERENCES

[Bamberger & Oswald 2012] Bamberger M & Oswald RE. Impacts of gas drilling on human
and animal health. New Solutions 2012, 22 (1)

[Brown 2014] Brown D, et al. Understanding exposure from natural gas drilling puts
current air standards to the test. Reviews on Environmental Health. 2014: 29, 4
DOI: https://doi.org/10.1515/reveh-2014-0002

[Catskill Mountainkeeper]: Toxic air emissions during a compressor station blowdown at
Hancock NY. unpublished data; contact Kathleen Nolan, MD, MSL (845-417-6489)

[Coming Clean 2014] Macey G, et al., Air concentrations of volatile compounds near oil and
gas production: A community-based exploratory study. Environmental Health 2014 13:82
DOI: 10.1186/1476-069X-13-82

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[Earthworks 2012]: Earthworks, Gas Patch Roulette, October 2012,

http://www.earthworksaction.org/library/detail/gas_patch_roulette_full_report#.Uc3
MAm11CVo

FERC. Eastern System Upgrade Project: Environmental Assessment (Docket No. CP16-486-
000). March 2017

[MCDOH 2014]: Comments of the Madison County Department of Health (Madison NY)
submitted to the FERC concerning the Dominion Transmission, Inc. project (Docket No.
CP14-497-000, October 15, 2014)

[PA Study 2013]: Steinzor, N W. Subra and L Sumi. Investigating Links between Shale Gas
Development and Health Impacts Through a Community Survey Project in Pennsylvania.
New Solutions: A Journal Of Environmental And Occupational Health Policy Vol 23:55-83.
2013


[Payne & Ackley 2014] Payne BF, Ackley R. Baseline Methane Emissions in Town of
Hancock, Delaware County, New York. (September 2014) Accessed 5/1/2017 at
http://www.damascuscitizensforsustainability.org/wp-
content/uploads/2014/12/Hancock4.pdf


[Payne & Ackley 2014 Addenda] Payne BF, Ackley R. Addenda to Baseline Methane
Emissions in Town of Hancock, Delaware County, New York. (September 2014) Accessed
5/1/2017 at
http://www.damascuscitizensforsustainability.org/wp-
content/uploads/2014/12/Compressor-236 Addenda-to-Hancock-Report.pdf

Pring M and Wilhemi J. Fort Worth Natural Gas Air Quality Study. Conference summary.
https://www3.epa.gov/ttnchie1/conference/ei20/session6/mpring.pdf

[Subra 2009] Wilma Subra, Results of Health Survey of Current and Former DISH/Clark,
Texas Residents December 2009. Earthworks Oil and Gas Accountability Project,
http://www.earthworksaction.org/files/publications/DishTXHealthSurvey_FINAL_hi.pdf

[SWPA-EHP 2013] Southwest Pennsylvania Environmental Health Project. EHPs Latest
Findings Regarding Health Data. http://www.environmentalhealthproject.org/wp-
content/uploads/2013/09/6.13.13-general.pdf







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