Gas Pipeline Transco 2800 Post Oak Blvd.

Houston, Texas 77056

July 9, 2012 Ms. Kimberly D. Bose, Secretary Federal Energy Regulatory Commission 888 First Street, N.E. Washington, D.C. 20426 Re: Transcontinental Gas Pipe Line Company, LLC (Transco) Rockaway Delivery Lateral Project PF09-8 Response to Scoping Issues

Dear Ladies and Gentlemen, On May 25, 2012, the Federal Energy Regulatory Commission (FERC) issued a Notice of Intent (NOI) to prepare an environmental impact statement for the proposed Rockaway Delivery Lateral Project. This NOI also contained a request for comments on environmental issues and notice of public scoping meetings. The formal scoping period closed on June 25, 2012. The attached table provides Transcos response to the issues raised during the public scoping period. Those issues not resolved in the attached table will be further addressed in Transcos Draft Resource Reports or when Transco files its formal 7(c) application. Any technical questions regarding this filing should be directed to Roberta Zwier at (973) 839-2410 or roberta.zwier@williams.com. Sincerely,

Tim Powell Manager, Natural Resources cc: Kara Harris, Commission Staff

Response to Scoping Issues Raised During the May 25-June 25, 2012 FERC Scoping Period Rockaway Lateral Delivery Project FERC Docket PF09-8
The Federal Energy Regulatory Commission (FERC) issued a Notice of Intent (NOI) to prepare an Environmental Impact Statement (EIS) for Transcos Rockaway Delivery Lateral Project (Project) on May 25, 2012. In addition to accepting written comments, FERC conducted formal public scoping meetings on June 12 and June 13, 2012. The following table identifies the scoping issues raised to date and provides Transcos response. Transcos response addresses comments submitted and uploaded on the FERC E-library through Friday June 29, 2012. As additional relevant comments are submitted after June 29, 2012, Transco will work with FERC staff to ensure that issues are addressed throughout the NEPA process.

Issue Expand Discussion of Purpose and Need for Project including a Quantification of Energy Demand in the Region.

Response Transco is in the process of updating the first draft of Resource Report 1, which will include an expanded discussion of purpose and need in order to address this comment as well as questions raised by FERC Staff in their Comments to the Initial Drafts of Resource Reports 1 and 10 issued on May 10, 2012. The expanded discussion will be included in the next draft of Resource Report 1, which Transco expects to file in August 2012. Transcos Rockaway Delivery Lateral is supported by customer demand and is not designed to provide natural gas from any particular source. National Grid is responsible for sourcing natural gas supplies to meet this demand. New York Citys PlanNYC (the Plan) contains an initiative for increasing natural gas transmission to improve reliability and encourage conversion from highly polluting fuels (New York City, 2011). The Plan goes on to identify Rockaway Delivery Lateral Project as way to ease supply constraints and reinforce gas supplies in Brooklyn and Queens (New York City, 2011). The increased use of natural gas in residences in New York City resulting from the Project and other sources will improve air quality by replacing the systems that use fuel oil to heat residences. Poor air quality directly contributes to health risks and mortality on a greater scale than any alleged risks posed by radon.

Source/Supply of Natural Gas

Radon Content in Natural Gas

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Response The half-life of radon is 3.8 days (Appleton, 2007). Furthermore, radon concentrations in natural gas are reduced when the gas undergoes upstream processing. An estimated 30-75% of radon can be removed from natural gas by processing (Johnson et al. 1973). Other research suggests that the cumulative decay of radon from wellhead to burner tip (due to processing and the short half-life) is approximately 60% (Gogolak 1980). Both studies conclude that indoor radon concentrations resulting from the use of natural gas in the home are unlikely to pose a radiological hazard to domestic users. Due to safety regulations and technology improvements, the percentage of unvented stoves and space heaters is significantly less today than it was in 1973 when Johnson et al. conducted their study, which could lower the potential exposure to radon associated with natural gas combustion. Van Netten et al. (1998) found that the radon exposure to domestic users in U.S. and British Columbia households was virtually nonexistent. More recently, Dixon (2001) found that individual exposure to radon associated with domestic gas use is small, and radon is not likely to be of concern to suppliers or customers due to the small quantity that is released into buildings from burning natural gas. Gas in the Projects pipeline will be mixed with that of supplies from around the country, diluting the radon concentration, as other regions have lower natural radon concentrations in their gas. The actual source composition of the gas that will be delivered to end users in New York City is not known, and there is no way to determine what proportion, if any, will have been produced in the Appalachian region of the northeast. All humans are exposed to radon, and the risks associated with different levels of exposure are expected to be minor but are largely unknown. In addition, the amount of radon that will be present in natural gas delivered to New York City by the Project is also unknown; however, the benefits from the reduced carbon dioxide output and improvements in air quality that will result from an overall increase of natural gas use in New York City will likely outweigh the potential risks associated with radon exposure resulting from in-home natural gas use.

Sediment Dispersion Modeling to Clarify Severity of Potential Offshore Impact Effects on Fish and Wildlife, including Wetland Habitat

Transco is currently conducting sediment transport modeling in coordination with feedback received from resource agencies and comments received from the public. The results of this modeling will be provided when complete. There will be no wetland impacts associated with the Project. By proposing a directional drill from onshore to offshore, the project is designed to avoid nearshore habitats. Transco is currently coordinating with New York State Department of Environmental Conservation (NYSDEC), NOAA Fisheries and other resource agencies to determine the potential effect on fish and wildlife species of concern, particularly threatened and endangered species. Additional information on potential

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Response impacts to fish and wildlife, including wetlands, will be included in Transcos draft Resource Reports, which will be filed with FERC in August 2012.

Consider Remote Operated Vehicle (ROV) Deployment for Entire Preferred Route

Offshore surveys including drop camera and diver video were conducted in 2009 and 2010 following consultation with NYSDEC and other resource agencies. Prior to completion of these surveys, a work plan was reviewed and approved by NYSDEC. Specific emphasis was placed on capturing video of the artificial debris that was deposited to characterize the existing habitat. To date, the NYSDEC has accepted data provided by Transco and there are no plans for additional surveys. Transco is currently coordinating with NYSDEC and other resource agencies and based on the outcome of agency consultations and permitting will perform mitigation as required. Transco will operate as a business in the community and will establish relationships with other business owners. Transco has reviewed maps produced by the New York State Department of Environmental Conservation, Office of Environmental Justice, and has discussed this issue with the NYSDEC. Because the project facilities are proposed solely within the limits of GNRA and property owned by the Triborough Bridge and Tunnel Authority, they are not depicted as potential Environmental Justice areas. In addition, no areas on the Rockaway Peninsula in proximity to the proposed project area are mapped as potential Environmental Justice areas. Transco will continue to coordinate with NPS on any potential impacts to park users and NPS property, specifically regarding the use of park facilities for non-recreational uses. Transco is working closely with the NPS and GNRA staff. The intent is for the project to benefit to GNRA and Transco. Information relative to these issues will be incorporated into the Transcos Draft Resource Reports, which will be filed with FERC in August 2012. Transco continues to coordinate with NPS on any potential impacts to land use, park users and NPS property. This information will be incorporated into the Transcos Draft Resource Reports, which will be filed in August 2012. Customer demand for the Rockaway Delivery Lateral Project is consistent with increased natural gas demand in New York City. A significant portion of the increased need is the result of residential customers converting from oil to natural gas, which has environmental benefits. The increased use of natural gas in residences in New York City resulting from the Project and other sources will improve air quality by replacing the systems that use fuel oil to heat residences. Potential emissions from the M&R Facility will be evaluated to determine if they are above reporting/permitting thresholds. The results of this evaluation will be included in the FERC 7(c)

Consider Mitigation in Jamaica Bay for Offshore Impacts Effects on Local Businesses Environmental Justice Analysis

Potential Project Conflict with Gateway Management Plan as Industrial or NonRecreational Use

Land Use Impacts to GNRA

Vapor/Greenhouse Gas Emissions and respect to GNRA Climate Friendly Park Action Plan and Green Parks Plan released in April 2012.

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Response application for the Project. The design for the proposed M&R Facility is subject to a design review process and approval by the NPS. It is Transcos understanding that requirements under the Climate Friendly Parks Action Plan and the Green Parks Plan are incorporated into the NPSs Sustainability Checklist for Building Projects. This checklist will be evaluated by the NPS as part of the design review for the Project.

General Conformity Analysis for Non-Attainment Area Noise and Vibration from M&R Facility

Transco is conducting a General Conformity Analysis which will be submitted as part of the FERC 7(c) application. Transco has performed pre-construction noise surveys to determine baseline noise levels at the M&R Facility. These levels combined with information about the equipment proposed for operation at the proposed M&R Facility will be used to predict the noise and vibration levels that may be generated from operation of the M&R Facility. Transco is also preparing an analysis of construction-related noise associated with onshore horizontal direction drill operations and offshore construction activities which will be presented as part of the FERC application

Enhance Alternative M&R Facility Site Analysis

From 2008 to 2010, Transco worked to identify potential sites for the M&R Facility. Transco engaged numerous agencies and other stakeholders throughout the process to ensure that all reasonable alternatives were identified and addressed. Sites considered included private and public lands. A complete discussion of the alternatives will be included with Transcos Draft Resource Reports, which will be filed with FERC in August 2012. Transco has not identified any set of energy alternatives that would satisfy all the goals of the Project based on the short-term and long-term demand for natural gas projected by National Grid. The Rockaway Delivery Lateral project is being designed and will be maintained in accordance with Federal pipeline safety regulations pursuant to 49 CFR Part 192. Transco also has a Public Awareness and Damage Prevention Program, which calls for communication with emergency responders on an annual basis. Information pertaining to this program will be provided to the National Park Service and the U.S. Park Police for incorporation into the National Park Services emergency management plan for Floyd Bennett Field. Emergency response plans will be approved and in place in advance of Transcos construction and operation of the facility and provide information and data as required.

Enhance Analysis of Alternative Energy Sources Pipeline and M&R Facility Safety and Security

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Response Safety Transcos integrity management program focuses first and foremost on prevention followed by detection and mitigation. Integrity management programs cover the life cycle of the pipeline. Design, manufacturing, construction and commissioning standards provide integrity on the front end of the life cycle. Operations and Maintenance (O&M) policies, procedures, and integrity management are used to manage the integrity of the assets throughout the life of the pipeline. The following provides an overview of the types of design, operations and maintenance standards Transco uses to help ensure the safety and reliability of its facilities: At steel rolling mills, where pipe is fabricated, pipeline representatives inspect the pipe to ensure that quality meets or exceeds both federal and industry-wide standards. Protective coatings and other corrosion control techniques are used to help prevent corrosion of the pipeline. During construction, pipeline representatives inspect the fabrication and construction of the pipeline. Welds linking the joints of the pipeline are checked to test their integrity. Once the pipeline is in the ground and before it is placed into service, it is pressure-tested with water in excess of its operating pressure to verify that it can withstand high pressure. After the pipeline is placed in service, company maintenance crews perform facility inspections, check for construction activity in the vicinity of the pipeline, and maintain the pipelines and their rights of way. Heavily populated areas are inspected and patrolled more frequently. Pipelines undergo periodic maintenance inspections, including leak surveys and valve and safety device inspections. An internal computerized inspection device known as a smart pig is also utilized to periodically examine the pipes condition. The Transco pipeline is continuously monitored 24 hours a day, 365 days a year through its Gas Control center in Houston. The project facilities will have redundancy in the number of remotely operated valves that will be monitored 24 hours a day/7 days a week from Houston for Transco and from Hicksville for National Grid. This will allow for an immediate response and closure of the system from either party in an upset condition. No special firefighting apparatus is required to fight a high pressure natural gas fire. The most effective and immediate way to begin to address such a fire is to shut off the gas source. Valves

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Response located along the pipeline can be used to isolate the M&R station as well as segments of pipeline. Security The physical security measures being considered for the facility include vehicle barriers, door locking hardware and strict key controls, intrusion detection systems, closed circuit television systems, remote monitoring of cameras and security alarms, and exterior lighting.

Ensure All Interested Parties are Being Notified

Transco maintains an extensive stakeholder database and will continue to engage with groups that request meetings and that could potentially be affected by the project. Stakeholders in the database have been notified via email and phone of events such as community board meetings and open houses to encourage attendance and participation. If additional stakeholders would like to be added to the mailing list, they may contact Williams at 866-455-9103 or PipelineExpansion@williams.com. Transco will develop a cumulative impact analysis as the proposed construction method is finalized and following further consultation with NPS, NYSDEC and other relevant resource agencies. This analysis will be included as part of the FERC 7(c) application for the Project.

Evaluation of Cumulative, Indirect and Secondary Impacts including National Grid BQI Project.

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References Appleton, J.D. 2007. Radon: Sources, Health Risks, and Hazard Mapping. AMBIO: A Journal of the Human Environment 36(1):85-89. Dixon, D.W., 2001. Radon exposures from the use of natural gas in buildings. Radiat. Protect. Dosim. 97 (3), 259-264. Johnson, R., D. Bernhardt, N. Nelson, and H. Calley. 1973. Assessment of Potential Radiological Health Effects from Radon in Natural Gas. Prepared for the U.S. Environmental Protection Agency, Office of Radiation Programs as EPA-520/1-83-004. Washington, DC. Kargbo, D.M., R.G. Wilhelm, and D.J. Campbell. 2010. Natural Gas Plays in the Marcellus Shale: Challenges and Potential Opportunities. Environmental Science and Technology 44:5679-5684. New York City. 2011. PlaNYC. April 2011. 202 pages. Available at: http://www.nyc.gov/html/planyc2030/html/theplan/the-plan.shtml. Accessed on July 2, 2012. Van Netten, C., K. Kan, J. Anderson, and D. Morley. 1998. Radon-222 and Gamma Ray Levels Associated with the Collection, Processing, Transmission, and Utilization of Natural Gas. American Industrial Hygiene Association Journal, Vol. 59 (9), p.622-8.