The Honorable Andrew M. Cuomo Governor of State NYS State Capitol Building Albany, NY 12224 Joseph Martens, Commissioner Dr. Howard Zucker, Acting Commissioner NYS Department of Conservation NYS Department of Health 625 Broadway Corning Tower, Empire State Plaza Albany, NY 12233-1011 Albany, NY 12237

March 24, 2015

RE: Brookman Corners Compressor Station

Dear Governor Cuomo, DEC Commissioner Martens, and DOH Acting Commissioner Zucker: Otsego 2000 is extremely concerned with plans by Dominion Transmission Inc. (DTI) to expand its Brookman Corners compressor station in Montgomery County, which would expose families and children in the vicinity to high levels of pollutants dangerous to human health. (FERC Docket #CP14-497-000) Please see the attached information that we provided to NYS-DEC project manager, Chris Hogan, in a meeting with him and his staff on March 19, 2015. During that meeting we discussed errors and misrepresentations by DTI, including erroneous air dispersion modeling which neglects impacts to the Otsquago Valley and village of Fort Plain. However we also recommended several design and development improvements, described herein, that could significantly reduce those emission levels and other impacts to the valley, including Otsquago Creek. Otsego 2000 maintains that this relevant and factual information should be reviewed before agencies consider air and water resource permits for this project. Respectfully, our objective is to encourage dialogue and avoid circumstances that often result in litigation, resentment of industry, and disillusion with government agencies entrusted to protect the public. Our organization seeks to achieve positive solutions whenever possible, so we urge your active support and involvement to facilitate a better outcome in these proceedings. Thank you.

Nicole Dillingham President, Otsego 2000

Post Office Box 1130, Cooperstown, NY 13326  Tel: 607 547 8881  Fax: 607 547 6195  www.otsego2000.org

March 19, 2015

Chris Hogan NYSDEC Division of Environmental Permits 625 Broadway, 4th Floor Albany, New York 12233

RE: Pollutant Reduction Techniques Applicable to the Brookman Corners Compressor Station Expansion (Dominion New Market Project CP14-497-000)

Dear Mr. Hogan,

Please accept the following from Otsego 2000 regarding the Air State Facility Application for the Brookman Corners compressor station, proposed for expansion by Dominion Transmission Inc. As we have expressed to FERC, our chief concern is the very high level of pollutants dangerous to human health that are projected for this compressor station which Dominion wants to enlarge in our region as part of its “New Market Project.” Independent research involving air quality sampling has documented the exposure of communities in other areas to harmful airborne chemicals around compressor stations that far exceed EPA recognized levels of safety for cancer.1 Furthermore, people living near compressor stations that were designed to produce pollutant levels much lower than specified in the Brookman Corners application are now experience odors events and health problems. This, along with the unique circumstances affected the geography of the Mohawk Valley and particulars of the proposed project, give us serious cause for concern.

Recognizing the acute adverse impacts that this part of the Mohawk Valley could experience as the result of Dominion’s expansion at Brookman Corners, we are presently coordinating with research groups to pursue human health and animal studies that will document effects surrounding the compressor station in the months and years ahead, regardless of what is approved. Clearly, however, our greatest wish is to limit harmful impacts up front, which is why we offer the following.

1 Macey, et al.; Air Concentrations of Volatile Compounds Near Oil and Gas Production: A Community-Based Exploratory Study. Environmental Health http://comingcleaninc.org/assets/media/images/Reports/Env_Health_air_quality_unconvetional_oil_gas.pdf See also Breech, et al.; Warning Signs: Toxic Air Pollution Identified at Oil and Gas Development Sites—Results from Community Air Monitoring Reveal Chemicals Linked to Health Hazards. Coming Clean and Global Community Monitor, October 2014. http://comingcleaninc.org/assets/media/images/Reports/Warning%20Signs%20Report.pdf

Post Office Box 1130, Cooperstown, NY 13326  Tel: 607 547 8881 Fax: 607 547 6195  www.otsego2000.org Discussed here are several design alternatives, modifications, and improvements to the currently proposed project which could significantly reduce overall emissions and especially the level of hazardous pollutants to which the surrounding community will be exposed. In the interest of protecting air quality and human health, we urge DEC to consider these solutions and require that Dominion make meaningful changes to its design accordingly. Brookman Corners will be a continuing focus of public attention in the future, so we hope you agree that it is in the best interest of everyone—the DEC, Dominion, and people of the Mohawk Valley—to minimize foreseeable impacts.

Overview

Today, the Brookman Corners compressor station in Montgomery County is a small facility with a single 7410 HP turbine compressor that runs only about once or twice a week. However as part of its proposed “New Market Project,” Dominion plans to significantly expand this to 18,543 HP in order to transport an additional 112,000 Dekatherms of gas per day. This includes 82,000 Dekatherms per day that would be transferred to the pipeline at Brookman Corners. As proposed, the project involve the addition of a second 6393 HP turbine compressor, two 2370 HP reciprocating compressors, coolers, and other equipment.

According to Dominion, the Brookman Corners facility would pump 96,683 tons of greenhouse gas emissions into the air every year. This is significantly more than the other two compressor stations proposed by Dominion in Chemung and Madison counties, and just under the 100,000 ton/year threshold for a major source under Title V. If all fugitive emissions, blowdowns, and other sources are fully taken into accounted, this threshold has almost certainly been exceeded. Moreover because of the facility’s proposed design, the level of pollutants harmful to human health would be dramatically worse than at the other two facilities. Formaldehyde levels would be 22 times higher, volatile organic compounds (VOCs) 14 times higher, carbon monoxide (CO) five times higher, and nitrogen oxides three times higher than in Chemung or Madison counties according to Dominion’s application to FERC. Negative health effects of exposure to these chemicals include cardiovascular, respiratory, and neurological damage; birth defects, cancer; leukemia; infertility; burning of lungs, eyes, and throat; muscle pain; mental impairment, headaches, and a host of other acute and chronic illnesses. Since the purpose of the Bookman Corners compressor station substantially changes with its connection to the higher pressure Iroquois system, the facility would have to operate continuously, exposing the residents of Brookman Corners and communities downwind to dangerous pollutants on an ongoing basis.

These concerns are compounded by Otsquago Creek and the particular topography of the Otsquago valley that limits the dispersion of emissions. The Brookman Corners compressor station is located next to Otsquago Creek, in the center of the which extends approximately ten miles from the creek’s headwaters near Van Hornesville to the village of Fort Plain. Prevailing winds move downstream in the direction of Fort Plain. However from dusk until sunrise, air stabilizes above cooler waters of the creek, creating a temperature inversion that can cause emissions to settle in the valley. The top of existing and

Page 2 of 13 proposed exhaust stacks at the facility are at a lower elevation than the valley rim. Therefore instead of dispersing high in the atmosphere, concentrated emissions are likely to be contained for longer periods in the basin and carried toward the populated community of Fort Plain. This is a particular concern for the two Caterpillar G3608 reciprocating compressors proposed by Dominion which are less effective at propelling combustion emissions into the atmosphere than turbines, as well as for fugitive emissions vented at low velocity near the ground. Dominion has failed to consider any of these factors in its analysis, instead modeling dispersion based on wind patterns from Rome, NY and Albany, NY located fifty miles away, far outside of the Otsquago valley.2

All of the above conditions place the residents of Brookman Corners and neighboring communities at much higher risk of exposure to pollutants dangerous to human health. Contrary to claims by Dominion, necessary steps have not been taken to protect the public. For example in its application to FERC, Dominion suggests that it should be permitted to exceed base-case criteria for formaldehyde under the pretense that it is using “best available control technology”. However best available technology has clearly not been proposed.

As discussed below, several design alternatives and readily achievable improvements can be implemented, such as less-polluting compressors, modification to existing equipment, and cost-effective vapor recovery technology. This information is presented in a good faith effort to reduce emissions from the proposed project and protect impacted communities.

The following emission reduction methods are discussed:

 Consolidate Turbine Compressors  Replace Proposed Reciprocating Compressors with Lower Emission Compressors  Replace Gas-Fired Compressors with Electric Motor Driven Compressors  Install Vapor Recovery Technology to Reduce Fugitive Emissions  Use Oxidation Catalysts for Each Exhaust Stack  Replace or Retrofit Dehydrators with Zero-Emission Dehydrators  Blowdown Prevention Techniques

2 See additional information submitted to DEC by Steve Hudyncia regarding dispersion at Brookman Corners.

Page 3 of 13 A. Consolidate Turbine Compressors

Dominion’s proposal involves the addition of a single Solar Centaur 50L turbine compressor and two Caterpillar G3608 reciprocating compressors at Brookman Corners. It is our understanding that the additional Centaur 50L turbine is intended to boost compression power of the existing Solar Taurus 60 turbine which would remain on site for the flow of gas in the Dominion pipeline, whereas the two reciprocating compressors would move gas from the Dominion pipeline to the Iroquois pipeline.

Instead of using two turbine compressors to provide compression in the Dominion pipeline, these could be replaced with a single, somewhat larger turbine compressor, such as the Solar Taurus 70 planned for Horseheads and Sheds. Since the purpose of this in-line compressor would be to maintain pressure in the Dominion pipeline, no more than 11,000 horsepower (equivalent to the compression power at Horseheads or Sheds) should be necessary. The advantage of this alternative is that it would reduce both total emissions and hazardous pollutants. In addition, it would eliminate one exhaust stack and could even reduce the required size of the building facility. A comparison of emissions for this is shown below:

Emissions from a single Taurus 70 turbine compared to current two-turbine proposal

Pollutant Current proposal (tons/year) Improved design (tons/year) Solar Centaur 50L + Solar Taurus 60 Solar Taurus 70 * Formaldehyde 0.07 + 0.86 = 0.93 0.11 VOC** 0.4 + 0.9 = 1.3 0.6 CO 1.6 + 17.0 = 18.6 2.4 NOx 14.4 + 27.9 = 42.3 22.3 PM-10/PM-2.5 3.9 + 4.6 = 8.5 6.1 SO2 0.4 + 0.5 = 0.9 0.6 GHG 30,779 + 35,676 = 66,455 47,830

Source: Resource Report #9, Tables 9.1-10 and 9.1-16 * Solar Taurus 70 emissions are based on Horseheads data with a rating of 11,010 HP. ** Does not include VOC fugitive emissions

It is important to note that because the existing on-site Taurus 60 turbine is not equipped with an oxidation catalyst, its formaldehyde, VOC, CO, and NOx emission are much higher than the Centaur 50L. Therefore using a single Taurus 70 (equipped with an oxidation catalyst) provides a substantial improvement for pollutants hazardous to human health. Formaldehyde emissions would be 0.11 tons/year rather than 0.93, CO emissions would be 2.4 tons/year rather than 18.6, and NOx emissions would be 22.3 tons/year rather than 42.3.

If for some reason, two turbines are required instead of one, a lesser but nonetheless notable reduction in emissions could also be achieved by replacing the existing Solar Taurus 60 turbine compressor with the more efficient and less polluting Centaur 50L. (However if two compressors are needed instead of one, Dominion should explain why this is the case.) Although not as effective as a single turbine compressor,

Page 4 of 13 using two Centaur 50L turbine compressors in tandem would still offer a significant reduction in formaldehyde, CO, and NOx. A comparison of this is shown below:

Emissions from two Centaur 50L turbines compared to current two-turbine proposal

Pollutant Current proposal (tons/year) Improved design (tons/year) Solar Centaur 50L + Solar Taurus 60 Two Solar Centaur 50L Formaldehyde 0.07 + 0.86 = 0.93 2 x 0.07 = 0.14 VOC** 0.4 + 0.9 = 1.3 2x 0.4 = 0.8 CO 1.6 + 17.0 = 18.6 2 x 1.6 = 3.2 NOx 14.4 + 27.9 = 42.3 2 x 14.4 = 28.8 PM-10/PM-2.5 3.9 + 4.6 = 8.5 2 x 3.9 = 7.8 SO2 0.4 + 0.5 = 0.9 2 x 0.4 = 0.8 GHG 30,779 + 35,676 = 66,455 2 x 30,779 = 61,558

Source: Resource Report #9, Tables 9.1-10 and 9.1-16 ** Does not include VOC fugitive emissions

The following summarizes projected emissions associated with both of the concepts discussed above for compressing gas within the Dominion pipeline. (This does not include emissions associated with moving gas from the Dominion to Iroquois pipeline, which are addressed in later sections of this letter.)

Summary of in-line turbine alternatives for the Dominion pipeline

Pollutant Current proposal Improved design Improved design (tons/year) (tons/year) (tons/year) Solar Centaur 50L Two Solar Centaur 50L Solar Taurus 70 * + Solar Taurus 60 Formaldehyde 0.93 0.14 0.11 VOC** 1.3 0.8 0.6 CO 18.6 3.2 2.4 NOx 42.3 28.8 22.3 PM-10/PM-2.5 8.5 7.8 6.1 SO2 0.9 0.8 0.6 GHG 66,455 61,558 47,830

Source: Resource Report #9, Tables 9.1-10 and 9.1-16 * Solar Taurus 70 emissions are based on Horseheads data with a rating of 11,010 HP. ** Does not include VOC fugitive emissions

Page 5 of 13 B. Replace Proposed Reciprocating Compressors with Lower Emission Compressors

Dominion proposes to use two reciprocating compressors to transfer gas to the Iroquois pipeline, which operates at a higher pressure from Dominion’s network. Based on Table 2 of the proposed air state facility application, these compressors—which use older-style G3608 engines—would be responsible for the greatest share of projected pollutants from the site including formaldehyde, volatile organic compounds (VOCs), carbon monoxide (CO), and nitrogen oxides. Notably, although the two proposed G3608 reciprocating units are each 2370 horsepower with a combined horsepower equal to less than a single Centaur 50L turbine, the levels of formaldehyde, VOCs, and CO they would produce are more than an order of magnitude higher. As a result, the levels of pollutants dangerous to human health at Brookman Corners would be far greater than at either of the two new compressor stations proposed by Dominion in Chemung or Madison counties.

Moreover, these pollutants, which include both combustion and fugitive emissions, are likely to be even worse than specified. Reciprocating equipment (both engines and compressors) have multiple seals from which leakage can occur, including the rod packing for individual pistons.3 Over time, these seals wear down and increasingly leak. Even when new, reciprocating engines and compressors leak far more than dry-seal turbine-driven compressors. They also require perpetual maintenance and replacement of rod-packing (which often does not happen) in order to maintain emission levels specified by the manufacturer. In addition, the reciprocating compressors at Brookman Corners would run at variable rates depending on varying pressure between the two pipelines, which means that they would almost never operate at the optimal conditions upon which the specifications in Dominion’s application were based.

The Caterpillar G3608 reciprocating engine has existed for decades, so is not equipped with state-of-the-art technology to limit pollutants. Furthermore, Dominion fails to identify the actual compressor that it plans to use with this reciprocating engine or show how or if fugitive emissions are calculated for it. Demonstrating best available technology requires identifying equipment proposed and comparing it with alternatives. For example, several manufactures including General Electric supply variable rate compressors that can be attached to a prime mover that is either a reciprocating gas engine or an electric motor.4 (See section C below.) Although the reciprocating engine and compressor that Dominion would like to use may offer a variable high compressor ratio, other equipment may perform just as well with less emissions.

Clearly, there are a variety of engine and compressor combinations that could effectively transfer gas between the Dominion and Iroquois pipeline. To reduce the high level of projected emission at Brookman Corners, Dominion should be required to evaluate alternatives to the Caterpillar G3608 reciprocating engine and compressor combination proposed.

3 Oil and Natural Gas Sector Compressors, Office of Air Quality Planning and Standards (OAQPS), April 2014 http://www.epa.gov/airquality/oilandgas/pdfs/20140415compressors.pdf 4 http://site.ge-energy.com/businesses/ge_oilandgas/en/literature/en/downloads/reciprocatingcompressors.pdf; http://www.geoilandgas.com/sites/geog.dev.local/files/GE_API618_Process_FS_012412.pdf ; see also http://potemkinindustries.com/wp-content/uploads/2011/03/CAMCS-L-AJAXC302.pdf

Page 6 of 13 C. Replace Gas-Fired Compressors with Electric Motor Driven Compressors

Electric-driven compressors are an alternative where electricity is available and, if used, could potentially eliminate all combustion emissions. At Brookman Corners, Dominion’s pipeline is collocated within a major overhead electric transmission corridor, so this possibility should not be dismissed, even if upgrading of the existing electric transmission line is involved. DEC should require that Dominion evaluate the feasibility of electric powered compressors in place of one or more of the compressors proposed at the Brookman Corners site. By replacing even one of the compressors at Brookman Corners with an electric-driven unit, total greenhouse gases for the facility would drop significantly, increasing the likelihood that Dominion will not exceed the 100,000 tons/year Title V threshold for a major source when all emissions are considered.

Compact electric compressors intended for in-line pipeline applications are readily available with sufficient horsepower to substitute for the Taurus 60 and Centaur 50L turbine compressors proposed by Dominion. For example, General Electric’s Integrated Compressor Line (ICL) series ( https://www.geoilandgas.com/sites/geog.dev.local/files/ge_icl_012815-3-page.pdf ) incorporates a design that integrates the electric motor and compressor into a single sealed casing. It also uses magnetic bearing which require no lubricants and have no seals that can leak. The result is a compressor that produces no emissions whatsoever, not even fugitive emissions. Moreover it takes up a small fraction of the space needed for a gas-fired compressor.

Because electric motors have high torque and can be adjusted for speed using variable frequency control, it may also be possible to use them in applications where reciprocating engine/compressors have been traditionally applied. For example, it is be possible for a variable speed electric motor to drive a reciprocating compressor to generate a high compression ratio that is also variable for the purpose of moving gas from the lower pressure Dominion pipeline to the higher pressure Iroquois pipeline. This would eliminate combustion emissions (CO2) as well as hazardous products of incomplete combustion (formaldehyde, carbon monoxide, etc) in the stack exhaust.

According to the EPA Natural Gas STAR Partners PRO Fact Sheet Number 103 titled “Install Electric Compressors” (http://www.epa.gov/gasstar/documents/installelectriccompressors.pdf ), in one application a partner replaced five reciprocating compressors including two 2650 HP, two 4684 HP, and one 893 HP compressor with four smaller 1750 HP compressors for an estimated annual fuel savings of 1,700,000 Mcf of natural gas. Therefore a similar replacement of the two very polluting Caterpillar G3608 reciprocating compressors, which are each 2370 HP, may be possible at the Brookman Corners facility.

More information on the advantages of electric compressors can be found at: http://www.epa.gov/gasstar/documents/installelectriccompressors.pdf

Page 7 of 13 D. Install Vapor Recovery Technology to Reduce Fugitive Emissions

Regardless of what configuration of compressors are implemented at Brookman Corners, we strongly urge DEC to require the installation of vapor recovery technology that would substantially reduce—and could even eliminate—fugitive emissions that will otherwise be released to the atmosphere. Especially in applications that use reciprocating compressors that are prone to leakage, vapor recovery should be considered a mandatory requirement to demonstrate compliance with Best Available Control Technology (BACT).

The EPA estimates that fugitive emissions from reciprocating compressors accounts for 24% to 29% of total emissions from reciprocating compressors, whereas they account for less than 5% for centrifugal turbine compressors.5 The fact that Dominion predicts that future fugitive emission for the Brookman Corners facility will be less than 6% of total greenhouse gas emissions (5512 tons/year of CO2e) suggests that it has significantly underestimated this impact. (See Table 2 of the air-state facility application for Brookman Corners.) This also raises significant doubt about the likelihood that total greenhouse gas emissions for the facility actually fall below the 100,000 ton/year threshold for title V permitting. Dominion asserts that it should be permitted to exceed base-case AGC criteria for formaldehyde (which would allow ten times the base criteria) under the pretense that it is using “best available technology”. However Dominion makes no provision for the recovery of fugitive emission, so DEC should reject this proposition.6 It is important to recognize that unlike combustion emissions that may be projected higher into the atmosphere where they disperse, fugitive emissions are vented very near ground level, and can therefore significantly impact nearby populations.

Two methods exist to recapture fugitive emissions today. A common method has been to use traditional Vapor Recovery Units (VRUs) that collect emissions that vent from various compressor components (including reciprocating rods) and then reinsert the stray gas back into the pipeline under pressure. However another innovative technique which has been developed by REM Technology (SlipStream®) is to manifold fugitive emissions together and reroute them under controlled conditions back to the air intake of the compressor engine where they are combusted. Unlike VRUs which can be expensive, the REM method is both cost-effective and efficient since no additional compression is required. Stray emissions normally vented from other places in a compressor station can be recaptured this way too. Furthermore, since recaptured fugitives are combusted within the engine or turbine, gas that would otherwise be lost becomes part of the fuel stream, allowing the entire compressor station to operate more efficiently without waste. According to REM, this allows the technology to pay for itself within just a few weeks.

5 Oil and Natural Gas Sector Compressors, Office of Air Quality Planning and Standards (OAQPS), April 2014 http://www.epa.gov/airquality/oilandgas/pdfs/20140415compressors.pdf See also the peer reviewed response dated June 16, 2014 by Environmental Defense Fund (Alvares, Harriss, Lyons) http://www.epa.gov/airquality/oilandgas/2014papers/attachmentr.pdf 6 See additional information submitted to DEC by David Stockwell regarding Brookman Corners.

Page 8 of 13

For reciprocating compressors, the EPA reports the effectiveness of this as follows:

REM Technology estimates that the gas recovery system can result in the elimination of over 99% of VOC and methane emissions that would otherwise occur from the venting of the emissions from the compressor rod packing (REM, 2013). The emissions that would have been vented are combusted in the compressor engine to generate power. This technique is discussed further in the Natural Gas STAR PRO Fact Sheet titled “Install Automated Air/Fuel Ratio Controls” (U.S. EPA, 2011c). This document reported an average fuel gas savings of 78 thousand cubic feet per day (Mcfd) per engine with the gas recovery system installed. …If the facility is able to route rod packing vents to a VRU system, it is possible to recover approximately 95-100% of emissions.7

The environmental, public health, cost, and efficiency benefits of installing vapor recovery technology, such as the SlipStream® technology available from REM, are numerous. Dominion may respond that it plans to maintain its equipment and replace worn components (such as rod-packing) when necessary, however this is impossible to enforce. Furthermore, even newly-installed equipment produces fugitive emissions, especially reciprocating compressors which are inherently leaky. So there is no substitute for vapor recovery.

More information on the REM SlipStream® technology can be found at the following links: http://www.remtechnology.com/products/rem/slipstream.aspx http://www.epa.gov/gasstar/documents/workshops/2012-annual-conf/nasser.pdf

7 Oil and Natural Gas Sector Compressors, Office of Air Quality Planning and Standards (OAQPS), April 2014 http://www.epa.gov/airquality/oilandgas/pdfs/20140415compressors.pdf

Page 9 of 13 E. Use Oxidation Catalysts for Each Exhaust Stack

Although Dominion includes an oxidation catalyst in the exhaust stream of the three new compressors proposed at Brookman Corners, as well as at other compressor stations in the project, there is not one on the existing 7410 HP Taurus 60 compressor presently on site. As such the levels of formaldehyde, volatile organic compounds, carbon monoxide, and nitrogen oxide for this one compressor exceeds that of the much larger 11,000 HP Taurus 70 compressors planned in Madison and Chemung counties. This is clearly unacceptable.

Emissions from a single Taurus 60 turbine compared to current two-turbine proposal

Pollutant 7410 HP Solar Taurus 60 11,000 HP Solar Taurus 70 without oxidation catalyst with oxidation catalyst (tons/year) (tons/year) Formaldehyde 0.86 0.11 VOC 0.9 0.6 CO 17.0 2.4 NOx 27.9 22.3

Source: Resource Report #9, Tables 9.1-10 and 9.1-16

As discussed in section A above, there are better compressor configuration for moving gas within the Dominion pipeline. These include replacing the existing Taurus 60 and proposed Centaur 50L with a single Taurus 70, or replacing the existing Taurus 60 with the Centaur 50L. As discussed in Section C, electric compressors could also be used that produce no emissions. Nonetheless, if the existing Taurus 60 compressor remains, an oxidation catalyst should be installed. This may not have been as critical in the past for a smaller facility that rarely operates, but for the new project with much higher overall emissions, an oxidation catalyst in the exhaust stream of each compressor is essential.

Formaldehyde is a dangerous carcinogen even in low concentrations. According to Table 2 of its air state facility application, Dominion predicts that formaldehyde emissions from Brookman Corners will be 2.2 tons/year, or 4400 pounds/year. This is 44 times the Significant Emission Rate of 100 pounds/year defined by 6NYCRR Part 201.9. Of this, 40% or 1600 pounds/year (0.8 tons/year) would be due to the existing Taurus 60 compressor which has no oxidation catalyst. As previously discussed, Dominion claims it is entitled to ten times base-case criteria for formaldehyde because it supposedly uses “best available control technology.” However it is clearly impossible for DEC to agree that best available control technology has been applied if a common emission-reducing features like an oxidation catalyst is missing from the exhaust stream of one of Dominion’s compressors. Today an oxidation catalyst is standard equipment, so this should be added if the Taurus 60 remains in operation. Assuming rates similar to that of the Taurus 70, adding an oxidation catalyst would conservatively reduce formaldehyde emissions by about 1500 pounds/year and CO emissions by 15 tons/year, as well as reduce levels of VOCs and NOx.

Page 10 of 13 F. Replace or Retrofit Dehydrators with Zero-Emission Dehydrators

A metering station for the Dominion and Iroquois pipelines is located on Brookmans Corners Road about 1000 feet away from the Brookman Corners compressor station. Currently two glycol dehydrator units are located at this metering station which are used to remove water from gas within the pipelines.

Typically, dehydrators produce significant emissions from the venting of still column vapors, and leakage from glycol circulation pumps and pneumatic controls which are gas-driven. Dominion fails to consider this in its analysis, despite the fact that these emissions include methane, VOCs, and hazardous air pollutants released to the atmosphere on an ongoing basis.

Fortunately Zero-Emission Dehydrators are now available which combine several technological improvements to virtually eliminate these emission loses. According to the EPA Natural Gas STAR Partners PRO Fact Sheet Number 206 ( http://www.epa.gov/gasstar/documents/zeroemissionsdehy.pdf ), a zero- emission dehydrator typically saves 31,400 Mcf of methane gas over the course of a year and will pay for itself within one to eight months. The economic and environmental benefits of this are tremendous. Existing glycol dehydrators can also be retrofitted with zero-emission technology.

DEC should require that Dominion upgrade the current set of conventional glycol dehydrators at Brookman Corners to zero-emission units to comply with the company’s claim that it uses best available technology.

More information on zero-emission dehydrators can be found at: http://www.epa.gov/gasstar/documents/zeroemissionsdehy.pdf

Page 11 of 13 G. Blowdown Prevention Techniques

Blowdowns occur when compressor stations are taken offline for maintenance or automatically shutdown. During blowdown events—which are extremely loud—large volumes of gas are released from the compressor station and adjacent pipeline, sometimes over a very long distance that can span miles. Planned blowdowns occur during construction, repairs, and other forms of maintenance. The U.S. Department of Transportation also requires that emergency shut down (ESD) systems at compressor stations be tested annually, so blowdowns are often associated with this. Operators are supposed to provide advance notification to residents when planned blowdowns occur, however they can also occur without warning if there is an accident or emergency that causes the compressor station to dump gas.

There are several techniques that can be employed to limit blowdown emissions or reduce their severity. A readily achievable method of reducing gas lost during blowdowns is to relocate or add fire gate valves closer to the compressor station, which are used to isolate sections of the pipeline. The benefit of this is that a much shorter length of pipeline is purged when a blowdown occurs. It is our understanding that off- site shut-off valves are located 22 miles apart in the Dominion system surrounding Brookman Corners. The possibility that 22 miles worth of gas could be vented to the atmosphere during a blowdown at Brookman Corners is inexcusable. At a minimum, DEC should require the installation of off-site shutoff valves near the compressor station to prevent these losses of methane and other airborne emissions during blowdown events. East of the compressor station, a main shutoff valve could be located at the metering station on Brookmans Corners Road, however a nearby location west and north of the compressor station along the Dominion and Iroquois pipelines should be identified too.

Another method involves modifying ESD vents and blowdown pipe systems to collect and reroute gas to other lines instead of releasing it to the atmosphere. Since the proposed project involves the interconnection of two pipelines at Brookman Corners, both of which would require testing, this is a possibility that should be explored. As an alternative to scheduling a conventional blowdown for ESD testing, DOT also allows dump valves to be tested individually which can substantially reduce emissions. The installation of Yale® closure pipe caps can facilitate this type of rapid cycling between valves.

Finally, for blowdowns that occur, the amount of lost gas can be reduced by substantially lowering the pressure within the pipeline in advance. External shut-off valves that can be operated remotely will also shorten the length of time that gas is lost during an emergency. Although gas is wasted in the process, flaring is also be a way of reducing methane emissions where allowed.

More information on blowdown prevention techniques can be found at: http://www.epa.gov/gasstar/documents/redesignblowdownsystems.pdf

Page 12 of 13 Respectfully submitted,

Nicole A. Dillingham, Esq. Keith W. Schue President, Otsego 2000 Technical advisor, Otsego 2000 Board of Directors Environmental Stewardship Committee

CC: The Honorable Governor Andrew Cuomo NYS-DEC Commissioner Joseph Martens NYS-DOH Acting Commissioner Dr. Howard Zucker

Page 13 of 13

March 6, 2015

Chris Hogan NYSDEC Division of Environmental Permits 625 Broadway, 4th Floor Albany, New York 12233

RE: Otsquago Creek and Water Resource Impacts Associated with the Brookman Corners Compressor Station Expansion (Dominion New Market Project CP14-497-000)

Dear Mr. Hogan,

This letter is specifically intended to address Otsquago Creek, wetlands, and other water resources which relate to the proposed expansion of the Brookman Corners compressor station by Dominion Transmission Inc. through its “New Market Project.” (CP14-497-000) We are deeply concerned that Dominion has ignored these critical resources and the significance of Otsquago Creek, with which the project is hydrologically connected.

Otsquago Creek flows approximately ten miles from its headwaters southwest of Van Hornesville to Fort Plain and is fed by two natural springs that produce approximately 300 gallons per minute of freshwater at a constant temperature of 47 degrees F. The creek is designated as a Class C(T) water for trout and supports the Van Hornesville Fish Hatchery which has been in operation at its headwaters since 1935. The hatchery is now managed by the NYS-DEC which stocks over 100,000 rainbow trout for the benefit of all who fish downstream. See http://www.dec.ny.gov/outdoor/21668.html and http://newyorktraveler.net/the-fish- hatchery-in-van-hornesville-ny/ .

The Brookman Corners compressor station property is located within about 100 feet of the meandering shoreline of Otsquago Creek north of Casler Road, and wetlands that cross the property are directly connected to the creek. Despite this, Dominion does not mention Otsquago Creek at all in its application to FERC. Incredibly, although the creek is clearly visible in aerial photographs of the property (including Figure 6C which depicts on-site wetlands), Dominion fails to acknowledge its presence, stating “No streams found in the vicinity of the Project Area.” This notation can be seen in the lower left portion of Figure 6C, enclosed.

Post Office Box 1130, Cooperstown, NY 13326  Tel: 607 547 8881 Fax: 607 547 6195  www.otsego2000.org Tetra Tech performed a survey of the Brookman Corners site for Dominion in March 2014 and identified wetlands which are labeled as W-17. (See Appendix 2-A titled “Wetland and Water Body Report” in Dominion’s application to FERC.) However nowhere in Tetra Tech’s report or Dominion’s application is there any description of the connectivity between those wetlands and Otsquago Creek. Dominion essentially treats the feature as an isolated wetland, which it mostly definitely is not. We also note that the field photographs by Tetra Tech were taken in the winter with substantial snow on the ground, which casts further doubt on the quality of the survey performed.

The importance of Otsquago Creek and connected wetlands clearly should have been discussed in Resource Report #2 (Wetlands and Waterbodies) and Resource Report #3 (Vegetation and Wildlife) of the project application to FERC. Failure to do so was a major oversight. Because of this it is imperative that DEC conduct its own thorough analysis of potential impacts on water quality and riparian habitat. The deposition of emissions, including particulate matter that settles in the immediate drainage basin of the creek, could adversely impact aquatic or wetland species, especially those sensitive to changes in water quality. Other impacts of increased industrial activity, including noise and light which can adversely impact sensitive riparian habitats and the wildlife they support, should be considered too.

Moreover, the potential for flooding must be considered. As the DEC knows, Otsquago Creek and Fort Plain experienced terrible floods in 2013 which caused much of the area to be designated as a disaster area. As a result, Otsquago Creek breeched its banks and required major restoration in the months that followed. In fact the 2013 flood actually caused washout around the Iroquois pipeline slightly east of the property resulting in pipeline exposure and damage that was not repaired for several months. (See enclosed photo.) The proximity of the Brookman Corners compressor station to Otsquago Creek should therefore be of great concern to both DEC and Dominion.

Significantly, Dominion proposes to cut through delineated wetlands on the Brookman Corners property in order to use the northern pasture area as a staging location during construction. Otsquago Creek is a designated Class C trout stream and as such is sensitive to turbidity and other changes to water quality, so every effort should be made to avoid this. An ample amount of open pasture land exists on site south of this wetland in which staging and equipment can be located, so there is no compelling need for this additional impact. Furthermore locating equipment and material in the northern portion of the property increases the risk of construction-related runoff from that area which could directly impact Otsquago Creek which is only about 100 feet away, as well as industrial noise and light pollution that could impact the riparian corridor. If a flood were to occur during this time, the results could be catastrophic. DEC should prevent Dominion from using lands north of the onsite wetland for anything other than a natural buffer to Otsquago Creek. Since this is a freshwater wetland directly connected to Otsquago Creek, which is a designated Class C (Trout) stream, Article 15 and Article 24 permits should be required if this wetland is impacted.

Page 2 of 6 Dominion has also not provided adequate information on how hydrostatic testing will be performed. FERC requires that applicants “identify all sources of hydrostatic test water, the quantity of water required, methods for withdrawal, and treatment of discharge, and any waste products generated.” (Resource Report #2, Water Use and Quality; second page - additional information) Instead of providing this information, however, Dominion simply states in Section 2.2.4 of its application to FERC that these issues will be addressed later, vaguely indicating that an unspecified amount of water will be obtained from an unspecified source, retained for an unspecified time, and discharged to an unspecified location, which could in fact be a wetland or water body. This is non-responsive to application requirements and offers no assurance that adjacent waters, including Otsquago Creek will be protected. According to the NOAA Northeast Fisheries Science Center:

Biocides (e.g., copper and aluminum compounds) are often utilized in the hydrostatic testing of pipelines… The release of contaminants can reduce or eliminate the suitability of water bodies as habitat for fish species and their prey. In addition, contaminants, such as copper and aluminum, can accumulate in sediments and become toxic to organisms contacting or feeding on the bottom.1

Dominion has provided no information on how water would be eliminated, stating only vaguely that hydrostatic test water would be discharged into a “well vegetated area” and eventually drain to a wetland or waterbody, possible involving the silt fences or straw bales to act as a temporary filter. This is extremely concerning. Otsquago Creek is located a very short distance from the property boundary of the Brookman Corners compressor station, so crude methods such as these will not ensure the protection of this Class C (Trout) water. We are very concerned that rapidly flowing, contaminated test water could be discharged to Otsquago Creek. DEC should specifically require that Otsquago Creek not be used as source for hydrostatic test water or for the discharge of spent water from hydrostatic testing.

In its application to FERC, Dominion claims that it does not require a DEC permit for freshwater wetlands under Article 24 because the project is not within 100 feet of a regulated wetland. Dominion also claims that it does not require a DEC permit for protected waters under Article 15 because the project with not impact a Class C (Trout) stream. We believe that the location of Otsquago Creek and potential impacts described above changes this. DEC should perform its own field evaluation of affected waters and wetlands at Brookman Corners and require all applicable permits. Likewise, in light of the above concerns, it is very possible that the proposed project would lead to the violation of DEC water quality standards §703.2, §703.3, or §703.5 (DEC Regulations, Chapter X, Divisions of Water, Part 703.) All of these issues require the proactive attention of DEC.

1 NOAA Technical Memorandum NMFS-NE-209: Impacts to Marine Fisheries Habitat from Nonfishing Activities in the Northeastern ; http://www.nefsc.noaa.gov/publications/tm/tm209/pdfs/ch3.pdf

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Otsquago Otsquago Creek

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74.712431

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the Iroquois Pipeline (2013) Pipeline theIroquois

42.923228, latitude latitude 42.923228,

http://goo.gl/maps/Si1qd

longitude Washout of Washout

Page 5 of 6 Respectfully submitted,

Nicole A. Dillingham, Esq. Keith W. Schue President, Otsego 2000 Technical advisor, Otsego 2000 Board of Directors Environmental Stewardship Committee

CC: The Honorable Governor Andrew Cuomo DEC Commissioner Joseph Martens

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