The Honorable Andrew M. Cuomo Governor of New York 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 Iroquois 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 drainage basin 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