February 6, 2011
Municipality of Dallas Township
P.O. Box 518
Dallas, Pa. 18612
Re: Compression Station
Dear XX,
We have only been residents of Dallas Township for approximately 11 years and we have three daughters that attend the Dallas School District. For your information, we run a family environmental consulting practice and we are writing this letter to your office to express our personal and professional concerns about the proposed compression station.
Since we are not familiar with the zoning related regulations in the Township and we believe this is a “new use” that has not been approved in the Township, we listed a number of items that we would suggest the municipality require as part of the review process for natural gas related activities.
The Township should hirer and pay for the services of an independent consultant(s) with experience with compression station design and operation and the development and implementation of emergency response planning. These consultants would review the proposed plan and provide these comments to the Township- the services for this professional should be reimbursed by the Applicant.
The Applicant should prepare and submit an Emergency Response Plan and Health/ Safety Plan for the pipeline and compression station and other hazardous activities or risks associated with this operation. Incidents should be ranked or prioritized and the level of response should be a function of the incident. This plan must be developed in cooperation with all “Stakeholders”. As reported in the Times Leader- it is not adequate for the company to just prepare the plans and coordinate with local responders, the “Stakeholders” will need to take an active role in developing, coordinating, and implementing this plan. This plan must have “local” ownership and direct input. The plan should also identify the equipment, training, and other items that will be needed to effectively respond to an emergency or incident and include a mechanism to report events to the appropriate agencies, local agency, and stakeholders.
This plan should include an evaluation of the potential “worst case” hazard and provide recommended strategies to minimize the risk and provide mechanisms to protect the welfare of the community and our environment. Additional engineering controls and monitoring equipment should be installed on-site and off-site, these controls should be installed and maintained at the Applicants cost.
The Applicant should include an Operation and Maintenance Plan and Procedures for the facility and if the facility is required to submit reports to, the PADEP or other regulatory agencies copies of all reports and accidents should be submitted to the Township within a fixed time period.
The Township should update the existing noise ordinance to properly address the operations of a compression station and require the installation of a real-time monitoring system with remote reporting to the Township and other Stakeholders. One of the pdf files listed below is a reference to an innovated noise control and prevention system. Since this proposed operation is within a “rural residential” area and near a major school, the noise control system should have a minimum of one back-up device in case the primary device fails.
The Applicant should conduct baseline water quality, noise, and air monitoring, install a meteorological station, and air monitoring equipment upgradient and downgradient of the facility, the installation should require real-time monitoring of the system with remote reporting to the Township and other stakeholders – this information is critical to properly respond to a “major” incident or release. The facility is located along or near a groundwater divide that may service our community and the area, surrounding the project site is serviced by individual private wells. These private wells are not routinely monitored or checked for contamination.
It is likely that the Applicant is required to report to multiple state organizations, the Applicant should be required to submit a copy of all reports submitted to obtain and maintain permits, emission testing reports during operation, and state inspection reports to the Local Agency. The Applicant should agree to pay an annual fee to maintain these records available to the public, Township, and local emergency response professionals.
The Applicant should be required to maintain an emergency call number and the Township should require the utilization of the NIMS – National Incident Management System and Incident Command System that has been developed by Homeland Security as part of the emergency response planning.
This is not our area of expertise, but we believe these are critical components to address concerns related to protecting the health and safety of the community. For your information, we found the following websites very informative:
http://www.ehs.okstate.edu/manuals/Gas_plan.htm
http://www.crosstexenergy.com/about/EPIR_gas_pipelines.html
http://www.pipelineawareness.org/wp-content/uploads/2010/07/ERguidelines2009.pdf
http://www.ccivalve.com/pdf/347.pdf
For the record, we DO NOT provide the consulting services that were mentioned in this letter. If you have any questions, please do not hesitate to contact me at 570-XXX-XXXX.
Respectfully submitted,
Mr. Brian Oram, Professional Geologist
Mrs. Robin Oram
Extra Comment
Without saying - the placement of a compression station at the proposed sight would appear to be extremely risky, based on the surrounding land-use, access roads, and the presence of all of the schools that make up the Dallas School System. If possible, the Township should work with the gas company and landowner to identify other sites that are more suitable to site this infrastructure.
The Compression station should not be located in this area, but if it is not possible to relocate the station, it may be necessary for the Gas Company to help relocate the school.
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