PIP Comments and LSP Complaint

The Public Involvement Plan (PIP) comment period ended on Friday, January 5, 2018.  I have consulted with members of Fore River Residents Against the Compressor Station, members of the petition group and the Town of Weymouth about comments that would be made.  I submitted my own letter.  To read it, CLICK HERE.  The LSP that has been hired to this PIP case will be responding to all questions and comments around this RTN.  Duplicate comments/questions will be bundled for one answer (i.e. If the town, myself and two residents all have a same or similar concern, only one answer will be provided).  

Additionally, on December 27, 2017, I mailed a formal complaint about the Licensed Site Professional (LSP) assigned to the PIP Release Tracking Number 4-0026230/4-0026243.  At the meeting held on November 13, 2017, it was discovered that Enbridge is using not only the same firm they hired to help move along the compressor station in Weymouth, but also the same exact person who spoke on behalf of Enbridge/Spectra back in 2016 at our Conservation Commission hearings for what should be an unbiased study of the contamination found at this parcel of land.  
The news article about this meeting can be found here:
The LSP which has been hired by Enbridge to conduct the Scope of Work, Remedial Action Plan, Remedy Implementation Plan, temporary and permanent solutions statements and Activity and Use Limitations for this oil contaminated parcel is the same one who has worked with them for years to help advance the Atlantic Bridge project and the Weymouth Compressor Station.  Due to her past work with Spectra/Enbridge in helping to gain federal approval of the proposed compressor station, it is a conflict of interest as the reputation of her past work is contingent on the outcome of the remediation plan for the recently found contamination and how quickly Enbridge can get the green light to move forward with the construction a compressor station which she received financial compensation for.
If she is allowed to continue on as the LSP for the PIP and her past work with Enbridge and the proposed compressor station is dismissed as a conflict of interest, then there appears to be a flaw with the system that allows these types of relationships to remain legal in the Commonwealth.  Her job with Spectra/Enbridge was to show this land is suitable for a compressor station - and she will be the one coming up with the solutions to clean up the contamination on the site.  Will it be the cheapest and fastest way to further advance the compressor station or will it be a thorough review and a clean up that ultimately bests protect those who live near the contaminated site? 
The draft PIP is riddled with inconsistencies from past information regarding this parcel and is just a poor cut and past job of summary points from the Phase I Initial Site Investigation Report which was prepared by TRC in July 2017.  No one believes we will have a fair review in the PIP moving forward as is.  CLICK HERE to view the complaint that I mailed in.  Please note that other residents have also filed similar complaints.  It is not that we doubt her work or believe she is not fully skilled in her field, however we deserve a true unbiased study of the oil contamination found on the North Parcel, free of a conflict of interest to ensure the cleanup is not detrimental to the health and welfare of the entire Fore River Basin.  

 


Public Involvement Plan (PIP) Meeting - 11/13/2017

If you missed the Public Involvement Plan (PIP) Meeting on November 13, 2017 at 5:30 at Abigail Adams Middle School in Weymouth, here are some supporting documents that were passed out:

PIP PowerPoint Presentation

Draft PIP Plan

 

Some background (taken from PIP):  On September 25, 2017, Algonquin Gas Transmission, Inc. (Algonquin) received a “Petition for the PIP Designation for Disposal Site #4-0026243” (the Petition) from Margaret Bellafiore of Weymouth, Massachusetts, representing a group of 16 residents from Weymouth, Quincy, Braintree, and Hingham. The Petition was also sent to the Massachusetts Department of Environmental Protection (DEP) and TRC Environmental, Inc. (TRC)(Licensed Site Professional, LSP). The Petition is associated with Release Tracking Number (RTN) Disposal Site #4-0026243/4-0026230 and requested its designation as a Public Involvement Plan (PIP) site, under Chapter 21E, Section 14(a) of the Massachusetts General Laws (M.G.L. c. 21E), the State "Superfund" Law, and the Massachusetts Contingency Plan (MCP), 310 CMR, 40.1404). On September 25, 2017, the MCP Site was identified on DEP’s Bureau of Waste Site Cleanup (BWSC) site list as the Calpine Fore River site (Atlantic Bridge Weymouth Compressor Station (Weymouth CS), Site), with a property address of 6 & 50 Bridge Street in Weymouth, Massachusetts (the Site). As a PIP Site, the preparation and implementation of a PIP is required under the MCP. This PIP has been prepared by TRC on behalf of Algonquin in accordance with the requirements of the MCP, 310 CMR 40.0000 and utilizing the Bureau of Waste Site Cleanup (BWSC) Public Involvement Plan Interim Guidance Document For Waiver Sites, WSC-800-90 (January 1991). However, as the MCP has been updated and revised over several years, sections of the Guidance document have been modified to incorporate changes in the MCP.


 

Last night at the PIP meeting, I asked the lady leading the meeting if TRC is the same firm who helped prepare the Resource Reports for Atlantic Bridge. The answer was yes. For anyone who might be confused, when these projects are in the "pre-filing" stage, the applicant must submit numerous reports that equate to 1000s of pages. Since Atlantic Bridge entered pre-filling in early 2015, all the reports were completed in November 2015 and that triggered them to submit the formal application to FERC.
 
If you scroll down at this link (http://www.beckyhaugh.com/gas_compressor_station?page=3) to 11/11/2015, all the Resource Reports for Atlantic Bridge are in clickable links per chapter. If you click on one and press "CTRL-F" and type in "TRC", you will see how many times they are referenced in each chapter. So Spectra paid TRC to do a lot of their mapping and research for these reports. These reports were then used in a more consolidated form to prepare the favorable Environmental Assessment. Most of their work was done in Chapters 2, 6 & 8.
 
At this link (http://www.beckyhaugh.com/weymouth_conservation_commission_denies_wetlands_permit_to_spectra), posted on June 15, 2016, there are links to the minutes of the April 6, 2016 and May 25, 2016 Conservation Commission. In these minutes, you'll see Ms. Kelly Race made comments on behalf of Spectra through being contracted with TRC. This is the same lady who spoke and was in charge of last night's meeting (real spelling is Kelley).
 
As the petitioner group went to MassDEP, it should be noted that no one from MassDEP was in attendance at last night's meeting.  It is TRC's job to collect the questions and comments and to present them and the answers to MassDEP.  It's extremely unfortunate that the same firm and the same exact people who have been working for Spectra/Enbridge for the past 3+ years is now trusted to be an unbiased party in this PIP preceding.  
The written comment deadline is January 6, 2018.  FRRACS will be working with other people to put out pertitent information about the contamination located at 6 Bridge Street Weymouth (a.k.a. the proposed compressor station site).  Will keep updates posted here as well.  

FRRACS Monthly Meeting Reminders

Just a reminder that the monthly FRRACS meeting will be held tomorrow, August 8th at the Fore River Club on Nevada Street in Quincy.  They typically meet the 2nd Tuesday of the month, every month.  Although it seems we are in a down period with the proposal, it's important to stay informed of what is going on.  

Please visit www.nocompressor.com for more information and meeting times.  Please feel free to reach out to FRRACS members if you have any questions or concerns.  You can also find them on Twitter at @FRRACS_MA or HERE ON FACEBOOK.  


CZM Extends Stay 6 Months

Great news - today, the office of Coastal Zone Management issued a 6 month stay on their decision in relation to the proposed compressor station in the Atlantic Bridge project.  This falls as the current 1 year stay is set to expire soon.  

You can read the stay at the Mayor's Facebook page here.

 


Comments for Air Permit by MassDEP for Atlantic Bridge Project

Comments to MassDEP are due May 1, 2017 for the Proposed Air Quality Plan Approval to Algonquin Gas Transmission, LLC's non-Mayor Comprehensive Plan Application.  

PLEASE CLICK HERE TO VIEW MY COMMENTS TO THOMAS CUSHING, PERMIT CHIEF AT MASSDEP


MassDEP Air Permit Comments Needed

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Copy and Paste:

Thomas.Cushing@state.ma.us

Into your email to simply send a comment on Air Quality for the pending air permit for the compressor station

Don't sit back and say this is out of our control. MassDEP has an open comment period for an air permit needed for the proposed Weymouth Compressor Station now.

Use your voice. We need as many people to email in as possible. We CAN fight this together.

Tips for commenting here: https://static1.squarespace.com/static/56afc3b92b8dded389a27cc2/t/58ed2c0115d5db86668be656/1491938305950/Commenting+Tips+for+MassDEP+Air+Quality.pdf



Atlantic Bridge Implementation Plan

Please find the Atlantic Bridge Implementation Plan by clicking HERE


Spectra Gas Leak - Town Council Meeting 2/6/2017

Last night the Weymouth Town Council had before it Spectra Energy due to a gas leak which occurred on January 6, 2017 at the Metering and Regulating Station located in North Weymouth.  The video of this meeting can be viewed online at WETC under Town Council with the date of February 6, 2017.  

There were many questions the councilors had asked that either went unanswered or were answered with erroneous responses.  

First, Congressman Lynch, State Representative Murphy and State Senator John Keenan expressed concerns and posed questions.  It was mostly due to the specific leak and measures Spectra would take to ensure this wouldn't happen again.  The following should be noted: 

-  Spectra stated there was no equipment failure and it was due to moisture buildup which froze.  
-  Spectra stated they replaced the valves and installed security cameras in response to the leak.  But if the equipment wasn't at fault and it was due to moisture, is replacing the valves just giving us false hope this won't happen again?  It wasn't specifically stated how security cameras are going to help detect a gas leak, since gas is invisible.  

Councilors started off by asking how many cubic feet of gas was released on the evening of January 6th.  The response we got was 214,000 standard cubic feet.  

Now reading through the Pipeline and Hazardous Materials Safety Administration (PHMSA) website and Spectra's website, you can find certain regulations which govern pipeline "incidents".  You can click SPECTRA'S ASSET SAFETY RECORD page and see how they outline how few incidents they have on their pipelines.  If you click on "More information: Incident Definition & Categories", you will see they outline what PHMSA says is reportable incidents.  Which I cut and pasted below here (it's Federal Code 49 CFR 191.3).  


Pipeline incidents are defined by federal law as the following events:

(1) An event that involves a release of gas from a pipeline, or of liquefied natural gas, liquefied petroleum gas, refrigerant gas, or gas from an LNG facility, and that results in one or more of the following consequences:

(i) A death, or personal injury necessitating in-patient hospitalization;
(ii) Estimated property damage of $50,000 or more, including loss to the operator and others, or both, but excluding cost of gas lost;
(iii) Unintentional estimated gas loss of three million cubic feet or more;

(2) An event that results in an emergency shutdown of an LNG facility. Activation of an emergency shutdown system for reasons other than an actual emergency does not constitute an incident.

(3) An event that is significant, in the judgment of the operator, even though it did not meet the criteria of paragraphs (1) or (2) of this definition.



Now Spectra states the leak was 214,000 cubic feet.  PHMSA regulations state that an incident is that which is 3 million cubic feet or more leaked unintentially - OR - (3) An event that is significant, in the judgment of the operator, even though it did not meet the criteria of paragraphs (1) or (2) of this definition.

Spectra DID NOT submit any report to PHMSA or the National Response Center (NRC).  Spectra released gas for over two hours and for those of us in close proximity, we could smell a strong odor of natural gas in the atmosphere of our highly residentially dense neighborhood for over 2 hours.  Spectra did not feel this was "significant" enough to file a report with PHMSA.  In fact, under current regulations of the natural gas industry, Spectra would have had to release 14 TIMES as much gas as they did that night in order to qualify for the current required minimum under paragraph 1 of the current federal regulation.  I could not imagine what it would be like if 14 times more gas was released on that evening as the smell and uncertainty were both very concerning to our neighborhood as is.  

Spectra representatives stated that faulty gas valves are not a normal occurance.  However, there were gas leaks reported on Spectra lines in Medway MA on January 5, 2016, Sandwich MA on December 11, 2016 and in South Brunswick NJ on December 18, 2016.  You will not find reports of these incidents however, because they did not meet the minimum required threshold of PHMSA regs and Spectra did not feel gas leaks from faulty valves are worth reporting.  This is why if you look Algonquin or Maritimes up on the PHMSA website, there is only 1 reported incident in the past 10 years.  It's not because they are safe and incidents don't occur - but because the regulations on the gas industry are so loose that they do not have to report them and they are not an honest enough company to do it on their own accord under Paragraph 3 of Pipeline Safety Regulations, Title 49, Code of Federal Regulations.  But you can find many of these occurrences through Google Searches due to local media outlets covering them.  

In fact, on December 31, 2013 - just three years prior to the gas leak in Weymouth, Spectra had a valve freeze at their compressor station in Searsmont, ME.  70 million standard cubic feet of natural gas was leaked - well over the 3 million minimum reporting requirement.  This incident is NOT registered under PHMSA because Spectra didn't report it.  They were imposed a Notice of Probably Violation and Proposed Civil Penalty on October 27, 2014 and were ordered to pay $34,500 in fines (You can read it HERE if you want).  Even still - an incident report was never filed and not searchable on PHMSA's database of pipeline incidents.  All of these incidents are only known due to local media sources which may or may not cover them.  


Click Here for all of Spectra's reported Algonquin incidents 

Click Here for all of Spectra's Maritimes reported incidents (again - note that 70 million cubic feet of gas released on 12/31/13 is not there) 


On September 21, 2015, Spectra stated at a Weymouth Town Council meeting that they have a skater system to detect losses of pressure.  Verbetim from Spectra's representative on the night of the 21st it was told to us, "There is also a skater system that operates, that if there is in fact a loss of pressure on the line at any point we'd know almost instantaneously."  It was further stated by Spectra that night, "An alarm would go off if there was a pressure drop.  It would go back to that sensor in a matter of about 10 seconds.  At our valve sites, sensors are located there and data is sent back to our dispatchers to monitor any discrepancies."  The response as to why Spectra was not notified of the leak by their detection system was that the leak did not cause the pressure to drop to a point that would trigger the sensors.  The representatives were pressured more by councilors - as it seemed ludicrous that a 2 hour leak would not affect pressure in the main line whatsoever.  It was also then revealed that the 2 1" gas valves do not contain sensors - only the bigger 20" pipe does.  

Spectra went on to say that they do check the moisture in the Metering Station but didn't go into details on how it is done.  Just that it is done.  PHMSA released a bulletin on February 11, 2016 titled "Dangers of Abnormal Snow and Ice Build-Up on Gas Distribution Systems."  In this memo, it clearly states, "Monitor the accumulation of moisture in equipment and snow or ice blocking regulator or relief valve vents which could prevent regulators and relief valves from functioning properly."  Spectra pretty much said there was no way they could actually do this.  So again, I'm not sure why new valves are going to improve the safety at the Metering Station if they stated they couldn't properly monitor or fix moisture buildup - and as they stated, these 1" relief valves do not have their own sensors on them.  When questioned why Spectra wouldn't choose to put sensors on these valves, the representatives just pretty much shrugged their shoulders and said they don't have to.  

Spectra likes to pat themselves on the back because they devised an emergency response plan after this incident.  However, federal code requires them to have one already established with the communities which host their infrastructure.  

Under 49 CFR §§ 192.605, 192.615, 193.2509, and 195.402, pipeline facility operators must include provisions for coordinating with appropriate fire, law enforcement, emergency management, and other public safety officials in their emergency plans. Immediate contact by pipeline facility operators with local emergency responders located in potentially affected areas provides for appropriate, more coordinated and effective response to emergency situations involving pipelines, and can minimize potential injury, death and environmental damage.  NOTICE CAN BE VIEWED HERE

The bottom line is Spectra leaked gas in our neighborhood for over 2 hours.  There is no punishment.  There is no fine.  There is no formal record of it.  Because the current regulations allow them to get away with it and turn a blind eye to incidents.  

This incident did not have any injuries, fatalities or personal property damage.  It did send our first responders on a wild goose chase for a little bit trying to track down the source of natural gas.  It should also be noted that there was a small, contained fire in a residence during this time - which our first responders had to respond to - so thank goodness the natural gas leak wasn't more than just a leak.  If a leak occurred in the summer, our 911 dispatchers would be inundated with calls from people assuming they have gas leaking in their homes.  The gas was just released into the environment with no care or concern - and again, no fines for the disruption they caused our community.  

There has been no outreach to neighbors about the incident and no public education (again, a violation of Federal Code) or awareness about the incident or what to do if this happens again.  

I have no faith in Spectra - and I didn't even mention the compressor station proposal once.  Many thanks to all the residents who took time out of their busy schedules to attend the meeting and those who watched from home.  Also thanks to Quincy City Councilors Croall and LaForest who came to our meeting as well.  


More information can be found here:

Fore River Residents Against the Compressor Station

Boston Globe Coverage of Leak

Patriot Ledger Coverage of Leak

Rep. Lynch Calls on Full Report of Leak

WATD Covers Town Council Meeting

Weymouth Councils Seek Meeting in Regards to Gas Leak


What you can do: 

baker_image_with_number.jpg

-  Call Governor Baker's Office and tell them this leak was unacceptable and Weymouth is not an appropriate place to continue the expansion of Spectra's operation - mostly the siting of a compressor station next to this leaking Metering and Regulating station.  Massachusetts is better than this.

-  Contact the Attorney General's office with your concerns over the proposed expansion of natural gas infrastructure in our neighborhood.  Explain how federal regulations are not protecting the citizens of the Commonwealth - an over 2 hour gas leak cannot happen in Eastern Massachusetts with our population density and still be considered a non-reportable incident.  

-  Contact federal delegation and ask them to sponsor bills to change the current federal regulations regarding Natural Gas Pipeline leaks. 

-  Share information with friends, family and neighbors.  


FERC's Ruling on the Atlantic Bridge Project

Click Here for the 101 page ruling on the Atlantic Bridge Project issued on January 25, 2017.  

 

 



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