Tuesday, December 4, 2012

Letter to PSC (Public Service Commission)

November 27, 2012


Hon. Jaclyn A. Brilling


New York State Department of Public Service Commission

Empire State Plaza

Agency Building #3

Albany, New York 12223-1350


            Re:       Concerned Residents of Windsor C.R.O.W.

                        Scott B. Clarke, Chairperson

                        249 Dodd Road

                        Windsor, New York 13865


Dear Secretary Brilling,


This letter is being presented to the NYS Public Service Commission by a substantial number of concerned residents of Windsor or C.R.O.W. (www.crowwindsorny.blogspot.com) regarding the Dunbar Road compressor station now owned by Williams Partners of Oklahoma and the serious problems local residents are having with it.


Soon after the July 23, 2012, Dunbar Road compressor station explosion—causing a 150-foot to 200-foot fireball and very loud explosive noise that shook nearby homes and scared residents in the immediate area—there was a regularly scheduled Town of Windsor board meeting on August 1st. Many, but not all, concerned West Windsor residents attended this meeting with questions, concerns, and comments for the three Williams representatives—Mike Dickinson, Manager of Operations for all Williams compressor stations in the Northeast; Dave Thompson, Supervisor of North Operations; and Helen Humphreys, Senior Corporate Communications Specialist—who  showed up almost 30 minutes late. After listening almost an hour to unconvincing explanations about what had happened at the compressor station and why, these residents left the meeting very dissatisfied with Williams’ mostly evasive answers. United in a cause, the group called Concerned Residents of Windsor (C.R.O.W.) was formed.


This letter addresses the July 23rd explosion/fireball at the compressor station and four major areas of serious concern that C.R.O.W. has with it: noise, odor and air quality, original and revised construction specifications, and water drainage issues.


July 23, 2012 Explosion and resulting fireball (See photo enclosed)

  • C.R.O.W. takes exception to Williams Partners’ downplaying the impact of the explosion and the resulting 150-foot to 200-foot fireball when numerous residents said it sounded like a jetliner crash. Contrary to the minimal coverage reported in the local newspaper, many nearby residents were shaken by the frightening incident—as were their houses—and angry that they had been left in the dark by Williams Partners about what had happened.
  • Equally upsetting is just why Williams would be venting natural gas during a severe lightning storm that everyone in Broome County knew was coming as early as several days before. Company representatives at the August 1st town board meeting said the workers in the compressor station had no way of knowing that a bad storm was upon them because the facility has no windows. With answers like this one and others they were given at the August meeting, concerned residents were left to wonder if they would ever get a straight answer from Williams on any of the serious issues they have with the compressor station. Questions like: How often does venting of natural gas occur? Are local residents informed about such venting? Would flaring off excess natural gas at the compressor station be less harmful to surrounding residents than venting it?
  • Williams Partners’ reps have said that the compressor station isn’t manned from 4:00 PM to 7:00 AM on weekdays and not at all on weekends, but rather is monitored from Tulsa, Oklahoma. C.R.O.W. has very serious concerns about just how quickly Williams can respond to dangerous situations such as the one on July 23rd at 5:45 PM, when the station is supposedly unmanned. Have there been any staffing adjustments made or other precautionary measures taken since this incident?
  • When local fire companies responded to the explosion and fireball, they did not know what to do but direct traffic on Dunbar Road. Why wasn’t there a Comprehensive Emergency Action Plan (CEAP) in place before this very serious incident occurred? Has a CEAP been developed and shared with local residents? What are the current evacuation procedures?

·         It is C.R.O.W.’s understanding that Williams Partners is working with staff from the Public Service Commission and the Office of Gas Safety at the PSC to fully investigate the incident. C.R.O.W. would like to be a part of the investigation to help insure this doesn’t happen again. The group is aware that Williams Partners owns the Lathrop compressor station in Susquehanna County, PA, where on March 30, 2012, there was also an explosionmaking that two serious incidents in less than five months. It is no wonder that there is concern about their safety track record.


Noise generated at the Dunbar Road compressor station is a major problem and has become a “quality of life” issue that could seriously impact property values in the area

·         The noise survey done by Hoover & Keith Inc., an acoustic engineering company from Houston, Texas, indicated that the compressor station in West Windsor failed to meet decibel criteria of the Windsor town ordinance at five of the ten locations surveyed. The follow-up survey in August showed that a number of the areas still needed to be resolved. This last survey also implied that Williams Partners will be able to further reduce decibel levels by installing exhaust silencers on compressor units one through three, although the company cannot predict with certainty the degree to which these additions will reduce decibel levels. Williams Partners states it is committed to achieving compliance of its existing and additional compressor units. C.R.O.W., however, agrees with Town of Windsor Supervisor Randy Williams, in his letter of August 6, 2012, to the PSC where he states, “Based upon the neighbor complaints regarding the fire, noise levels, odors and water problems, there is already an environmental impact that may not currently be within the parameters prescribed by the Town and the Commission. Adding 50% more compressors to the current number of compressors will not aid in the current issues, but rather add to them”.

·         C.R.O.W. wants to know who is responsible for monitoring noise levels coming from the compressor station, how often readings are taken, and what locations are being monitored.  Are readings taken only at the perimeter of the compressor station property or are they being recorded, as required by the town’s noise control ordinance, on nearby residential properties where owners have made complaints?

·         C.R.O.W. is aware of a World Health Organization study of negative health impacts on residents from compressor station noise, including Low Frequency Noise (LFN) in a frequency range of 25-32 cycles per second.  Is Williams Partners doing anything to mitigate noise in this frequency range, which is below the threshold of human hearing?

·         At a March 16, 2011 Town of Windsor public hearing on site plan approval for the Dunbar Road Compressor Station, representatives of former compressor station owner Laser Midstream LLC—later called Laser Northeast Gathering Line—verbally agreed to be in compliance with the town’s recently approved noise control ordinance.  One resident asked the important question, “Will we hear it (the compressor station) when it’s fully operational?”  The answer given by the Laser rep was “No”.  Williams also agreed to be in compliance with the local noise ordinance when they took ownership from Laser at the beginning of this year.  Then why is it that many local residents have continued to hear noise coming from the station, sometimes quite loud.  If Williams Partners isn’t operating the station within the parameters of the town’s noise ordinance, why was it given a Certificate of Completion? Shouldn’t fines and civil penalties be applied?

·         C.R.O.W. wants to know what noise problems were identified in the April 2012 H & K survey, how they were resolved, and what problems remain.


Air quality and odor problems related to the Dunbar Road compressor station are another major concern of area residents

·         In a letter dated August 16, 2012, and addressed to you from Sam M. Laniado, attorney for Williams Field Services Company, LLC, he stated that repairs had been made to a dehydration filter system which he declared to be the source of complaints about odor.  However, some residents still report odors in the air.  C.R.O.W. wants to know if records of water vapor venting referred to by Mr. Laniado are being kept as well as maintenance logs of filter system malfunction and correction.  Are these records available to residents?

·         C.R.O.W. is informed that the PSC Office of Gas Safety is responsible for addressing air quality issues and would like to know if any air quality testing has been or is being done on emissions from the Dunbar Road compressor station. If so, what are the results? C.R.O.W. has heard accounts from area residents of noxious smells, burning eyes, and excessive, non cold-related coughing, symptoms they were not experiencing prior to the compressor station going online. If Williams Partners says unequivocally this is not from natural gas leaks or emergency venting, then what other emissions are being released from the compressor station and related equipment? Are there any releases of chemical pollutants, such as Benzene, Toluene, Ethylbenzene, and Xylene (BTEX) as have been found being emitted from natural gas well sites and compressor stations in Texas by Wolf Eagle Environmental.  These “fugitive emissions” compounds can cause irritation to the upper respiratory tract and eyes, sore throats, dizziness, headaches, and more.  


Differences in the original, revised, and as built construction plans and specifications for the compressor station are a major concern for C.R.O.W.

At Laser Midstream’s informational meeting at the West Windsor Fire Station on May 19, 2010, Windsor residents were presented with a detailed artist’s rendering of the Dunbar Road compressor station project.  Sometime subsequent to this meeting, project design plans were produced first by Keystone Associates of Binghamton, N.Y. and then Pro Plus, Inc. of Houston, Texas, that indicate significant changes from the design originally shown to Windsor residents.   C.R.O.W wants to know when these changes were made, by whom, and why they were done without public input.  Several specific areas of change are of concern to residents.

·         Keystone’s design (as shown on sheet #C100, dated September 28, 2010, project #1781.16210) indicated that the rock cut behind the compressor building would start about 90 to 100 feet horizontally from the base of the building and slope upward (towards the east) at roughly 26o to the horizontal. Such an angle would deflect noise coming primarily from fans on the rear side of the building in an upward direction. As constructed, there is roughly an 8-foot high vertical rock cut about15 feet behind the building, creating a plateau upon which the exhaust silencers for the diesel exhaust are placed. This plateau extends from the silencers to the second rock cut at least fifty feet to the rear and is at an elevation of at least 1538 feet, not the 1530 feet shown on Keystone’s plan. The second vertical rock cut varies in height but is at least 15-20 feet high before meeting the hillside. Both these vertical rock cuts act as sound barriers that reflect the sound from the three, 13-foot diameter fans behind the building laterally rather than upward, thus increasing noise levels to the surrounding community. According to General Construction Conditions, note #5 on Sheet C220 of Keystone’s plans, there should be written authorization from “the engineer” for any design change. Who authorized the rock cut modification and why?

·         Another problematic revision has to do with the inadequate height, length and placement of the earthen berm.   As was visually presented by Laser Midstream at its info meeting in May 2010, the berm was shown in front of and parallel to the long side of the building and wrapping around its southern side to blend back into the original ground at the same height as the top of the building, which is 25 feet from finished floor to the top of the roof ridge.  Residents were told that the berm would help hide the building since it was of the same height.  The existing berm doesn’t look at all like it did in the original drawing. It now is solely parallel to the long side of the building with the top of the berm at an elevation  of 1540.0 feet or 8.5 feet above the building’s finished floor elevation of 1531.5 feet.  This does little to hide the building or to help in noise abatement. 

·         A third issue is that site work at the compressor station has apparently been done by Williams Partners without the necessary SPDES permit from the New York State DEC.  Laser Midstream had received permit #GP-0-10-001 to construct the compressor station, but Williams is apparently only now—in mid November—in the process of reapplying for the necessary permission for site work even though they took ownership of the pipeline and station from Laser in early 2012.  This information was provided by Ellen Hahn of the DEC office in Syracuse when Mark Lippolis met with her and Williams’ employee Julie Nichols at the compressor station on Thursday morning November 8, 2012.

·         Mark Lippolis, a member of C.R.O.W. and retired Civil Engineer with the NYS Dept. of Transportation, went on a tour of the compressor station on August 23, 2012, and has spoken numerous times with Town of Windsor Code Enforcement Officer Dave Brown, and Corey Strub and Jim Austin from the PSC about these highly troublesome revisions.  To this date, no good answers have been received by him or C.R.O.W. to these questions and issues.  We at C.R.O.W. hope to be included in a meeting with the PSC, Williams Partners and town officials to review all of these problematic issues.

·         C.R.O.W. would like to know what firm provided construction supervision and inspection to assure the design plans were properly adhered to.  Helen Humphries of Williams Partners was asked this by Mark Lippolis but she was unable to provide an answer.


Drainage issues related to revisions in the original layout of the Dunbar Road compressor station have caused serious and unresolved problems.

·         Town of Windsor Supervisor Randy Williams has sent numerous correspondences to the PSC requesting help or guidance on this issue. In his April 16, 2012, letter to you he wrote: “At the Town’s April 4, 2012 meeting, Mr. Kelly Pennay (421 Dunbar Road) came and spoke to the board. Mr. Pennay had a water/drainage problem at his property before the compressor station and berm were installed. To help address this problem, a larger pipe was installed, which made the water manageable. However, now the water is a problem again. . .Mr. Pennay’s belief is that the berm is diverting the water from its normal drainage pattern, and this is causing the problem. The water is so voluminous that it is covering the road. This is a concern for the Town. We have contacted Williams on the water issue; however, we believe that this is a large issue with serious ramifications. We ask the PSC to please investigate the water issue and take whatever actions are necessary”. This is what C.R.O.W. asks for too!

·         Kelly Pennay has repeatedly told the Windsor Town Board that the two creeks coming down the side of the hill below the compressor station are no longer functioning as they did before it was built. Now one of the creeks that once handled part of the water runoff has been closed off and the other creek, which runs through Pennay’s property, produces such an excessive increase in water flow that even a long mild rain is causing flooding in his basement and undermining the foundation of the garage portion of his home.

·         Supervisor Williams addressed this issue again with the PSC in a letter dated August 6, 2012. In response, he received a copy of a letter dated August 16, 2012, addressed to the PSC from attorneys for Williams Field Services Company, LLC stating that “Williams was made aware of a drainage issue with a property bordering the compressor station to the southwest. As a follow up, the affected compressor station area was re-graded, a mud pond was filled, a pile of soil was removed and the area was subsequently seeded on July 9, 2012”. The letter goes on to say, “These measures were taken in an attempt to reduce the amount of water entering the bordering property”. C.R.O.W. wants to know why neither Williams Partners nor the PSC have, in all this time, contacted Mr. Pennay, despite his having initiated contact with both. As stated above and to Williams’ representatives at the August 1, 2012, Windsor town board meeting, Mr. Pennay believes berm changes made to the original layout plans he saw at Laser’s May 19, 2010, public information meeting are seriously exacerbating his drainage problems. C.R.O.W. wants to know why these revisions were made.


C.R.O.W. commends Windsor Town Supervisor Randy Williams for communicating with the PSC in writing about various concerns reiterated and emphasized in this correspondence. He has repeatedly suggested to West Windsor residents living around the Dunbar Road compressor station that they send public input on these important issues directly to the PSC.  C.R.O.W. has taken his advice in bringing its concerns to the attention of the PSC and hopes it will result in a meeting of all parties to resolve these issues.


The members of C.R.O.W. believe that the burden of proof for compliance with local and state laws should be with Williams Partners and we are asking the PSC to hold them accountable. C.R.O.W. appreciates, in advance, your attention and response to these important issues.



Respectfully submitted,

C.R.O.W. committee members


Scott B. Clarke                                                                       Kelly Pennay

Linda Pierson                                                                          Rebecca Reed

Eileen Ruggieri                                                                       Mark J. Lippolis

Peter Ruggieri



Cc:    NYS Gov. Andrew Cuomo, NYS DEC Commissioner Joseph Martens, Broome Co. Executive Debbie Preston, NYS Senator Tom Libous, NYS Assemblyperson Clifford Crouch, NYS Assemblyperson Donna Lupardo, Broome Co. Legislator Scott Baker, Windsor Town Supervisor Randy Williams, Windsor Town Supervisor elect Carolyn Price, NYS DEC Storm Water Specialist Ellen Hahn, Town of Windsor Engineer Ron Lake, Town of Windsor Code Enforcement Office Dave Brown, Williams Partners Northeast Manager of Operations Michael Dickinson, Williams Partners Supervisor of North Operations Dave Thompson , Williams Partners Senior Corporate Communications Specialist Helen Humphries, NYS PSC reps Corey Strub and Jim Austin.  

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