April 6, 2012
Via First Class and Electronic Mail
Secretary Michael Krancer
Pennsylvania Department of Environrnental Protection
Rachel Carson State Office Building
400 Market Street
Harrisburg, Pennsylvania 17101
Re: Lathrop Compressor Station Explosion
Dear Secretary Krancer,
On March29, 2012, a gas leak ignited attheLathrop Compressor Station (Lathrop) in Springville Township, Pennsylvania, causing large explosion. Residents heard a loud boom that in some cases shooktheir homes. Residents then witnessed flames and gray and black smoke pouring from the station for hours. We, the undersigned, write to demand a full investigation into the cause ofthe explosion and the arnountofpollution that was emitted into the arrioient air. Additionally, we, the undersigned, request full enforcement of the air permits associated with Lathropinduding the issuances ofviolations and flnes. Further, we request that the Pennsylvania Department of Environmental Protection (PA DEP) take this incident as the harQinger that it is and perform a full review ofthe safety ofpermitting natural gas compressor stations, at such a rapid pace, within our communities.
Williams Field Service Co., LLC (Williams), the owhers of Lathrop, began flowing gas through the compressor station one day afterthe explosion. PA DEP requested that Williams “continue to stand down at the site until [they] got an engineer to .. .inspect the compressor stationarid until [they] received a final report from [Williams].”! However,Williams chose not to honor that request. PA DEP has indicatedthat they do not plan to issue an enforcement order now and have not determinedwhether Williams will be fined for the explosion or for disregarding PA DEP's shutdown request.
While PA DEP has indicated that they are “disappointed” with Williams that is an insufficient response to this incident. The undersigned are very concerned that Williams may have violated the conditions of their permits and demand that these permits be enforced to their fullest extent.
Williams operates seven engines at Lathrop. Four ofthe engines are Caterpillar 03608 engines, 2370-2520 bhp @ 900-1000 rpm. These four engines received plan approval 58-329-016 on December 10, 201 O. A plan approval is a construction permit and temporary operating permit. According to PA DEP's EFACTs website, Williams submitted an operating permit application for these four engines on February 6,2011 and it has not yet been issued. The three other engines are Caterpillar 3516B engines, 1380 bhp @ 1400 rpm. P A DEP issued plan approval 58-329-029 for these three engines on February 15, 2011 and issued a general pennit for operation, 58-399- 009GP5, on January 26,2010.
While we, the undersigned, have not reviewed the permits associated with Lathrop and the air emission limits within those permits, it is a synthetic minor. Therefore, it has the potential to emit a major amount of pollution but has agreed to limit is hours or capacity of operation to stay below the major source thresholds. Generally, synthetic minor facilities come very close to tripping those major source thresholds and the emissions from Lathrop's explosion may very well have led to the facility tripping major source status. Additionally, it is very likely that visible emission limitations were exceeded.
General permits, plan approvals and operating permits require that the source will be “operated in such a manner as not to cause air pollution. (General Permit-5 § 4(a); 25 Pa. Code § 127.402(c); 25 Pa. Code § 127.13a(1)). Air pollution, as defined by 25 Pa. Code § 121.1, includes the “discharging from…open fires…or any other source ofany smoke, soot… fumes, oxides, gases, vapors, odors, toxic, hazardous or radioactive substances, waste or other matter in a place, manner or concentration inimical or which may be inimical to public health, safety or welfare or which is or may be injurious to human, plant or animal life or to property or which unreasonably interferes with the comfortable enjoyment of life or property.”
Further, General Permit – 5 (GP-5) requires that a “facility shall be operated and maintained in a manner consistent with good operating and maintenance practices.” Any authorization to operate under the GP-5 that is granted by PA DEP may be suspended or revoked ifP A DEP determines that, at any time, that person has failed to operate the natural gas facility in compliance with the terms and conditions of this permit. Upon suspension or revocation of the authorization operation shall cease immediately.
Additionally, a plan approval may be terminated, modified, suspended or revoked and reissued if the permittee constructs or operates the source subject to the plan approval in violation ofthe Pennsylvania Air Pollution Control Act, the Clean Air Act, the regulations promulgated under either act, a plan approval or permit, or in a manner that causes air pollution.
While we are currently unsure which engine(s) were involved in the explosion, Williams has a GP-5 and a plan approval for operation oftheir seven engines and there is a clear directive that the facility shall not cause air pollution under either permit. Further, there is clear authority to terminate, suspend or revoke either of these permits.
Similar engines are being placed, at a rapid pace, across rural Pennsylvania, near homes, schools and livestock. The undersigned urges PA DEP to suspend the Lathrop permits while a full investigation is perfonned. Further, we urge P A DEP to issue violations for Williams's failure to comply with their permit. Once a full investigation is performed we encourage P A DEP to hold a public meeting and explain why the explosion occurred, what was emitted into the air and what subsequent actions were taken by Williams and PA DEP.
The people of Pennsylvania entrust you with protecting public health and the environment and this explosion and subsequent failures by both WilIiams and PA DEP has rocked that confidence. We urge PA DEP to take strong measures to restore it.
Joseph Otis Minott, Esq.
Executive Director
Clean Air Council
cc: Shawn Garvin, Regional Administrator, U.S. EPA Region 3 Michael Bedrin, Director, PA DEP Northeast Regional Office Jan H. Freeman, Executive Director, Pennsylvania Public Utility Commission
