Wednesday, August 12, 2015

Cluster of Power Plants in Brandywine

4 existing and 1 proposed

Public HEARING, August 17, 2015 • Brandywine, MD  •  Volunteer Fire Department  •  7:00 PM


Where the Farms, the Preservation and Conservation Land Uses have been changed and no longer called the Rural Tier.  Community residents are of the opinion that Brandywine has become an industrial environmental sacrifice zone.


An Alliance for Environmental Justice that’s working towards an Clean Air, Clean Water, Clean Soil environment protecting our resources for the Future of our kids.

Statement of Concern

Natural gas (and oil) power plants add dangerous pollutants to the air that seriously impact the health of people within a ten-mile radius, with children and the elderly most susceptible.  The U.S. Environmental Protection Agency (EPA) has linked air pollutants with cancer, heart disease, chronic obstructive pulmonary disease, asthma, respiratory symptoms, reproductive issues and birth defects. 

We are of the opinion that the North Keys and the Panda Mattawoman proposed project gas power plants will also create water problems, both in sourcing and disposal.  When operating on natural gas, it can consume 58,000 gallons per day; in oil mode, can use 1,000,000 gallons per day.  We believe that consuming such a large amount of water could disrupt our aquifer and cause water shortages. This does not include the Quarry Mines, Surface Mining Plants that consume massive about of water.

We ask for legislation that pertains to a Department of Energy pledge with a 20/20 program: 20% of its energy coming from renewable sources by the year 2020.  We are currently at 3%.  The construction of the power plant will not contribute to this goal.  The plant is also unnecessary, based on Forecast Reports that concludes electric generation supply will be adequate through 2022. 

Various constituencies in opposition of the plant are in the process of assessing all options available to attempt to stop this plant from being constructed. In the weeks ahead they will be looking to the vast numbers of supporters who have expressed their opposition to the plant in joining together to continue the effort of looking at the environment disparity aspect.

The Executive Community Citizens Board(ECCB) is a permanent standing committee of the Brandywine| TB Southern Region Neighborhood Coalition located in Brandywine Maryland, 20613. The ECCB assertion, in part, states that the "effects” on the natural environment; ecological integrity and balance; public health and safety; scenic, historic, and recreational values; forests and parks; air and water purity; and fish and wildlife are disproportionate either alone or cumulatively with other effects when compared to public benefit. Even if the Power Plant is not in conflict with policies of the State of Maryland concerning “effects” of such there are sufficient reasons

As we move forward in evaluating the environmental disparity we urge our governmental agencies to propose strong standards to minimize methane pollution from new and modified sources in the oil and gas industry and also provide a solid foundation for required standards reducing methane emissions from a broad range of existing sources. Comprehensive and rigorous methane standards covering, at a minimum, the sources currently subject to VOC standards as well as those examined in the five 2014 EPA white papers will deliver important public health and environmental benefits. Effective curbs on methane emissions from new, modified, and existing sources are critical to provide much needed clean air protections to local communities, to meet EPA’s obligations under the Clean Air Act, and to meet the administration’s international climate goals.

The ECCB is uniquely situated to evaluate and advise about the potential impacts of the Project. The ECCB is still in the process of evaluating all concerns of the community related to the missions and operations that may be impacted by the Project. As such, the concerns are not an exhaustive list. The ECCB will supplement its concerns as information becomes available and in the event any additional impacts are identified.

  1. The cumulative effect of methane leaks before burning makes natural gas more climate-unfriendly than coal. Every independent study of gas-field methane emissions has corroborated this fact, including those from the National Oceanic and Atmospheric Administration (NOAA), Purdue University, and the Cornell University research team that was the first to explore the climate impacts of natural gas and shale gas production.
  2. Traffic Concerns (Brandywine Road Club) and emissions
  3. Truck Traffic (over 1500 truck trips)
  4. We deserve our Clean Air, Water and Land (soil).
  5. Flammable, toxic, and a potent greenhouse gas; Mixed with: Acid, Corrosive inhibitor, Bactericides, Friction reducer, Iron control, and Scale inhibitors which end up in the wastewater and drilling slurry; erodes Air, Soil and Drinking water Quality 
  6. Environmental and public health hazards are serious and irreversible
  7. Pipeline drilling uses millions of gallons of water/creates adverse environmental consequences to farms food chain, citizen’s communities and conservation land
  8. At risk of possible rupture and explosion causing loss of life and property damage
  9. Accelerates Climate Change
  10. Erodes property values and impact consumer mortgages and insurance. National research studies have shown that property values will decline; and a safety risk will be introduced into populated areas.
  11. Stresses local communities resources and damages infrastructure
  12. Subverts needed investments in carbon-free fuel alternatives
  13. Wealth and income shift from 95% to 5%
  14. Along with the other environmental disparate industrial uses in the Brandywine such as Aggregate Surface Mining, Fly Ash, Lagoon Sludge Fields pollution
  15. The percentage of Distribution of the Environmental Burdens of impaired or threats to the environment in the Brandywine area are in the 90% to 100% for health risks, exposure, emissions, and major chemical releases or waste generation. 
  16. Cooling Tower Are Total Dissolved Solid (TSD) levels in the cooling tower water expected to exceed the assumed average with regularity and is there a significant difference in PM emissions from the cooling tower complex using maximum TDS levels versus average TDS levels? 
  17. Ammonia Emissions Mattawoman's estimated ammonia emissions (198 tpy) are approximately five (5) times higher than Maryland's largest point source ammonia emitter in the 2011 version 1 NEI. These emissions are also significantly higher than reported ammonia emissions for comparable facilities in the NEI and reported emissions in PA DEP's eFACT site. 
  18. The proposed site boundary must have adequate public access controls to qualify as an ambient boundary for modeling purposes. (Brandywine Road Club inefficiencies).
In closing it’s been brought to the attention of the ECCB that the emissions for Brandywine seem very high given the nature of the source. The off-site inventory should, in our opinion, reflect limits during normal base-load operations. CO modeling completed by PPRP indicate the proposed Mattawoman facility exceeded the 1-hr CO SIL when the combustion turbines were in startup modes.

The residents of Brandywine shouldn't have to trade their safe drinking water, clean air, climate, health or communities for energy.

First, notice to the BTB Coalition was around May 20, 2015 therefore limiting the chance for meaningful input was and has been grossly inadequate.

The BTB Coalition mission is that we focus on providing a clean energy future –- one centered on clean, safe, renewable sources of power, used efficiently, that ends our dependence on fossil fuels as quickly as possible. Energy efficiency and renewable energy must be our country's top energy priorities because they are the quickest, cleanest, and cheapest solutions to global warming and other pollution problems.

Although burning natural gas can reduce harmful pollution when it displaces coal in power plants, the extraction of both coal and natural gas is currently resulting in public health threats and climate change pollution. The full extent of those threats from natural gas extraction remains largely unknown and ongoing study indicates substantial concerns and major uncertainties. To the extent near-term use of any fossil fuels continues, we must curb emissions of harmful pollutants and implement strong safeguards for production and use of all fossil fuel energy sources to minimize risks to our health and environment.

The ECCB would greatly appreciate the Maryland Public Service Commissions leadership in protecting public health and addressing harmful pollution. We urge you to establish protective safeguards addressing methane pollution from new and modified sources in the natural gas sector, including the standards that will establish a strong foundation for required actions to address methane and other harmful emissions. Priority actions should include:

Putting sensitive lands and watersheds completely off limits to oil and gas production;

  1. Curbing air pollution across the entire system, from drilling and production to distribution, by setting strong clean air standards that minimize methane leakage and prevent dangerous smog-forming and cancer-causing toxic air pollution;
  2. Mandating the strongest well siting, design, construction, and operation standards and other drilling best practices;
  3. Protecting the landscape, air, and water from pollution by closing clean air, clean water and safe drinking water laws loopholes, reducing toxic waste and holding toxic oil and gas waste to the same standards as other types of hazardous waste, funding robust inspection and enforcement programs, and requiring that oil and gas companies post adequate bonds or other financial securities;
  4. Mandating full public disclosure of information regarding chemicals used in fracking;
  5. Prioritizing renewables and efficiency to replace fossil fuels;
  6. Ensuring full transparency and public participation in permitting and regulatory processes associated with oil and gas development, and allowing citizens to bring enforcement actions against lawbreakers; and
  7. Allowing communities to determine their own future by restricting fracking through comprehensive zoning and planning
In January, President Obama administration took an important step by committing to a suite of actions to reduce harmful methane emissions from the oil and gas industry, the largest industrial source of this pollution. These protections are urgently needed for the health of our communities and families.

The BTB Coalition mission is to ensure that citizen’ rights to oversee their communities are not diminished in the regulations in exercising ones first amendment their right to enforce and defined local legislation ordinance against drilling companies protecting our right to be heard. Maryland should enact a fracking law, such as the Hydraulic Fracturing Regulatory Act, which ensures citizens’ rights to public hearings concerning proposed permits, to appeal permits that are granted, and citizen enforcement against violations of law or permit. The law should also impose bonding and insurance requirements to hold drilling cause and more.

It is urgent that the Maryland Public Service Commission takes immediate protective action for the health of our communities and families. The Brandywine community has the right to limit oil and gas development locations, including prohibiting such development entirely along with community efforts we will continue to champion in our effort to protect public health and pass a permanent moratorium on fracking in lue of the limited moratorium so the state can study the risks and impacts and determine whether—and if so, how—communities can be protected.  In the meantime, we are working with our government agencies to ensure that regulations are as strong as possible to protect residents who are exposed to fracking now.

In closing, and well stated “Rising sea levels. Raging storms. Searing heat. Ferocious fires. Severe drought. Punishing floods. This is what climate change looks like. It threatens our health, our communities, our economy, and our security. It is the greatest environmental threat of our time.

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