Date: December 23, 2024
To: Thomas Joseph, Environmental Engineering Manager, Department of Environmental Protection, and Kevin Halloran, Assistant Regional Director, Department of Environmental Protection, Southwest Regional Office, 400 Waterfront Drive, Pittsburgh, PA 15222
Subject: ETC Northeast Pipeline, LLC proposed Operating Permit #63-01001
Dear Environmental Engineering Manager Thomas Joseph,
Moms Clean Air Force is a community of over 1.5 million moms and caretakers united nationally to equitably protect children’s health from air pollution and our changing climate. Our Pennsylvania chapter has over 105,000 members. The potential negative health impacts from the pollution associated with the rapidly expanding fracking infrastructure in our state are a primary concern.
ETC’s Northeast Pipeline LLC Revolution gas processing plant has been an egregious contributor to this air pollution. Given the history of the Christmas Day 2022 explosion, flaring, and noncompliance at ETC’s Northeast Pipeline LLC Revolution gas processing plant, we urge you to deny the request for the State-Only Operating Permit, and we respectfully request a public hearing on the operating permit so the public has the opportunity to voice their concerns.
Parents across Pennsylvania want their children to grow up happy and healthy. However, because of the 40% growth of oil and gas operations across Pennsylvania over the last decade, families understandably have serious concerns over potential health impacts. In fact, research shows fossil fuel pollution is the top environmental threat to the health of our children and other vulnerable Pennsylvanians. And, we are concerned about the petrochemical expansion in the region that would continue to drive oil and gas operations and compound pollution. Our children are especially sensitive to this pollution as their bodies develop.
The December 25, 2022, explosion at the ETC Revolution gas processing facility was a dangerous reminder of what is at stake as residents were forced to flee their homes and told to shelter-in-place for the nearly 11-hour duration of the fire. Reports of flaring, in violation of permit restrictions, and Energy Transfer’s dangerous history of noncompliance at its other Pennsylvania facilities have increased public concern about their operations.
The ETC Revolution gas processing facility disproportionately impacts vulnerable and sensitive communities who are already living with a significant pollution burden from the massive amount of oil and gas operations in the area. The health and safety risk to families living near the ETC Revolution gas processing facility could range from respiratory illness and cancer caused by increased exposure to volatile organic compounds, to loss of property or possible death in the case of another explosion.
We object to DEP’s Draft SOOP No. 63-01001 because it fails to comply with DEP’s regulations for issuance of operating permits for several reasons, including:
- ETC Northeast Pipeline, LLC’s extensive, excessive history of explosions and chronic noncompliance with air pollution laws at Revolution Cryogenic and its other facilities indicate a lack of ability or intention to comply with air pollution control laws and indicate that this facility is likely to cause air pollution or to violate applicable air pollution laws and regulations;
- The SOOP Application fails to include required information such as listing the December 25, 2022 fire, explosion, and uncontrolled emissions event in its compliance history;
- The Draft SOOP fails to incorporate appropriate and clear permit limits on emissions of pollutants of concern from sources at Revolution Cryogenic; and
- The Draft SOOP lacks adequate monitoring, testing, and reporting requirements necessary to verify compliance.
We also respectfully request the PA DEP hold a public hearing on both of the permits, so the public has the opportunity to voice their concerns. A public hearing is warranted for many reasons, including:
- The public has significant interest in and concerns regarding the operation of this facility given its history of an explosion, flaring, and other instances of noncompliance;
- The facility is located in an environmental justice area, which renders it in need of enhanced public participation processes and opportunities; and
- The facility has also already submitted an application for an expansion that will necessitate nonattainment new source review, as it will be a major emitter of volatile organic compounds.
The opportunity to voice concerns and have them on public record should be an essential part of the permitting process. We urge you to hold a public hearing on the operating permit as well as the proposed expansion, so the public has the opportunity for public participation and direct engagement with the PA DEP.
Thank you,
Moms Clean Air Force, Pennsylvania Chapter
555 12th St NW #400, Washington, DC 20004