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HomeMy WebLinkAboutMDGFireandEmergencyPlanComments-v21/10/2017 Fire Prevention and Emergency Preparedness Plan Comments Pg. 1 of 8 Marcus Gingerich Comments on the Fire Prevention and Emergency Preparedness Plan for Black Oak Wind Farm (changes in red, the remainder is still almost completely relevant) This plan is somewhat improved over the previous version of the Fire Prevention and Emergency Preparedness Plan with some changes in formatting and some additional information, but it is still quite vague and lacking in details. It is still rather like a plan to come up with a plan at a later date. It still seems to be a generic outline of a plan that one might expect to be used to flush out with the specific details for a given application, location, configuration, etc. Without a more complete plan, there is no justification for the town board to even consider approving this plan. 1) Overall, certain elements of this plan remain quite vague and generally incomplete. This plan addresses the construction phase, the operational phase, but there is no mention of the decommissioning phase of this project. Also, what about a repair or reconstruction phase (due to catastrophic failure)? 2) First, our town law contains the following provision in Article III, Section 1. C. 5: Fire Protection Plan. A fire protection and emergency response plan that (i) complies with the Tompkins County All-Hazards Mitigation Plan, and (ii) is created in consultation with the fire department(s) having jurisdiction over the proposed Site. Has Tompkins County reviewed the plan to assure it complies with the Tompkins County All-Hazards Mitigation Plan (http://tompkinscountyny.gov/files/planning/HazMitRpt/Tompkins%20County%20HMP%20Final %20Draft%20-%20July%202013%20-%20ALL.pdf)? Has their review been verified? 3) Have this plan been reviewed by any municipality which already has experience with these type of emergencies? 4) Has Roger Lauper, Enfield Fire Chief, actually been consulted with respect to this plan? Based on conversations with him within the last month or two he indicated he had never seen the plan. Supposedly it has since been reviewed with him, but is there verifiable confirmation of this review, from Roger Lauper? 1.0 Project Description 5) paragraph 1. This description ends with “...and related facilities including a substation in Enfield, NY.” To date there is no accurately known location for said substation no size, no configuration information, etc. At one point, the substation was proposed to go into Newfield; however, it has since presumably been changed back to Enfield, but it is still unclear. One cannot make proper emergency plans when the location isn't even known. How can a plan for access to a location be made if the location is not yet known? The exact configuration and location of the various components including the substation must be specified in order to ascertain the completeness of a fire and emergency preparedness plan. What if there is not access to water where needed? Who pays to get it installed or make the necessary arrangements? If the exact locations of components are specified in other documentation, then a proper reference to said document needs to be included. 2.0 Emergency Management Responsibilities 1/10/2017 Fire Prevention and Emergency Preparedness Plan Comments Pg. 2 of 8 Marcus Gingerich 6) “Project Operator Emergency Response - ...The Project Operator will have specifically trained personnel available to handle emergency response situations.” How many personnel? When will they be available?...24/7? Where will they be stationed? It is mentioned that there will be different teams during construction phase versus operational phase, but there is no detail of what those differences will be. What about decommissioning phase? 7) “...The all-volunteer Enfield Fire Company provides fire services to the Project area,” Until BOWF meets with, discusses with, and agrees upon a response plan with the Enfield Fire Company, no emergency response plan can be seriously considered as complete. It should be noted that it is unlikely that the fire company has experience with or knowledge of dealing with issues related to emergencies in wind farm facilities. So, having the wind project sponsor educate the local services seems a bit self serving. 8) “In addition, helicopter services operating out of Syracuse, New York and Sayre Pennsylvania are also available...” While these services are available, it is not clear how close they can/would fly to the turbines once operational. This needs to be ascertained and detailed so that proper procedures for medivac evacuation are in place ahead of time rather than trying to figure it out at the time of an accident or even worse resulting in an additional accident. The town needs this information to properly evaluate what risk residents are being placed under due to the lack of access by emergency services. 9) “...a meeting will be held with the General Contractor building the project, and local emergency response providers to establish their responsibilities.” This should be done prior to finalization of this plan as there is no way to know whether the local services are equipped and/or trained to handle the requisite situations. If specialized equipment and/or training is required, who pays for it? 10) The fire company should be making contact with other fire companies who have dealt with wind turbines and the emergencies which they have had to deal with. This should be done prior to completion and approval of this plan. 3.0 Emergency Procedures - Construction 11) “Prior to the start of construction,...” per BOWF's own statements, construction has already started so this should have already happened. So, in its current form, this plan has already been violated, thus it still cannot be considered valid as written. 12) When will initial meeting and training occur? This should happen well before the project commences and it should approved by the Town. 13) There are now a few specifics in this plan such as what happens if/when a fire breaks out in the nacelle during the operation phase. The local fire company is only responsible for keeping the public back and controlling ground fires. However, based on conversations with the local fire company, they have little or no capability to control a forest fire. This is a very real problem since the turbines are located so close to forested properties. What is the plan to deal with such a situation? Is the fire company going to have to invest in new equipment, training and resources? If so, who pays for it? What capabilities/training do they need to be sure to have? 14) Since the MSDS information has never been provided, there is no way to ascertain whether the local fire company has the capability to deal with any specific dangers related to the burning 1/10/2017 Fire Prevention and Emergency Preparedness Plan Comments Pg. 3 of 8 Marcus Gingerich debris which will inevitably be falling to the ground. With potentially several hundred gallons of burning lubricants and/or coolants this could produce a toxic cocktail of fumes, but it is completely unknown without the proper documentation and compliance with the local wind energy facilities law. 15) Will the Project Sponsor cover any loss of property and/or value related to potential contamination and/or cleanup? Do they have insurance to cover such an incident? They should be required to maintain a specific amount of insurance at all times and this should be enforceable by the town. 16) BOWF appears to have left open the option of several different wind turbine models, while it seems that is not within the town's wind energy facilities law, they must then provide the details for all proposed turbine models including design specifics, MSDS information, etc. Without this information, a good Fire and Emergency Plan cannot be developed and approved. 17) The plan doesn't really go into detail of the different phases of the project. Is the plan exactly the same during all phases? It mentions project employees assuming several roles, is this also the case during the operation phase? Are there going to be enough employees available to fill all those roles? 18) Per a GE safety manual, a very large radius around a turbine should be cordoned off in emergency situations. In several cases this will extend well onto non-participating properties. Might this also include adjacent residences? If so, what is the procedure for alerting those residents? Where will they be moved to? 19) Apparently icing conditions is not considered an emergency situation even if the turbines are actually throwing ice? Why are not icing conditions considered an emergency situation? What are the procedures if there is an icing situation? Where is the comprehensive list of known emergency situations/conditions? While all emergency conditions/situations can not be anticipated, the more that are anticipated and planned for, the better the potential outcomes. BOWF has said that the turbines will have sensors for icing, but GE’s documentation indicates that they do not necessarily work reliably. Thus, with the close proximity to residences, icing should be considered a serious, if not and emergency situation. 20) What happens in the event that a wind turbine collapses? Are there provisions to contain spills of lubricants, coolants or any other liquids which might be present and leak? Again, without a comprehensive list of materials, it is impossible to develop a proper plan of action. 21) With the height of the nacelle higher than the distance to non-participating property lines, if the turbine falls, who is responsible for the cleanup and damage to the non-participants private property due to environmentally sensitive spills or environmental damage? Does the wind farm have immediate access to non-participants private property and the right to overrun it? Presumably, emergency responders have immediate access to a non-participants property? What rights does the non-participant have over their private property in this type (or any type) of emergency situation with the turbines located so close to their property line? Who is responsible? 3.2 Project Operator Emergency Response Team (Construction) 22) Members of the construction Emergency Response Team and the operational Emergency Response Team need to be identified no later than 60 days before construction/operation. 1/10/2017 Fire Prevention and Emergency Preparedness Plan Comments Pg. 4 of 8 Marcus Gingerich 23) Are the ECPs, communicator, and Site Supervisor different individuals? Are they members of the construction crew? If so, what happens if they are the injured person? 24) The new plan does include mention of an AED which is a great idea; however, there is no indication as to how this device will be available at all different locations of construction. With such a large project area, it seems like a good chance the AED will not be at the location at which its needed. The plans should be flushed out a bit better. 3.3 Emergency Situations and Procedures (Construction) 25) A section 3.4 is referred to, but is not included. Is this supposed to be section 4.0? This needs to be fixed. 26) Project Evacuation events are mentioned, but what exactly are they? Who decides what qualifies as such an event? Is this conveyed to surrounding residents? How? Is there a situation where they might have to be evacuated as well? How? 3.3.1 Minor Injuries 27) When will the accident/injury reporting procedure be developed? Shouldn’t it be in this document? How will it be kept readily available? Where? 3.3.2 Major Injuries 28) Where are the standard operating procedures for accidents? Surely in some instances, personnel will be required to transport to the hospital such as if exposed to dangerous chemical, etc. Or will it all be left up to the victim at the time of incident? 29) When will the emergency phone number list be generated and how will ready access be assured? 30) “When site emergency services personnel arrive…” It is unclear who this is referring to. Is it on-site emergency personnel (from section 3.2) or is this first responders, EMT, firefighter, etc. This needs to be clarified. 31) It seems that no medical personnel, EMTs, etc. are ever expected to respond above ground level. If there is an injury ‘at height’, are the personnel trained for ‘at height’ rescue trained as EMTs so that they can stabilize the injured personnel and maintain the medical condition while retrieving them from the ‘at height’ location? In other words, how will ambulatory services respond to an ‘at height’ injury and get the injured personnel to the ground level for transport to a hospital? 4.0 Emergency Procedures – Operation 32) “Ongoing communication between Project Operator, Town officials and police, fire and emergency services officials…” This sounds very reactive rather than proactive. Why have the procedures not be reviewed with officials in locations that already have wind turbines in operation and even better, locations which have had to respond to emergencies? 4.1 Training and Safety Procedures 33) Contents of the safety and training manuals must be drafted and approved by the [the Town Board/Code Enforcement Officer?] no later than 60 days before the project becomes operational. 1/10/2017 Fire Prevention and Emergency Preparedness Plan Comments Pg. 5 of 8 Marcus Gingerich 34) How often will refresher training of all operating personnel occur? Is there any level of proficiency which must be achieved by personnel? 35) “The MSDS for all hazardous materials on the Project will be on file…” As per the Enfield Town Wind Facilities Law, aren’t these supposed to already be included in the application and ready for review by the town board? Why are they not known? 4.2 Project Operator Emergency Response Team (Operation) 36) This is a team of one person, the Operations Supervisor. There does not seem to be any operating procedure(s) in place. When will this happen? Shouldn’t it be approved by the town board and/or code officer? 37) Many times this document mentions ‘appropriate personnel/agencies’, but these are never detailed. When will these actually be determined? Or will that just be determined on an ‘as needed basis’ when the time comes? That should not be acceptable. 4.3 Emergency Situations and Procedures (Operation) 38) Apparently an icing situation with ice throw is not considered an emergency situation. This seems to ignore the very close proximity to non-participating properties, residences and even participating property owners. There should be some procedure in place as to how the Operator responds to icing situations as far as notification to nearby residents, property owners, etc. The GE manual even addresses procedures for this, but it is not addressed at all by this plan. 39) Project Evacuation is mentioned several times, but no guidance or criterion seem to be mentioned as to what situations might initiate this. Is this only for construction or operation personnel? Is it also for nearby residences? If so, what are the procedures for implementing such an evacuation? 4.3.1 Fire or Explosion 40) “Turbine operations will be monitored 24 hours/day…” Is this accurate for the duration of the project operations? Or is this only for a short time at the beginning of the project? It seemed that an extended service plan might be needed for long-term support? This is again one of the vagaries of this project and plan. This needs to be clarified. What happens if there is a communications failure for any reason or more importantly in weather related situations? Do the turbines go into a fail safe mode? During inclement weather, if there is a regional power failure, is there redundant communication to allow remote monitoring and intervention of the turbine function and status? What are the plans for such a situation? 41) The towers have an internal fire suppression system, but what about the nacelle? There are conflicting statements as to whether there is a fire suppression system in the nacelle. There is mention of ‘considering purchasing an additional fire protection system from Firetrace International’, but since it is only consideration, the town must assume that it will not be included. The overall fire protection/suppression systems that will be in place need to be clarified. The town needs to enforce those plans prior to any operations. 42) “The towers are designed with internal fire suppression systems that will automatically activate if a fire escapes the nacelle.” This does not make sense at all. First, there has been conflicting information as to whether there is an internal fire suppression system. This needs to be clarified. Also, this needs to be detailed for all potential models of turbine which might be 1/10/2017 Fire Prevention and Emergency Preparedness Plan Comments Pg. 6 of 8 Marcus Gingerich installed. Second, if there is an internal fire suppression system, why would it activate after the fire escapes the nacelle? Is the internal fire suppression system going to protect the surroundings once the fire escapes the nacelle or what is its purpose? The trigger of an internal fire suppression system should also trigger a call to the local emergency responders including the fire company so they can be ready to protect local residents. Since this is potentially a significant burden upon the local services, serious consideration should be given to including relevant fees for services otherwise it is simply coming out of the local taxpayers pocket. 43) One of the steps “in the event that a fire escapes the nacelle, personnel should:…Use water to saturate the ground to prevent spreading;” What personnel is this, operations personnel or Enfield fire company? Where does all this water come from? The previous version of this plan indicated use of ‘on-site water access points’; however, that has now been omitted. Are there no longer going to be on-site water access points? If not, where does all this water come from? 44) “Use onsite water access points to saturate the ground to prevent spreading;” Where are these on-site water access points? Who provides them? Is there some plan as to how these will be implemented? What is the source of water as this is potentially a VERY large amount of water? If it is an entire water system, should not this have been detailed in the environmental impact statement? If its going to be a pond or tank (or pipeline system), should this not be indicated in all of the other relevant plans, landscaping, decommissioning, EIS, invasive species (water borne), etc? Is a well going to be drilled at each turbine site to provide this water source? 45) The local Enfield fire company is only responsible for keeping the public back and controlling ground fires. However, based on conversations with the local fire company, they have little or no capability to control a forest fire. This is a very real problem since the turbines are located so close to non-participating forested properties. What is the plan to deal with such a situation? Is the fire company going to have to invest in new equipment, training and resources? If so, who pays for it? What capabilities/training do they need to be sure to have? 46) There is nothing in this plan regarding how an ensuing forest fire might be addressed. A specific example is that Turbine 6 is right next to a non-participating landowner’s woods so if it falls it could fall into the woods and start a fire. It is very likely that burning debris would fall or bow into that woods even if it did not actually fall. What is the procedure then? Who is responsible for containing that fire? Clearly the local volunteer fire department won't have the capability of doing so. The local fire chief, Roger Lauper, has indicated there is nothing they could do. Is it the county? The state? 47) What recourse does the landowner have against BOWF for the loss of property value if the woods burn down? What are the evacuation plans if a forest fire gets started? Will the Project Sponsor cover any loss of property and/or value related to such a fire? Do they have insurance to cover such an incident? They should be required to maintain a specific amount of insurance at all times and this should be verifiable and enforceable by the town at all times. 48) “...a local project manager will be available on-call in case of emergency.” Will this be a BOWF employee or an employee of BayWa (or some other company)? This must be spelled out carefully so that any proposed transfer of ownership is clear in duties. What should a local resident do if they note a problem such as a fire, liquid leaking from tower, ice being thrown from blades, blade failure, tower collapse? Should they just assume that the project is already aware of 1/10/2017 Fire Prevention and Emergency Preparedness Plan Comments Pg. 7 of 8 Marcus Gingerich the situation and ignore it? Is there a plan to educate residents particularly those who live nearby and are most likely to be affected and endangered by emergency situations with the turbines? Without detailed plans of the project and where things will be located, it is impossible to know who may be affected and how the plan needs to be devised to protect them? This plan cannot be properly completed without those details. 49) Because of the potential seriousness of the situation and response time, local responders should be notified as soon as a fire is detected or reported so that responders can be ready to respond if/when the fire escapes the nacelle. 50) What about protecting adjacent property which in several cases is a very short distance away from the proposed tower location? There are no provisions on how to protect and/or interact with adjacent properties or non-participating properties. 51) “Consult the accident/injury reporting procedure to report the incident to the appropriate personnel.” Where is this procedure? Should it be part of this plan? If not, then it should be referenced and accessible to ensure that it is consistent with this plan. If this is the previously mentioned procedure in this plan, please clarify as this plan as it is poorly written. 52) “Enfield Volunteer Fire Company is not responsible for firefighting activities on any portion of wind turbines. A fire in the nacelle is allowed to burn out by itself, as it cannot be fought from the ground. Local fire professionals are responsible for keeping the public at a safe distance, and ensuring no ground fires start from any falling debris. This approach is consistent with that taken by wind projects across New York State and the US generally.” At what point is the Enfield Fire Company informed that there is a fire? Again, this should happen as soon as a fire is detected/reported so that the fire company can be ready to respond when the fire escapes the nacelle. While the approach outlined may be consistent with other wind projects, each project is different especially since in this case non-participating properties are so close to the proposed tower locations. Just because someone else does it is not justification for doing it the same way in Enfield's particular situation. 53) There should be an emergency hotline for the residents (or anyone) to contact the wind project about any emergencies related to the wind facilities. Or is this all supposed to happen through the 911 service? If so, are they going to be trained to handle this type of emergency? Or will they simply send police? Maintenance, Pg. 8 54) What is this rigorous maintenance plan? How does the town enforce adherence to this plan to provide safety for the residents? Is this the standard maintenance plan or the maintenance/support plan which costs extra from the manufacturer which the Project Sponsor is likely ‘considering’ purchasing? Compliance with any actual plan must be verifiable and enforceable by the town if it is to be considered as part of the safety of the project. 55) “Regular maintenance and inspections on all turbine components is standard practice.” This should be verified by the town on a regular basis to ensure compliance and failure to adhere should be enforced by the town shutting down operations until correct actions are taken. 1/10/2017 Fire Prevention and Emergency Preparedness Plan Comments Pg. 8 of 8 Marcus Gingerich 56) “The ground around turbines and ground-based support structures will be maintained in low vegetation to minimize flammable material…” There are no details. What is the size of this area? With turbines so close to non-participating properties, this is a very important detail. Other useful information: 57) Each turbine has a transformer at the base with ~300 gallons of mineral oil in it, but no mention of how much hydraulic oil and other combustible fluids are in the nacelle. This information needs to be included. 58) “…and no batteries or fuel.” This seems a bit out of the ordinary as there would almost certainly be batteries in UPS systems to continue to provide electrical power in the event of a power failure. This needs to be verified and corrected if necessary. 59) “…in the internal fire suppression system is 3M Novec 1230 Fire Protection Fluid,…” Is this in the tower or in the nacelle, or both? The fire protection system details are lacking, confusing and possibly misleading. The fire protection/suppressions systems in all components related to the proposed wind facility needs to be completely clarified and detailed in order to make a reasonable assessment of their safety. It also needs to be approved and enforceable by the town as to whether or not certain system(s) are used or not.