Sewer Commissioners warn: Wind turbine placement dangerous and illegal
If you ask the Sewer Commission how they feel about wind turbines, they would probably say, “great”, but ask them how they relish the idea of placing such a structure hovering over the sewer plant and you will get a different answer.
On August 27 the Commission wrote a four page letter to the Green Committee essentially tearing apart every aspect of the turbine, its placement and its financials. That correspondence outlines how the height of the turbine violates Kingston’s own by-laws and places the sewer plant directly under its fall zone “rendering it inoperable for an indefinite period of time. Such an accident could cause harm to the operators of the plant and displace the entire sewer district, including the entire length of Route 3A from the Plymouth town line to the Duxbury town line and side streets.” The Commission questions the ability to insure a turbine at a location that does not meet minimum setback requirements.
Sewer Chairman Elaine Fiore said that members of the Commission have attended numerous Green Committee meetings where their basic questions have not been address. Fiore said that that Green Committee Chair Brian Spires continually says that such answers are forthcoming. Fiore does not want to see the Town investing any more grant money for a bad plan. Other issues described by the Commission letter address what is known as Ice Throw which occurs when ice accumulates on the blades and can fall when still or moving. They fear the result of lightening strikes, power surges and fire.
The Commission claims that the noise and rhythmic thumping of the turbine can cause health issues of homes living within up to 1.3 miles away and feel a 1.5 mile distance from homes could work. They also note that NSTAR must always be able to maintain access to the turbine for electrical reasons and the Commission will “not permit unlimited access to a private company or anyone other than emergency personnel employed by the Town of Kingston.”
The Sewer Commission will once again take their concerns to the Green Committee when they meet again later in September.
Text of Sewer Commission’s Letter
The Board of Sewer Commissioners is writing to voice our concerns over the proposed location for the proposed wind turbine being researched by your committee. We feel that there is significant evidence to support our concerns and ask that you consider an alternative site for this project for the following reasons.
· Fall Zone – All published information, including the Feasibility Study of June 11, 2008, states that wind turbine siting laws and recommendations require setbacks that take into consideration the potential for a worst case scenario to occur, such as turbine collapse or blade fracture during operation. This proposed site would violate our own by-law which states that the turbine would have to be located at least 1.5 times the height of the blade tip. The proposed turbine would be located about 100 to 125 feet away from the Wastewater Treatment Facility. Clearly, this is too close to our facility and the Transfer Station. A worst case scenario could potentially place the fall zone directly on top of the Wastewater Treatment Facility, rendering it inoperable for an indefinite period of time. Such an accident could cause harm to the operators of the plant and displace the entire sewer district, including the entire length of Route 3A from the Plymouth town line to the Duxbury town line and side streets, at great liability to the Town of Kingston. The close proximity to the MBTA line and the proposed new Cranberry Road, new highway ramp and Route 3 is an added liability. Blade fracture during operation and/or complete failure of the turbine could send debris flying hundreds or even thousands of feet from the site. Wind turbines must carry Liability Insurance. We anticipate that it will be difficult for the Town to obtain insurance that will sufficiently cover operating a turbine located at the proposed site, not to mention a worst case scenario, given the fact that the location does not even meet minimum setback requirements.
· Ice Throw – In icing conditions a turbine should have safety mechanisms in place to shut it down. However, even when the blades are not in motion, chunks of ice will fall from the blades to the ground below and could be thrown a significant distance depending on wind conditions. If the blades are in motion, ice can be thrown for great distances. The June 11, 2008 report suggests that access to the immediate area would have to be carefully managed until the ice has melted. Access to the Wastewater Treatment Facility must be maintained 24 hours a day. We cannot limit access to the grounds below the proposed site. Ice throw creates a very real hazard to the employees that are required to be outside daily. In addition, limiting access to the Transfer Station would inconvenience the public by the forced closing of the area and would displace the employees of that facility as well. The close proximity to the proposed new Cranberry Road and highway ramp would also pose additional risk for motorists. The June 11, 2008 report concludes that there is a potential risk to vehicles and people.
· Power Surges, Lightning Strikes and Fire – Wind Turbines cause irregularities in power supply as wind speeds change. When the wind gusts it causes power surges. People living near turbine installations have had to replace small appliances and stove elements, etcetera, due to power surges. Lightning strikes have also been noticed to increase in the area surrounding turbines causing damage to TV sets and computers, even though they had surge protectors in use. We must assume that such problems could also occur with the equipment required to maintain the proper operation of the Wastewater Treatment Facility, posing a potential violation of our discharge permit and health hazard to the sewer customers should a complete shutdown of the sewer system occur. Should lightning strike the turbine tower, there is the potential to ignite approximately 200 gallons of hydraulic fuel contained within the nacelle, causing a severe fire hazard to the Wastewater Treatment Facility. In most cases the fire cannot be fought with fire apparatus due to the height of the nacelle and must be left to burn itself out. Should a fire occur it could also render the turbine controls inoperable making it susceptible to catastrophic failure (falling over).
· Noise and Health Hazard – There is a great deal of information published stating that noise generated by wind turbines can have a very real negative impact on the health or residents living up to 1.2 miles or further away. The rhythmic thumping sound creates a low pitched sound and causes disruption in sleep even when the windows are closed. The low frequency sound created by the turbine travels through walls and other obstacles causing reverberation within the home. Such noise can cause sleep deprivation, dizziness and loss of balance in people, especially those with hearing damage. It also causes anxiety and depression. These health problems are magnified in the elderly. Those living within 1/2 mile (2640 ft.) are likely to experience very bothersome levels of noise. This annoyance continues to distances of 1 mile or more. There are documented cases of people abandoning homes due to the low frequency noise generated by nearby wind turbines. It is recommended that wind turbines should not be built within 1.5 miles of any homes. The June 11, 2008 report estimates the closest residence to be about 790 feet from the proposed turbine site. This is far less than the previously noted distance. We expect the same impact on health would occur if a turbine were located at the proposed turbine site and could have an effect on our staff as well as those working at the Transfer Station. The June 11, 2008 report states there are potential noise related issues that arise from the proximity of the proposed location to residences. There will be perceptible noise and visual impacts on the surrounding community.
· Flicker – Turbine blades cast a moving shadow across landscapes and homes causing a strobe effect. People with a history of migraines, vertigo and motion sickness are susceptible to adverse health effects. The strobe effect can also provoke seizures in people that suffer from epilepsy.
· Turbulence and Wind Shear – The June 11, 2008 report documents significant wind shear and turbulence for the proposed wind turbine site. Such conditions cause higher levels of mechanical strain on the wind turbines blades and drive train causing fatigue and potentially decreasing the life expectancy of the turbine. It also poses a greater risk of blade fracture or complete turbine failure.
· Distortion of Electromagnetic Waves – The June 11, 2008 report studied local radio, cellular and microwave transmitters and receivers. It states nowhere if a study has been done to determine if the proposed turbine would interfere with the communications systems in use at the Wastewater Treatment Facility and pumping stations.
· Power Requirements – The June 11, 2008 report states that interconnection of a 2.0 MW turbine could be interconnected to the Wastewater Treatment Facility with minimal facility and distribution upgrades. A medium voltage cable or overhead line will need to be constructed and a new 1.5 to 2.0 Megavolt-ampere step-down transformer (13.8 kV to 480 V) will need to be installed at the turbine site. It states nowhere in the report whether this can actually be constructed without interfering with the operation of the plant. The report states that electricity production from a wind turbine should coincide as much as possible with electricity usage at the Wastewater Treatment Facility. It also states that with the expansion it would save 90.4 % or $289,469.00 in avoided energy costs. Nobody has been able to provide us with any information that can estimate our actual savings, although the report suggests we would be able to offset all costs at the Wastewater Treatment Facility. We also pose the question of how does an Enterprise Fund benefit from a project that is paid for by the tax payers? We ask that your committee seek assistance from the appropriate Town boards to help you obtain information regarding the financial impact this proposed project will have on the Town’s tax rate and the savings it would generate for the Town and the Wastewater Enterprise Fund.
· Access to Turbine – The June 11, 2008 report states that NSTAR must have access to the disconnect switch at all times in order to potentially disconnect the DG facility should it be responsible for interference in the power system. Where would this disconnect switch be located? Who is considered the interconnected customer, the Wastewater Treatment Facility or the Town of Kingston? Access to the turbine site must be outside of the restricted access fence surrounding the Wastewater Treatment Facility. The Sewer Commissioners will not permit unlimited access to a private company or anyone other than emergency personnel employed by the Town of Kingston.
· Construction – The June 11, 2008 report suggests that construction of a turbine on the proposed site will not interfere with the current Wastewater Treatment Facility or its proposed expansion. There is a significant amount of underground and above ground structures existing and proposed for this site that cannot be relocated. We are very concerned that vibration caused from driving the turbine support structures into the ground would cause damage to the plant and the underground conveyance systems. They cannot be shut down and damage to any of the underground conveyance lines would result in wastewater being released. The construction of the turbine tower requires a large amount of space for lay down of the components. Access to the Wastewater Treatment Facility grounds cannot be restricted at any time. Our access road around the facility must be maintained at all times.
· Public Awareness – The June 11, 2008 report states that the Green Committee should perform extensive community outreach efforts such as an abutters survey, mailing letters and or informational brochures to residents and conducting community meetings to inform residents of project updates. The Sewer Commissioners attended one public meeting held at the Kingston Intermediate School on March 25, 2008, which presented information about other types of energy generating options that are less beneficial to the environment than wind energy. There was not enough information provided regarding the proposed Kingston project and questions from those in attendance could not be answered. Adequate information, both pro and con, some of which is mentioned in this letter, should be provided to the public in order for residents to make an informed decision.
Based on our careful examination of information provided to us by the Green Committee as well as research we have done on wind turbines, the Board of Sewer Commissioners finds significant hazards associated with the proposed project and we cannot support the construction of a wind turbine on the Wastewater Treatment Facility site. We recommend researching alternatives sites for this project.
By Dan Sapir
Editor, Kingston Observer
4 September 2008
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