COMMONWEALTH OF MASSACHUSETTS

EXECUTIVE OFFICE OF ENERGY AND ENVIRONMENTAL AFFAIRS

MASSACHUSETTS DEPARTMENT OF ENVIRONMENTAL PROTECTION

THE OFFICE OF APPEALS AND DISPUTE RESOLUTION

In the Matter of
Algonquin Gas Transmission, LLC
)
) OADR Docket Nos. 2019-008, 2019-009,
) 2019-010, 2019-011,2019-012 and 2019-013
) DEP File No.: Application No. SE-15-27
) No. X266786 Air Quality Plan Approval
) Weymouth, MA
)
)

PRE-FILED REBUTTAL TESTIMONY OF ROBERT D. O'NEAL

I, Robert D. O'Neal, hereby state as follows:

1. My name is Robert D. O'Neal, and I am Managing Principal for Epsilon

Associates, Inc. My business address is 3 Mill & Main Place, Suite 250, Maynard,

Massachusetts 01754. I am providing this testimony on behalf ofthe Applicant, Algonquin Gas

Transmission, LLC ("Algonquin").

2. I have a Bachelor of Arts degree in Engineering Science from Dartmouth College,

and a Master of Science in Atmospheric Science from Colorado State University. I am Board

Certified by the Institute of Noise Control Engineering (INCE), and am a Certified Consulting

Meteorologist by the American Meteorological Society. My full Curriculum Vitae is attached as

Exhibit A.

3. I have over 30 years of experience performing sound level evaluation studies in

Massachusetts, and have extensive familiarity with the MA DEP noise regulation under 310
CMR 7.10. The state noise regulation is contained in the MA DEP Noise Policy dated February

1, 1990("DAQC Policy 90-001"). These projects range from gas-fired power plants, rock

quarries, solid waste facilities, and electric substations. I have offered expert testimony on noise

before several Massachusetts regulatory bodies including the Energy Facilities Siting Board

(EFSB), Massachusetts Land Court, and a MA DEP Administrative Law Judge. More detail is

available in Exhibit A.

4. I have been engaged by Algonquin to perform ambient sound level testing and

sound modeling as described in the Sound Level Impact Assessment Report, Weymouth

Compressor Station, Atlantic Bridge Project, Weymouth, MA, prepared by Epsilon Associates,

Inc., October 15, 2018 ("Epsilon report").1

5. The purpose of my testimony is to rebut claims asserted in the Memorandum of

Law ofthe Ten Persons Group filed on April 19, 2019(the "TPG MOL").

CONSTRUCTION NOISE

6. Epsilon Associates did not perform the construction noise modeling for the

Weymouth Compressor Station project. The information on projected construction noise

impacts is found in the report Results of Additional Ambient Sound Survey and Updated

Acoustical Analysis of a new Natural Gas Compressor Station associated with the proposed

"AB Project"
Atlantic Bridge Project( ), prepared by Hoover & Keith, Inc., January 11, 2017

("H&K report").2

7. The construction noise analysis in the H&K report is quite conservative in that it

assumes all six pieces of construction equipment are operating at their maximum power load

simultaneously, AND that they are all working the edge of the site closest to the nearest Bridge

A copy of this report was filed as a Basic Document in this proceeding on February 8, 2019.
2 A copy of this report was filed as a Basic Document in this proceeding on February 11, 2019, as Attachment F to
the May 2018 Update to NMCPA Application.
Street residence simultaneously. Those conditions of maximum power of all six pieces of

construction equipment, all operating at the edge ofthe construction site closest to the nearest

residence, happening all at the same moment are likely never to happen, and thus the projected

construction sound levels are overstated. In addition, based on my experience in Massachusetts,

it is my understanding that the MA DEP does not apply its Noise Policy to construction noise.

8. The TPG MOL has misused the construction sound level information in the

Health Impact Assessment of a Proposed Natural Gas Compressor Station in Weymouth, MA,

January 2019("HIA"),3 which relied on the information in the H&K report. For example, at p.

1 1 the TPG MOL incorrectly states that projected construction noise levels will be as high as 113

dBA at the Kings Cove Conservation Area. The 113 dBA value is a sound power level of all the

construction equipment operating at once at the construction site. That noise is then propagated

out from the source as a sound pressure level which decreases with distance(56 dBA at Bridge

Street for example). Sound power is simply a rating analogous to the rating of a light bulb at 100

watts, where light level attributable to the bulb decreases with distance

9. The TPG MOL at p. 11 states correctly that H&K projected a sound level of 56

dBA at the nearest residence on Bridge Street, which is approximately 650 feet south-southeast

ofthe site (Table 17 of H&K report). However,the TPG MOL is incorrect in stating the increase

over background would be 12 dBA at the nearest residence. The nearest residence is on Bridge

Street where the quietest daytime L90 background is 48 dBA (Table 5-4A of Epsilon report).

Therefore, the increase over background is 8 dBA, not the 12 dBA claimed in the TPG MOL.

And, as explained above in paragraph #7, the 8 dBA increase over background scenario is

unlikely to occur and thus the increase over background will be less than 8 dBA.

3 A copy ofthe HIA was filed as a Basic Document in this proceeding on February 8, 2019.
 OPERATIONAL NOISE

10. The TPG MOL incorrectly states the nighttime background noise levels will be 47

dBA at Kings Cove Park and 46 dBA at a residence on Monatiquot Street. Those are total sound

levels combining both existing background and the future project(Table 6-9B in Epsilon report).

The quietest nighttime background at the residence on Monatiquot Street is 45 dBA today. Thus,

the project is only adding 1 dBA in the middle of the night — an imperceptible change, and well

within the MA DEP Noise Policy.

1 1. In addition, the MA DEP Air Quality Plan Approval dated January 11, 2019

("AQPA under appeal") contains post-construction sound testing requirements in Table 9 to

enforce that the permittee meets the projected levels put forth in the Application and listed in

Table 2 of the permit.

12. The TPG MOL states at p. 10 that "exposure to acute, high decibel sounds(85

dBA)or greater for long periods of time is associated with hearing loss." No area of the

community is projected to come close to those sound levels due to the compressor station. The

highest construction noise level is predicted to be 56 dBA at all residential locations, and the

highest sound levels at a residence due to any aspect of operations will be even less than 56 dBA.

Thus, the comparison of the Weymouth Compressor Station to an 85 dBA occupational exposure

limit is irrelevant.

INTERMITTENT EVENTS

13. Epsilon Associates, Inc. prepared a technical memorandum focused on the

infrequent operational sound sources associated with the Weymouth Compressor Station.

Exhibit B is a copy ofthis memo dated November 9, 2018 ("Epsilon memo").

 14. Blowdowns from the Emergency Shut-Down(ESD)vent will only occur during

an unplanned, emergency station blowdown event, and will be extremely rare after initial

commissioning. The change in sound levels could be as much as 17 dBA if the following three

events occurred simultaneously:

• The ESD vent trips, AND

• The trip occurs during the quietest hour in the middle of the night, AND

• A person is walking on the Kings Cove Conservation Area at the point nearest the

ESD vent at that time (duration approximately 1 to 5 minutes).

15. All ofthese three events occurring at the exact same time is extremely unlikely.

Sound increases at all residences will be less than 10 dBA. The fact that the sound may be

"audible" as noted by the TPG MOL is irrelevant since zero audibility is not required by any

applicable regulation or standard. In any case, emergency events such as this are not regulated

by the MA DEP Noise Policy.

16. Planned case vent blowdowns will be scheduled for daytime hours only and

would be well under a 10 dBA increase over the quietest background at the nearest residences.

At the nearest portion of the Kings Cove Conservation Area, this event would be approximately

a 9 dBA increase over background. In order to experience a 9-dBA increase over background

due to this infrequent source, a person would need to be on the walking path directly across from

the case vent within the one to five minute duration of a planned case vent, and that would need

to happen during the quietest six minutes of the five-hour daily window (see Exhibit B), which

occurs approximately 0.1%(100%-99.9%=0.1%)of the time. In other words, an increase of9

dBA above the quietest background due to a planned case vent is not likely to ever be

experienced.
 2018 WHO GUIDELINES

17. In October 2018, the World Health Organization(WHO)issued a report entitled

Environmental Noise Guidelines for the European Region(

"2018 WHO Guidelines"
). The 2018

WHO Guidelines document was written to cover five specific sources: road traffic, trains,

aircraft, wind turbines, and leisure noise. This compressor station is not in any of those

categories and thus this report is not relevant.

18. Furthermore, the sound levels in the 2018 WHO Guidelines represent ANNUAL

average sound levels across an entire year, and thus are not directly comparable to the sound

levels contained in the Weymouth Compressor Station analyses. For perspective, the existing

sound levels in the area are over the 45 dBA Lden annual average put forth for wind turbines.

The relevant sound level standard is the MA DEP Noise Policy, which establishes the quietest

existing sound levels, and then limits the worst-case increases from future development to less

than a 10 decibel increase.

CONCLUSION

19. In summary,the Weymouth Compressor Station has been designed with extensive

noise control in order to limit sound levels and not create a noise nuisance condition. During the

very quietest hour ofthe night, sound levels will increase by no more than 8 dBA at a couple

homes along Bridge Street, and by 3 dBA or less at all other residences. During the quietest

daytime hours, sound level increases will be 2 dBA or less at all residences. These sound level

impacts comply with 310 CMR 7.10 and the MA DEP Noise Policy.
Signed under the pains and penalties of perjury on May ,2019.

Robert D. O'Neal