Apr 02

Submit a comment to MDE to oppose Dominion Energy’s Compressor Station

The public comment period will be open until June 12, 2018.

Comments may be submitted at the Public Hearing or in writing to the Department to the attention of Ms. Shannon Heafey, MDE/ARA, 1800 Washington Boulevard, Suite 720, Baltimore MD 21230-1720. Citizens may request a one-time 60 day extension to the comment period at the Public Hearing or in writing to the Department during the comment period.

Information from the Maryland Department of the Environment:

The Department of the Environment is aware of the Charles County Board of Appeals’ decision on March 13, 2018 to deny the zoning special exception for Dominion Energy Cove Point LNG, LP (Charles Station) (Dominion). The Department will hold the previously scheduled public hearing on March 28, 2018 on the tentative determination to issue the permit-to-construct for Dominion. By holding the hearing, it provides an opportunity to solicit comments from the general public and other interested parties on all air quality issues related to the proposed facility. The comment period has been extended to June 12, 2018. After comments are received, the Department will review the comments, and will then make a final determination with regard to issuance or denial of the permit. In the interim, the Department will be reviewing the factual and legal basis for the Charles County Board of Appeals’ decision to deny the zoning special exception to determine whether there are issues of federal preemption or other legal concerns.

The tentative determination can be found here.  The draft permit conditions may be found here.  Both documents will also be included in the Dockets located at the Potomac Branch Library, 3255 Ruth B. Swann Drive, Indian Head MD 20640, and at MDE headquarters.

The Air Quality Permits program received a Permit to Construct Application for the Charles Station project for one compressor station that will consist of two combustion turbines equipped with SCR and thermal oxidation units, one 1070HP emergency generator, one 5MMBTU boiler and three storage tanks to be located on their property at 6855 Barrys Hill Road in Bryans Road, MD.

This application can be found at the Potomac Branch of the Charles County library located in Indian Head, MD and can be viewed online here.  Application Supplement One SCR can be found here.  Application Supplement Two air dispersion modeling can be found here.  Supplement site map can be found here. The presentation given at the informational meeting by Dominion can be viewed here.

Information about the compressor station compiled by Rosa Pinnola Hance:

The Maryland Department of the Environment (MDE) should not be rushing to approve this application. Only four days after MDE received Dominion’s most recent supplemental information, they released their “tentative determination” of approval. MDE should have taken more time to consider the material and deferred to the decision made by the local zoning authority: the Charles County Board of Appeals. For MDE to give a tentative determination so quickly after highly questionable and technical supplemental data was submitted by Dominion is a red flag.

Dominion’s proposed compressor station would emit many harmful air pollutants, including nitrogen oxides, carbon monoxide, volatile organic compounds, particulate matter, and formaldehyde (which is considered a hazardous air pollutant by the Environmental Protection Agency (EPA). These air pollutants are associated with health impacts ranging from respiratory illnesses to cardiovascular effects, birth defects, cancer, etc.

Air pollution from compressor stations includes “spikes” of pollution during “blowdowns” when the station is depressurized and air pollutants are literally shot out of the station at great speeds and in great quantities. Dominion estimates that these “events,” which include plant start-ups and shut-downs, would be scheduled on about one third of the days of each year; plus unplanned emergency blowdowns would occur. In combination, all these “events” would expose people to extremely high spikes of pollution that could cause acute negative health effects.

The air permit application and draft permit do not include the blowdown emissions in the estimated emissions, so there is no way to measure whether Dominion will be in compliance with federal air limits during blowdowns, which will be frequent.

The air pollution in our community would be worse than for many other communities near compressor stations because the proposed compressor station is a particularly large one — larger than all compressor stations in New York, for example. Plus, this station would be located in a geographic depression where pollution collects. Finally, the planned smoke stack height was lowered from 83 feet to 50 feet, which will further increase the amount of air pollution lower to the ground.

Dominion’s lowered, proposed stack height of 50 feet is just 4.6 feet higher than the proposed compressor building.  When smoke stacks are not sufficiently taller than the buildings that surround them, air pollutants tend to get trapped in recirculating paths downwind of the buildings, in a phenomenon called “downwash.” Downwash leads to greater pollution levels near the ground level, downwind of the smoke stacks. In order to prevent downwash, EPA created rules to regulate stack height. The EPA formula is that the stacks should be 2.5 times the building height – something called the “good engineering practice” stack height. According to this formula, Dominion’s good engineering practice stack height should be 113.5 feet. Dominion’s stack height is 63.5 feet lower than the recommended height, which means the downwash increase in ground level pollution will be severe. Also, Dominion has not released its electronic air modeling files for this project, so the downwash effects on the air modeling and anticipated emissions on this site are currently unknown.

The air application and draft permit do not include estimates for unregulated “fugitive emissions.” These are leaks from connectors that are common at LNG facilities. They are often substantial, but may go unnoticed if the gas isn’t odorized (which it is not planned to be here). Dominion is allowed thirty days to fix leaks, so citizens could routinely be exposed to emissions that exceed federal air limits for as long as a month due to leaks. In the Cove Point case, Dominion argued that they could not monitor fugitive emissions and also that they should not be required to monitor fugitive emissions.

MDE is not considering the worst-case scenario for the ambient air, which is especially problematic given how close to the legal limit some air pollutants are reported to be. Regional/multi-source modeling should have been done instead of using background averages based on ambient air monitoring data from across the river in Arlington, Virginia, more than 13 miles from the proposed compressor station site.

Estimates show that the proposed compressor station could emit an illegally high amount of nitrogen dioxide (NO2). 188 is the one hour NO2 limit. In their original application, Dominion reported their predicted NO2 emissions would be 177. In the recently submitted supplemental information, the number changed to 129. Why are Dominion’s numbers so different since the project has not changed? In MDE’s tentative approval of the project, the estimated number is 181.5. Modeling uncertainty is +/- 30%.

MDE should provide an opportunity for the cross-examination of witnesses. Dominion has submitted two contradictory air-modeling statements.  Citizens need an opportunity to cross-examine Dominion’s expert witnesses.  This is the best way to learn the truth about the inconsistencies in their application.

The EPA has required that the NO2 levels not be exceeded for purposes of public health. The health of people with existing health problems (such as asthma and respiratory illnesses), would be threatened by NO2 levels that exceed the federal standards. Some studies already question the sufficiency of current standards.

MDE needs to conduct a “health impact assessment” to determine potential and predicted health impacts for the local population.

At the current time, the region is already not in compliance with the federal ozone standards. The proposed compressor station would further exacerbate air pollution and related health problems.

The proposed project would result in approximately 5.9 million metric tons of CO2e emissions per year from end-use combustion. This is equivalent to the annual emissions of over 1.2 million cars and is greater than the annual emissions of a major coal-fired power plant.

Emissions per year of just four kinds of air pollutants would equal that emitted by 887 idling tractor trailers, 41 tractor trailers worth of nitrogen oxide (NOx), 53 tractor trailers worth of volatile organic compounds (VOCs), 132 tractor trailers worth of carbon monoxide (CO), and 661 tractor trailers worth of ambient particulate air pollution (PM2.5).

Cumulative impacts of multiple pollutants can be severe, but are being ignored. Potential health impacts are being considered on a one-by-one pollutant basis without consideration of their accumulated impacts. Dominion and MDE have failed to assess the additive impacts of exposure to multiple pollutants (e.g., PM2.5, ozone, NO2), an especially important concern for already health sensitive individuals including the very young, the elderly, pregnant women, and those with pre-existing conditions. The standards also do not consider the potential synergistic effects of different pollutants.