Responsible Drilling Alliance

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25
Apr

Be True To Your School

ERCS [Emission Reduction Credit Registry System] for nitrogen oxides (NOx) and volatile organic compounds (VOCs), the main components of ground-level ozone, are the most sought-after and marketable ERCS in Pennsylvania at this time.” – PA Bureau of Air Quality


Pennsylvania moved another step closer to the reality of the Williams Company’s Atlantic Sunrise pipeline project at last week’s PA DEP’s public meeting/hearing at the Salladasburg elementary school.

Specifically, the matter under consideration was whether Williams-Transco’s permit application to construct one 16,000 horsepower combustion turbine and an emergency generator at their Compressor Station 520 meets the applicable state and federal laws and complies with DEP’s best available technology requirements.

Station 520 currently has five natural-gas-fueled piston engine compressor units totaling 10,000 horsepower. There is little doubt that the massive turbine will be a huge upgrade over the older units in terms of efficiency, noise, and emissions.

At the same time, once the new pipeline is up and running, increasing demand for gas from the region, it will increase overall emissions coming directly from the station, and from the larger region. Greater amounts of gas will need to be extracted and compressed numerous times along the way to send as far away as South Carolina.

All the impacts beyond what comes out of Station 520 – from the wells, pads, pipelines, other compressor stations, etc. – along the way, of course, are not part of the equation DEP must consider.

Unfortunately, Station 520 was built in 1960 and five years later a new Salladasburg Elementary School opened about 2400 feet north of the compressor.

It would be interesting to see if, in the early 1960s, anyone involved in discussing plans for the school raised concerns about the proximity to Station 520. There was no EPA or DEP back then. In all likelihood, coal was burned to heat many homes in the area. Probably the compressor engines were diesel powered, cars ran on leaded gasoline, more people smoked, life expectancy was lower and so on. Do you think the station’s emissions were of concern to anyone in 1965? Does anyone remember?

Today we have a little better idea from scientific studies to look carefully at emissions like formaldehyde that have been measured as exceeding health-based exposure limits at distances half a mile away from compressor station sources in Susquehanna County. NOx emissions are known to have health consequences also.

DEP informed those at the hearing that the new turbine compressor would have an oxidation catalyst installed to reduce formaldehyde emissions. When questioned, it was stated that the piston-driven compressors at the station do not have such devices. In talking with one of the station’s workers, a life-long Salladasburg resident who once attended the elementary school and whose children go there now, there was obvious excitement about the new equipment being cleaner and far quieter.

Another worker who installs turbine units at Williams facilities all over the east said that once a new one is set up, the pattern is to replace the old piston engine compressors with another new turbine unit. If so, that could be a good outcome for the community. Someone, perhaps DEP, would have to do the math.

The math is one of the main concerns the Mifflin Township Supervisors expressed to the DEP in a December 19th, 2016 letter and forwarded to the Federal Energy Regulatory Commission informing them of their questions and the hearing. Among the questions the Supervisors asked the DEP were:

With the 2014 actual eFACTS emissions added to the published Notice of Intent to Issue Plan Approval for the Mars 100, etc., units, the Total Tons per Year in the preceding chart exceed 298 tons of allowable aggregate emissions emanating from that site. Are these total aggregate site emissions allowable under the National Ambient Air Quality Standards (NAAQS)?

Does your Department, EPA, or FERC have regulations that require and examine aggregate site emissions when reviewing new permits, additions or extensions to currently existing facility limits, to assure minimal impact upon the surrounding adjacent properties and residents?

Specifically, but not limited to this program, is the referenced Plan Approval subject to the requirements of the Prevention of Significant Deterioration (PSD) Program, including the need for an air quality modeling analysis?

Does the Department’s incorporation of the use of the Emissions Reductions Credits of 85.68 tons actually allow the site operator to increase the allowable nitrogen oxide emissions thresholds for the unit beyond what should be allowed under the NAAQS or other regulations?

Is the Department aware of the fact that the Salladasburg Elementary School is located within a few hundred feet from the site of the proposed turbine?

What is the Department’s position on that adjacent property location and the future increase in 20170314-0380 FERC PDF (Unofficial) 03/13/2017 emissions which may affect the student body’s environment? Currently there are 218 students attending Salladasburg Elementary in addition to faculty and staff.

 

The answers to these good and reasonable questions were not part of the discussion at the hearing. It appears that thanks to ERCS, there is a reduction of up to 85.68 tons of NOx emissions per year somewhere in York County. What that means for Salladasburg is not clear at this time. The DEP will respond to the Mifflin Township letter, along with other submitted public comment, when a final decision on the permit is made.

The DEP’s comment period on the Williams-Tranco’s compressor station 520 expansion is open through Monday, May 1st. Submit questions and comments to mzaman@pa.gov.

UPDATE: On May 1, 2017, RDA formally submitted their comments on Compressor Station 520. Click the link below to read the comments in full. RDAcomment    

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