The Department of Environmental Quality (DEQ) has been reviewing the ACP air modeling report, readying for the proposed Buckingham compressor station air permitting process. Friends of Buckingham and friends have accessed the documents and are reviewing them, readying for commenting. You can read them here. Further below is a brief preliminary analysis of these reports, thanks to the brilliance of Mary Finley-Brook, PhD. Also, there is a pdf with a few photos and tables; highlights from these ACP-DEQ longer documents.

ACP – Buckingham Compressor Station – Air Modeling Report 07-10-2018
ACP Buckingham-Response to VADEQ Data Request 06252018 Letter_FINAL_0629.._

There will be a public hearing in Buckingham, as we have requested. The hearing will likely be in the middle of the 30 day comment period. We are expecting it to be in August. The commenting is not limited to Buckingham County, nor Virginia citizens. Please y’all speak out and come on out!

Friends of Buckingham has scheduled a community meeting to share information and prepare ourselves for the hearing and the comment period. Union Hill Baptist Church has again generously opened its doors for this event on Monday August 6, 5 pm. A potluck will follow the meeting at 6:30 pm. See you there!


The 2018 Air Permit Application for the proposed ACP CS#2
Excerpts from report here: Compressor station ACP air report – photos and tables 7-17-18

Pre-analysis by Mary Finley-Brook, PhD:

(Woods Corner/Union Hill/Buckingham)

Pollutant Annual Air Releases Public Health Implications of Pollutants

(https://www.epa.gov/criteria-air-pollutants)

Nitrogen Oxides (NOX) 34.3 tons Causes inflammation of the airways, decreased lung function, increased risk of respiratory conditions, and increased response to allergens.
Carbon monoxide (CO) 51.6 tons Vital organs, such as the brain, nervous tissues and the heart, do not receive enough oxygen to work properly; people have trouble concentrating, lose coordination, and feel tired.
Volatile Organic Compounds (VOCs) 7.69 tons VOCs can irritate the eyes, nose and throat, can cause difficulty breathing and nausea, and can damage the central nervous system as well as other organs.
Particulate Matter (PM) 43.2 tons Exposure to PM can lead to premature mortality, aggravation of respiratory and cardiovascular disease, decreased lung function growth, exacerbation of allergic symptoms, etc.
Sulphur Dioxide (SOX) 8.30 tons Exposure to SO2 can harm the human respiratory system and make breathing difficult; SO2 contributes to acid rain.
Carbon dioxide equivalent (CO2e) 295,686 tons Carbon releases contribute to climate change with climate-related health impacts, such as increases in distribution and/or intensity of mosquitoes and ticks, allergens, natural disasters, etc.
Methane (CH4) 70.9 tons Methane is a potent greenhouse gas; methane gas exposure can cause headaches, dizziness, weakness, nausea, vomiting, and loss of coordination.
Hazardous Air Pollutants (HAPs) 5.3 tons

 

More than 30 Hazardous Air Pollutants (HAPs) (e.g., arsenic, benzene, toluene, xylene, etc.) would be released from the proposed compressor station. There are particularly high levels of formaldehyde (can cause irritation of the skin, eyes, nose, and throat; high levels of exposure may cause some types of cancers) and hexane (or n-hexane, which can cause dermatitis and irritation of the eyes and throat).

 

ENVIRONMENTAL JUSTICE THREATS AND RISKS

The Freedman community of Union Hill lies proximate to the only compressor station location in all of Virginia. Similarly, the only compressor station in North Carolina was sited in community that is predominately African American today on Native American land.

Union Hill has not been given adequate information about ACP-associated infrastructure (i.e., pigging launcher, M&R, pumping house, microwave tower, above and below ground storage tanks). This polluting, dangerous (high pressure, explosive) infrastructure in Buckingham will not be staffed round the clock to assure safe management–the station will operate long-distance from West Virginia. There is significant explosion risk with gas from six pipelines channeled through Transco and ACP Pipelines at the Buckingham intersection. A blast zone extends a minimum of 2 miles with secondary fires likely for much larger distances. Air pollution from the compressor is estimated to spread approximately 10-15 miles. For more information and a visual representation, see VA River Healers/Citizen Drone of Union Hill Compressor Station Site.

CONTRADICTORY INFORMATION AS REGULATORS HELP DOMINION

If you wonder why you have seen some many different numbers referring to one compressor station, it is 1) because Dominion keeps changing their story, and 2) this is the third major update to the original application on September 16, 2015 (updates May 25, 2016, August 7, 2017, and May 25, 2018). Due to incomplete information, there have been five additional requests for clarification in 2017 and 2018. In each instance, the Department of Environmental Quality (DEQ) appears to feed information to Dominion Energy and to project consultants so they get future wording and testing correct. Records suggest a close connection between DEQ, Environmental Resource Management (ERM),[1] and Dominion Energy.

PROPOSED REDUCTIONS APPEAR TO BE BASED ON WEAK EVIDENCE

The reductions that are proposed come from Selective Catalytic Reduction (SCR) and Oxidation Catalyst. Modifications to the 2017 application led to increases in SO2 and potentially hexane but suggest control of NOx (estimated 58% reduction), CO (92% reduction), and VOC (50% reduction). There are also claims of a 50% reduction in HAPs. It is not fully clear “reduction from what?” (i.e., from standard practices? from a particular baseline?). NOTE: projections are based on manufacturers’ lab tests with a series of modeling assumptions about temperature, etc. The manufacturer SOLAR clearly states on their technical sheets that they do “not typically warranty the emission rates for VOC, SO2 or formaldehyde.” They include other disclaimers and suggest adding a “significant margin” to estimates. Thus, it is vital that additional and independent testing occurs using more precise place-based data.

LINGERING CONCERNS REQUIRING ADDITIONAL ANALYSIS

  • Toxic formaldehyde and hexane levels remain high.
  • Baseline locations for comparison of air emissions are problematic (e.g., Hopewell, Harrisonburg, Richmond, Charlottesville, Roanoke, etc.). Documents argue they used the best available comparative location for each specific emission under analysis, but circumstances are dissimilar.
  • The projected/estimated reductions of emissions come from manufacturers’ estimations from lab studies and not from any existing compressor facility (i.e., these are “DESIGN VALUES” and “PERFORMANCE PREDICTIONS” only). Some of the NOx reduction technology seems to have only been used on small turbines.
  • The technology proposed is unproven—the Union Hill community is being treated like guinea pigs without Dominion and ACP being clear in public statements that all claims of reductions are hypothetical and not based on actual operation or testing of equipment. There is very little evidence for proposed reductions outside of computerized air models, which have not been independently verified.
  • While claiming use of Best Available Technology, there are emission reduction devises and procedures discussed in Dominion’s Methane Management Report are NOT discussed in the air permit application
  • In answers to requests for information, Dominion admits that they will pollute up to mandated limits (e.g., VOC emission limit of 2.7 tons annually). They suggest they will add expensive additional controls only if and when they approach annual limits. This shows that they have technology available to reduce more, but suggests they prefer to pollute because it is more profitable.
  • If there is a leak of some sort at the compressor station, compressor station operators have 30 days to fix it. They could delay fixing it if they think the shutdown emissions would be greater than the leak.
  • The size of the ammonia tank has increased over time from 8,000 gallons to 13,400 gallons.
  • The air permit does not address the proximity of wetlands and other site impacts deemed irrelevant to an air permit but important when considering overall environmental impact. Will they be addressed in another way or another permit? What, if any, other regulatory processes remain?
  • Who else should be looking at these permits and providing technical support to Friends of Buckingham? Send suggestions to friendsofbuckinghamcountyva@gmail.com.

Additional Information:

Friends of Buckingham, https://www.friendsofbuckinghamva.org/friends/.

Baars, S. 2018. Compressor anxiety: historic African American community alleges environmental racism. C-ville Weekly.

Finley-Brook, M., Williams, T.L., Caron-Sheppard, J.A. and Jaromin, M.K., 2018. Critical energy justice in US natural gas infrastructuring. Energy Research & Social Science.

Martz, M. 2015. Center of the state, Buckingham in middle of pipeline debate. Richmond Times-Dispatch.

McCue, C. 2018. History, health at stake in Buckingham County. Front Porch Blog, App Voices.

McKenna, P. 2018. Atlantic Coast Pipeline faces civil rights complaint after key permit is blocked. Inside Climate News.

McKenna, P. 2018. Public Comments on Pipeline Plans may be falling through the cracks at FERC, audit says. Inside Climate News.

Miles, J. 2017. Supervisors, ACP face suit over compressor station. The Farmville Herald. https://www.farmvilleherald.com/2017/02/supervisors-acp-face-suit-over-compressor-station/.

Page, S. 2017. Virginia county approves massive natural gas compressor over community outrage. Think Progress. https://thinkprogress.org/acp-moves-forward-in-buckingham-186a5b9eeb6c/.

Quillin, M. 2017. Atlantic Coast Pipeline would hurt Black residents most, NAACP says. The News and Observer. http://www.newsobserver.com/news/business/article184597888.html.

Sokolow, J. 2017. Echoes of a dark past at Virginia’s Standing Rock. Huffington Post.


Williams, M.P. 2018.Williams: Dominion pipeline project would devastate historic black community in Buckingham. Here’s why. The Richmond Times-Dispatch.

[1] See this 2017 piece by Itai Vardi on Natural Resource Group, which was purchased in late 2014 by Environmental Resource Management, the ACP project consultants https://www.desmogblog.com/2017/04/02/firm-hired-ferc-review-dominion-atlantic-coast-pipeline-linked-environmental-contractor.

 

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