Urgent: Please submit comments to MassDEP on the vacated AQ permit

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Action Item: Please submit a comment to MassDEP in response to the vacated air permit.

This is very important as we are putting every effort into stopping the nearly finished compressor station from ever operating.  Enbridge knows this is likely to be a "stranded asset," and, sadly, one that will be paid for by the gas ratepayers.  Please help us to make this a very painful lesson for this greed driven company.

On September 8, comments are due to the Department of Environmental Protection (DEP) on the vacated air quality permit. The 1st Circuit Court of Appeals vacated the permit based on one thing--that Enbridge and the DEP did not do the full BACT (Best Available Control Technology) analysis as required.  In this case, they should have explored the use of an electric motor drive (EMD) as opposed to a gas fired turbine.  Enbridge (Algonquin) has had to go back and explain themselves, and the DEP simply rubber stamped their new BACT explanation.  

It's all very complicated, but we have prepared a list of possible questions/comments for you to send into the DEP.  Go here or scroll down to see the list of comments and a sample letter.  Choose one or several--it's up to you!  Instructions on emailing and snail-mailing are at the link above and written below. If you are feeling motivated and adventuresome, here are all of the documents pertaining to this vacated permit at this point.  You can read and make your own questions and comments.  You might even catch them in something we missed!  

In 2017, YOU sent over 1500 comments on the original air quality plan approval. This was amazing! We would love to see you do this again--or even top your last effort!  You are all truly incredible.

Remember, comments must be in the hands of the DEP by 11:59 PM on September 8, 2020.  Emailing is essential, and you can send a back up copy via snail-mail if you want as well. We are counting on you!

Thank you, as ever, for all that you do.

Instructions on how and when to send comments:

Interested parties may submit written comments for a period of thirty (30) days by email to

weymouthcomments@mass.gov or by US mail to MassDEP, Air Permit Section, 20 Riverside Drive, Lakeville, MA 02347.

Public comment is limited to issues in the BACT addendum, specifically:

1. Whether the use of an Electric Drive Motor (EMD) represents Best Available Control Technology (BACT), and

2. Whether the use of an  Electric Drive Motor (EMD) redefines the source in the context of BACT

Comments Due September 8, 2020

In addition to sending an email, we encourage you to send a message via this Sierra Club AddUP campaign. It’s quick and easy — just fill out your contact info, add a personal note (if you want), and hit send!

Potential questions/comments for BACT comment period:

  • The original application stated: 3.1.6. Proposed Compliance Demonstration

As indicated in Table 3‐1, the maximum emission rate for the new turbine during normal operation will be 9 ppmvd of NOX at 15 percent O2 on a 3‐hour average. Since this is a new technology and the resulting NOX emissions are dependent on site‐specific factors, Algonquin and Solar are requesting an extended shakedown period to fully evaluate and tune the new turbine installation to achieve the very low NOX BACT emission rate.

Based on information from the vendor, Algonquin expects a 6‐month shakedown period before the 9 ppmvd technology will be installed and fully operational on the turbine.

Why was this “shakedown” period not addressed in the BACT analysis when the 9 ppmvd for NOX cannot be guaranteed?

  • How is a zero emissions electric motor not BACT? 

  • Why did Enbridge/Algonquin not study battery or flywheel storage for power outages on the electric motor as a part of the analysis? 

  • The Prefiled Direct Testimony of John Heintz, on page 3, refers to “communications in June 2020 with representatives from National Grid. We require copies of those communications and copies of any and all communications between Algonquin and National Grid in order to understand what technical information Algonquin is relying on from NG. (Miyares & Harrington letter, August 4, 2020)

  • Algonquin claims that Calpine  “does not have the capacity to provide the level of service that would be required to power the EMD.” We require the backup information on how Algonquin arrived at this statement.  (Miyares & Harrington letter, August 4, 2020)

  • What is National Grid’s unit cost to install an underground 13.8-kV transmission line?  (Miyares & Harrington letter, August 4, 2020)

  •  Where is the map that shows the transmission line routes from Calpine to the compressor station?  (Miyares & Harrington letter, August 4, 2020)

  • The gas fired turbine requires electricity to run.  Algonquin needs to supply the following information:  origin point; length of the conductor from the origin point to the Compressor Station; route of the conductor ; whether the conductor is an overhead transmission line or undergrounded; and the type (e.g. 477AAC), voltage, and amperage rating of the conductor.  (Miyares & Harrington letter, August 4, 2020)  

  • Algonquin must explain whether and to what extent National Grid will be responsible for any costs referenced in the EMD BACT Analysis for electric power supply infrastructure including interconnection with the proposed Compressor Station.This must include all D.P.U.-approved and other National Grid documents relevant to those costs and calculations, including the relevant D.P.U.-approved tariff and National Grid connection terms and conditions.  (Miyares & Harrington letter, August 4, 2020)

  • In the 2018 BACT analysis, Algonquin used the Massachusetts statewide industrial retail natural gas rate (in 2015 dollars, $11.34/MMBtu) when calculating BACT costs. In the EMD BACT Analysis, however, Algonquin changes that price assumption to what appears to be the wholesale rate--a much lower rate: $3.04 MMBtu. What is the rationale for using a different rate?   (Miyares & Harrington letter, August 4, 2020)

  •  We require confirmation from Algonquin that the Spartan EMD it proposed for the Weymouth Compressor Station includes an input transformer and request that Algonquin supply 13.8 kV distribution voltage, available from the Calpine substation, to the input transformer.  (Miyares & Harrington letter, August 4, 2020)

  • Algonquin calculated certain electrical grid efficiency losses as part of its EMD BACT analysis. Algonquin did not calculate any analysis of natural gas pipeline transmission losses, including in the form of compressor station power demand and natural gas consumption at compressor stations from the source of the natural gas to Weymouth. We require such an analysis.   We require from Algonquin the gearbox efficiency for the Solar Taurus 60 combustion turbine proposed for the Weymouth compressor station.  (Miyares & Harrington letter, August 4, 2020)

  • The BACT Analysis states that installing an electric motor drive (EMD) instead of a natural gas-fired turbine would “cause substantial upstream air emissions” (p. 4-8), and that “natural gas delivery to the Maritimes system would cease during a power outage, preventing the delivery of natural gas from south of the compressor station to points north” (p. 4-7). Since the Solar 60 is also reliant on electric power, how would this be any different should the power go out using the gas turbine?  What back up plans for power does Algonquin have in the case of a power outage in general? Does not Algonquin have generators on-site?  (Miyares & Harrington letter, August 6, 2020)

  •  Did Algonquin consider onsite solar or other behind-the-meter generation       options in order to mitigate natural gas delivery disruptions during a power outage and upstream emissions? (Miyares & Harrington letter, August 6, 2020)

  • The EMD BACT Analysis states that “electric driven compression would necessitate the construction of a new building, electric substation, and ancillary equipment within TGP’s existing CS 261 site.” (Appendix A, p. 8 of 50). We would like proof of this statement and all capital costs involved. (Miyares & Harrington letter, August 6, 2020)

  • The BACT analysis states “[g]iven the existing facilities on the site, the only location where these facilities could be located would be in the southwest portion of the site, which has a large wetland system associated with Worthington Brook” (Appendix A, p. 8 of 50). Where is the proof of this statement?  Is there another possible location for these facilities? (Miyares & Harrington letter, August 6, 2020)

  • The Right of Way land purchase cost for the transmission line is listed as $619,460 (  (Appendix C, Table 2). How was this figure arrived at? (Miyares & Harrington letter, August 6, 2020)

  • The analysis states that the medium voltage line at the Weymouth station will cost $693,764 (Appendix C, Table 2). How was this cost arrived at? (Miyares & Harrington letter, August 6, 2020)

  • In multiple instances in the Addendum, Algonquin states that the compressor is needed to raise the pressure of the gas from the I-9 to the I-10 (Maritimes & Northeast).  And yet, Algonquin has been successfully shipping gas northward on the I-10 for the past three years.  So why is this pressure increase necessary?

  • From page 4-7of the Addendum: “In considering an EMD option initially, Algonquin concluded that the installation of the required infrastructure would significantly impact the project schedule and thereby not meet the delivery needs of the Project Shippers. Also, the electricity rates are significantly higher than wholesale rates for natural gas that is already available at the Facility site, and therefore are not compatible with the existing Atlantic Bridge Project contract requirements.”  In this new analysis (Addendum) Algonquin does not consider the contracts already lost due to the protracted fight against the placement of this station and the relative worthlessness of gas in these economic times. The delivery needs of the Project Shippers, therefore, no longer apply.  Please also supply the wholesale electrical rates along with the current wholesale gas rates. 

  • On page 4-7 of the Addendum it states: “Algonquin proposes to install one Solar Taurus [70] gas-fired compressor unit providing the necessary horsepower to meet the pressure requirements for the required deliveries into the Maritimes system. To ensure system reliability, the gas turbine will be equipped with an emergency generator that is fueled by the same gas that the turbine is compressing, and sufficiently sized to run the compressor station in the event of an electrical outage.”  All other references to the Solar Taurus turbine are for the Solar Taurus 60 turbine with an output of 7700 HP, not the Solar Taurus 70 which has a beginning output of 9500 HP.  Please clarify the discrepancy.  The numbers for the Solar Taurus 70 are significantly different than those for the Solar Taurus 60.

  • Page 4-7 of the Addendum states: “The Facility will provide critical compression needs and a step-up in pipeline pressure for reliable delivery to the Maritimes system. If Algonquin were to install an EMD, then natural gas delivery to the Maritimes system would cease during a power outage, preventing the delivery of natural gas from south of the compressor station to points north.” How often in the 20 years of service of the I-9 and I-10 in Weymouth has the power been disrupted? Has it affected the ability of the metering and regulating station in the same area from operating? 

  • Underground transmission has a significant higher cost than above ground lines. Can you please provide routes & costs of 13.8-kV & 115kV above ground lines by National Grid and Algonquin.

  • How can you say that an electric motor option is too costly when you have not outlined all of these options including above ground transmission?

 

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 SAMPLE LETTER:  

DATE

 MassDEP

Air Permit Section

20 Riverside Drive

Lakeville, MA  02347


To Whom it May Concern,

I am writing today to comment on the BACT analysis for the EMD alternative for the Weymouth compressor station.  I am aware that the air quality permit issued by your department in January of 2019 was subsequently vacated in June of 2020 for lack of appropriate BACT analysis.

My comment/question is specifically this:  From page 4-7 of the Addendum: “In considering an EMD option initially, Algonquin concluded that the installation of the required infrastructure would significantly impact the project schedule and thereby not meet the delivery needs of the Project Shippers. Also, the electricity rates are significantly higher than wholesale rates for natural gas that is already available at the Facility site, and therefore are not compatible with the existing Atlantic Bridge Project contract requirements.”  In this new analysis (Addendum) Algonquin does not consider the contracts already lost due to the protracted fight against the placement of this station and the relative worthlessness of gas in these economic times. The delivery needs of the Project Shippers, therefore, no longer apply.  Please also supply the wholesale electrical rates along with the current wholesale gas rates. If comparisons are to be made, the data must be clear. 

I do not believe that the Addendum clearly proves that the Electric Drive Motor (EMD) is not the Best Available Technology for the Weymouth compressor station. 

Sincerely,

Your Name 

Your Address