FRRACS demands FERC to deny Enbridge's in-service request
/We have submitted a letter on the FERC docket, demanding that they refuse Enbridge's request to place the facility in-service. You can read the letter here and below.
September 17, 2020
Ms. Kimberly D. Bose, Secretary
Federal Energy Regulatory Commission
888 First Street, NE
Washington, DC 20426
Re: Algonquin Gas Transmission, LLC, Docket No. CP16-9-000, demand to refuse
Request to Place Facilities In-service
Dear Secretary Bose,
On September 16, 2020, Algonquin Gas Transmission filed a request to place facilities in-service, including the Weymouth compressor station. They seek authorization by September 24, 2020 in order to start shipping on October 1, 2020. We demand that your office refuse this request for the Weymouth compressor station for the following reasons:
• On Friday, September 11, 2020 a gasket failed on the sump tank of one of the inlet filter separators being tested by Enbridge, resulting in line pressure gas venting at ground level into the surrounding community. Enbridge has reported to the Massachusetts Deptartment of Environmental Protection (MassDEP) that this leak resulted in 265,000 scf of gas and 35 pounds of Volatile Organic compounds (VOCs) seeping into the surrounding community’s ground-level air. No investigation or report has been filed on this failure, no report has been filed on how much of the 265K scf was released at ground level, and no report has been filed as to the completion of repairs to this failed gasket and sump.
• In the most recent version of the air permit (May 2018) submitted to MassDEP, Algonquin lists the maximum natural gas release rate as 20,000 scf per hour. Per the Sept 3 Enbridge notification, the planned Emergency Shutdown test would have released gas at a rate of 1,590,000 scf / hour. This has potential implications for safety and Algonquin needs to explain why there is such a substantial discrepancy between the application and the actual operation of the facility and file a corrected application. Such a correction could force MassDEP to revisit the plan approval, thus negating the air quality permit.
• Based upon the average hourly composition of natural gas provided by Algonquin for their May 2018 application update, the amount of VOCs released in a 265,000 scf emergency shutdown event would be 264 pounds. Since these simple calculations are based solely upon data provided by Algonquin, they and MassDEP need to clarify why the quantities of VOCs Enbridge claims are released with a 200,000 - 265,000 scf gas released are an order of magnitude smaller than what would be expected from their application. Again, Algonquin needs to explain this gross discrepancy and change their air quality application.
• The Best Available Control Technology (BACT) decision by the MassDEP will not be complete until September 29, 2020. Should either Algonquin or the Petitioners be dissatisfied with the decision, the complete BACT appeal will not be finished until January 19, 2021. Algonquin could be forced to change their source and, thus, would be shut down to reconfigure the station. Operation at this time would be premature.
• No safety or risk analysis has ever been done on this location. FERC has been notified on innumerable occasions that this compressor is situated in a hurricane inundation zone, a FEMA flood zone, an Environmental Justice neighborhood, and is too close to critical infrastructure to be insurable under industry standards. Without a safety and risk analysis, this compressor presents a clear and present danger to the residents and the commercial industries of the Fore River Basin. As a Designated Port Area and a critical region for oil and gasoline delivery to much of eastern MA, NH, RI, and parts of CT this compressor also creates a danger to the shipping channel.
• New England NG and Exelon have sold a substantial amount of their contracts for the gas to National Grid. National Grid states that they do not need the Weymouth compressor in order to fulfill their gas deliveries in their 14-year plan to the MA Department of Public Utilities. The Goldboro NS LNG facility where close to 62% of the gas was to be shipped has never broken ground and may have its financing collapse by September 30, 2020.
As FERC has failed, since the time of pre-filing in 2015 until the present date, to properly vet the siting of the Weymouth compressor station and has failed further to consider the lack of necessity for the delivery of the gas through this compressor, our demand must be considered by The Commission.
Thank you.