Unfortunately, the fight against the compressor station is not over yet. The Maryland Department of the Environment (MDE) has interpreted the law in a way that allows them to override our recent zoning decision victory. Of course AMP Creeks will fight that interpretation, but while that battle moves forward, if MDE does decide to approve the project, construction will mostly likely begin this summer. Even before the Charles County zoning decision, the MDE had issued a draft air permit for the station.
We need your help to make sure this draft decision doesn’t become final. Convincing MDE to deny the air permit is critical because the Federal Energy Regulatory Commission (FERC) cannot override (preempt) MDE if they deny the permit.
The MDE public hearing will be held on Wednesday, March 28 at 6:30pm at the Bryans Road Volunteer Fire Department, and the most important steps we can take right now are to have a big community turnout at the hearing with lots of people testifying and submitting comments. This is our best shot at stopping the project.
To learn more about the hearing and what you can do to help, please attend an organizing meeting at the Moyaone Association Community Center on this coming Sunday, March 25th, at 2:00pm. The Moyaone Public Affairs Committee and AMP Creeks Council will review the air permitting process, the flaws in the air application and draft air permit, and tips for effective oral and written testimony during the public comment period.
We’ll also have flyers for the hearing in case you can help distribute them. If you know in advance that you are interested, please contact Kelly at email@example.com to sign up.
Here are some talking points that you can use as you work on your oral or written testimony:
- MDE should not be rushing to approve this application. Only four days after they received Dominion’s most recent supplemental information, they released their tentative determination of approval. They should have taken more time to consider the material, and give deference to the decision made by the local zoning authority (the Charles County Board of Appeals). For MDE to give tentative determination so quickly after highly questionable and technical supplemental data was submitted by Dominion is a red flag.
- MDE should provide an opportunity for cross examination of witnesses. Dominion has submitted two contradictory air modeling statements. We need an opportunity to cross examine their expert witnesses. This is the best way to learn the truth about the inconsistencies in their application.
- 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 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 include huge spikes of pollution during “blowdowns” when the station is depressurized and air pollutants are shot out of the station at great speeds and in great quantities. Dominion estimates that these events, which include start-ups and shut-downs of the plant, would occur on about one third of the days in each year, plus unplanned emergency blowdowns. During those times we would be exposed to extremely high spikes of pollution that can cause acute health effects.
- The air permit application and draft permit do not include the blowdown emissions in the estimated emissions, so we have no way of measuring whether Dominion will be in compliance with federal air limits during blowdowns, which will be frequent.
- 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, and may go unnoticed if the gas isn’t odorized. Dominion is given thirty days to fix leaks, meaning we 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 couldn’t monitor their fugitive emissions, and that they shouldn’t have to.
- The air pollution in our community would be worse than for many other communities near compressor stations because this would be a particularly large compressor station (larger than all compressor stations in New York, for example), the station would be located in a geographic depression where pollution can collect, and the smoke stack height was lowered from 83 feet to 50 feet.
- Dominion’s lowered, proposed stack height of 50 feet is the same height as 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 has created rules that tell companies how tall their stack heights have to be to avoid this phenomenon. 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 stack height should be 125 feet. Dominion’s stack height is 75 feet lower than the recommended height, which means the downwash increase in ground level pollution will be severe. Dominion also did not release its electronic air modeling files, so we do not know how the downwash affects the air modeling and anticipated emissions.
- MDE is not necessarily capturing the worst case scenario for this project, which is especially problematic given how close to the legal limit for some air pollutants they are. 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 compressor station could emit an illegally high nitrogen dioxide (NO2) level. 188 is the one hour NO2 acceptable standard. In their original application, Dominion reported their predicted NO2 concentration would be 177. In their recently submitted supplemental information, they changed it to 129. It is unclear why those numbers are so different since the project has not changed. In MDE’s tentative approval of the project, they estimate the number at 181.5. Modeling uncertainty is +/- 30%.
- The EPA has required that the NO2 levels not be exceeded for purposes of public health. People with existing health problems (such as asthma and respiratory illnesses), would be in a lot of trouble. Some studies already question the sufficiency of the standards. If you or a family member has pre-existing health problems, please raise them in your testimony. You would be hit extra hard by this pollution.
- MDE should conduct a health impact assessment to determine the predicted health impacts for the local population.
- This region is not in compliance with the federal ozone standards, and this project would make the air pollution and related health problems worse.
- The 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 (VOC), 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. Health impacts are considered on a one-by-one pollutant basis. Dominion and MDE fail to assess the additive impacts of exposure to multiple pollutants (e.g., PM2.5, ozone, NO2) on the health of sensitive individuals including the very young, the elderly, pregnant women, and those with pre-existing conditions. The standards also do not look at the potential synergistic effects of different pollutants.