Buckingham CountyCompressor StationAtlantic Coast PipelinePOLLUTION REPORT:Unfair, Illegal and UnjustTechnical Report No. 16-342December 2016
1Blue Ridge Environmental Defense LeaguePO Box 88 Glendale Springs, NC 28629(336) 982-2691BREDL@skybest.comwww.BREDL.orgOne person speaking alone may not be heard,but many people speaking with one voice cannot be ignored.Janet Marsh, Founder
2Table of Contents·Executive Summary3·Overview/Facility4·Air Pollution6·Noise Pollution9·Zoning12·Environmental Justice13
3Executive SummaryNoise and air pollution from natural gas compressor station, as revealed in this report, wouldplace a disproportionate impact on minority communities in Buckingham County.Locating a compressor station in a rural district would violate the county zoning ordinance. Thelist of permitted uses in the A-1 District does not include compressor stations nor does it includeenergy facilities. A compressor station is not a “public utility generating plant,” a “public utilitybooster station” nor any other category of permissible special use.Unwanted, unpleasant noise is a growing public health problem. Industrial sources of noisecommonly disrupt communities. Disturbing levels of sound become a medical issue when thenoise interferes with normal activities and the quality of life. Being unable to sleep or to have anormal conversation for extended periods or at recurring intervals creates stress. Theseconditions lead to acute, chronic and long-term problems. The economic considerations ofindustrial special interest groups cannot be allowed to take precedence over the right to be securein one’s home.Compressors operate 24 hours a day, 365 days a year. During the winter, natural gas poweredturbines can emit many times more pollution. On average, at low temperatures the combustionturbines at the Buckingham Compressor Station would emit 13 times as much nitrogen oxides, 6times as much carbon monoxide, and 2 times as much volatile organic compounds. Pollutioncontrols are unreliable. Lean-burn engine technology proposed for the Buckingham compressorwould have wide variations in nitrogen oxide and carbon monoxide emissions depending on theload placed on the turbines. The state air permit would allow dangerous levels of hazardous airpollutants formaldehyde and hexane. Over two and a half tons of formaldehyde and a half-ton ofhexane would be emitted from the compressor station every year.The Buckingham County Planning Commission convened a public hearing at which manypeople spoke and multiple issues were raised, including toxic air pollution, objectionable noise,environmental justice and others. People from Union Hill, Union Grove and many othercommunities spoke at public hearings and public comment sessions, providing the county with adetailed justification for rejecting the application by Atlantic Coast Pipeline, LLC for a SpecialUse PermitVirginia statutes governing energy development clearly support environmental justice. Thepolicy of the Commonwealth is to “ensure that development of new, or expansion of existing,energy resources or facilities does not have a disproportionate adverse impact on economicallydisadvantaged or minority communities.” The Virginia General Assembly enacted this law toprotect family life and public health in residential areas. Buckingham County must go back andimplement the law which protects its residents from obnoxious noise and toxic air pollution.
4Overview of Combustion Turbine CompressorCombustion TurbinesA natural gas turbine is an internal combustion engine. The turbines burn natural gas fuel at hightemperature and the turbine blades convert the heat energy into mechanical power. The turbinesturn a shaft which is attached to mechanical compressor units, increasing natural gas pressure tomove it through the pipeline. The components of a natural gas turbine include a compressor, acombustor, a turbine, an output shaft, and exhaust. The turbine manufacturing company for theproposed Buckingham facility describes their operation:The compressor takes in outside air and then compacts and pressurizes the air moleculesthrough a series of rotating and stationary compressor blades. In the combustor, fuel isadded to the pressurized air molecules and ignited. The heated molecules expand andmove at high velocity into the turbine section. The turbine converts the energy from thehigh velocity gas into useful rotational power though expansion of the heatedcompressed gas over a series of turbine rotor blades. Rotational power from the turbinesection is delivered to driven equipment through the output shaft via a speed reductiongearbox. The engine’s exhaust section directs the spent gas out of the turbine sectionand into the atmosphere.1Figure A. Single Shaft Gas TurbineCombustion turbines are remarkable for their lack of efficiency in converting chemical energy tomechanical energy. Regardless of its end use, a combustion turbine must have an inputcompressor to raise the pressure of the air-fuel mixture. Energy output is reduced because intake1Solar Turbines website at https://mysolar.cat.com/en US/products/gas-turbine-overview.html
5air is compressed up to 30 atmospheres of pressure. Accordingly, according to the USEnvironmental Protection Agency, “More than 50 percent of the shaft horsepower is needed todrive the internal compressor and the balance of recovered shaft horsepower is available to drivean external load.”2Under normal conditions, a simple cycle unit’s thermal efficiency ranges from 15 to 42 percent.As a result, from 58 to 85 percent of the fuel burned produces no power. But air pollution andglobal warming gases are created by combustion whether power is produced or not.The Proposed Buckingham Compressor StationInformation in the original application submitted by Atlantic Coast Pipeline listed the centralpower plant equipment manufactured by Solar Turbines, Inc. as follows:(CT-01) Mars 100 Combustion Turbine(CT-02) Taurus 70 Combustion Turbine(CT-03) Taurus 60 Combustion Turbine changed to a Titan 130(CT-04) Centaur 50L Combustion TurbineOn June 17, 2016, Atlantic Coast Pipeline, LLC and Dominion Transmission, Inc. submitted asupplemental filing to Virginia DEQ indicating a change in Combustion Turbine Unit 3 (CT-03),substituting a Titan 130 for the Taurus 60. No other changes were submitted. The new unit wasmuch larger than the first, raising overall power of the compressor station by 30%.Table 1. Buckingham C2 Station Turbine Power RatingsTurbine TypeEmission Unit RatedNominal Output Nominal OutputManufacturer: SolarHorsepower3 Horsepower4Kilowatts4Mars 100CT 0117,57415,90011,860Taurus 70CT 0211,88210,9158,140Titan 130CT 0321,76520,50015,290Centaur 50LCT 046,6426,1304,570Capstone C200 (10 units) MT-01–MT-102,680n/a2,000Totals 60,54353,44541,860See Appendix A for detailed listThe power rate of the original application’s four-unit compressor station was listed by thecompany at 44,512 horsepower. With the substituted turbine Unit 3, the four-unit BuckinghamCompressor Station increased to a total of 57,863 horsepower. Also, the permit application liststen additional turbines which would burn natural gas to generate on-site electrical power. Eachof these units is rated at 200 kilowatts (268 hp), for a total power of 2,000 kW (2,680 hp).2US EPA Air Pollution Emission Factors, AP-42, Stationary Gas Turbines, Section 3.1.2 Process DescriptionTable C-1 Permit to Construct Application Project Equipment List, ACP Buckingham Compressor Station,Updated Air Permit Application, June 17, 2016, submitted to Virginia Dept. of Environmental Quality4Solar Turbines, Inc. corporate brochure, “Compressor Set/Mechanical Drive Specifications”3
6Air PollutionAtlantic Coast Pipeline, LLC and Dominion Transmission, Inc. want to build a series ofcompressor stations to move gas through the Atlantic Coast Pipeline. Atlantic Coast Pipeline,LLC submitted an air permit application for the facility in Buckingham County which wasreceived by the Virginia Department of Environmental Quality Blue Ridge Regional Office onSeptember 17, 2015. ACP’s application to DEQ indicates the plant would emit huge levels of airpollution:Table 2. Estimated Annual Emissions5PollutantAnnual Emissions(pounds/year)Nitrogen oxides (NOx)100,400Carbon monoxide (CO)190,400Sulfur dioxide (SO2)14,600Volatile organic compounds (VOC)65,400Particulate matter (PM)87,800Hazardous air pollutants (HAP)9,940TOTAL468,540Greenhouse gas (CO2e)647 millionThese air pollution levels are estimates. The actual emissions can be affected by many things,including weather conditions, operator ability, control devices, regulations and load factors.At very low load and cold temperature extremes, the turbine system must be controlleddifferently in order to assure stable operation. The required adjustments to the turbinecontrols at these conditions cause emissions of NOx, CO and VOC to increase(emission rates of other pollutants are unchanged).6Compressors operate 24 hours a day, 365 days a year. During the winter, natural gas poweredturbines can emit many times more pollution. Temperature condition considered extremeaccording to ACP are between -20 degrees F. and 0 degrees F., occurring no more than 50hours/year. The air permit application shows a very large multiplication of emissions duringsub-zero temperatures, for the four units averaging 13.45 times higher levels of NOx, 5.85 timeshigher levels of carbon monoxide (CO) and 1.95 times higher levels of volatile organiccompounds. Occurring for 50 hours per year, as estimated by the company, would be 5.7% ofthe operating time operating at excessive levels of air pollution emissions. 7In the permit application, ACP claims that the Buckingham Compressor Station will not besubject to federal Clean Air Act acid rain regulations because it will not sell electricity andtherefore “is a non-utility facility.”85Table C-9 Project Potential Emissions, ACP Buckingham Compressor Station, updated permit applicationsubmitted to Virginia DEQ on June 17, 2016 by Dominion Transmission, Inc.6Buckingham Compressor station air permit application 9/17/15, page 6-77Buckingham Compressor station air permit application 9/17/15, Table 3.2, page 78Buckingham Compressor station air permit application 9/17/15, Section 4.7, page 19
7The Buckingham Compressor Station would emit 647 million pounds of carbon dioxide andother global warming pollutants every year of operation.Many types of pollution-causing equipment are exempt from state regulations. According to theair permit application for the proposed Buckingham plant, exempt equipment would include:WH-01LH-01–04MT-01–10One 9.5 MMBtu/hour (million British Thermal Unit per hour) boilerFour line heaters each rated at 17 MMBtu/hourTen Capstone C200 Microturbines each rated at 200 kilowattsThe air permit application proposes to use a lean combustion control technology—calledSoLoNOx—on the four main compression turbines, Units CT-01, CT-02, CT-03 and CT-04.Also, ACP proposes to use selective catalytic reduction (SCR) technology to help controlnitrogen oxide emissions (NOx). To control carbon monoxide emissions (CO), the companyproposes to use operator-managed “good combustion practices” and oxidation catalysttechnology.Air pollution emissions can vary, sometimes greatly, depending on the operating work loadplaced on the turbines. The US Environmental Protection Agency compiles pollution data foralmost all fuel burning engines in its AP-42 database. The information published there states:Available emissions data indicate that the turbine’s operating load has a considerableeffect on the resulting emission levels. Gas turbines are typically operated at high loads(greater than or equal to 80 percent of rated capacity) to achieve maximum thermalefficiency and peak combustor zone flame temperatures. With reduced loads (lowerthan 80 percent), or during periods of frequent load changes, the combustor zone flametemperatures are expected to be lower than the high load temperatures, yielding lowerthermal efficiencies and more incomplete combustion.9For example, lean-burn pollution control technology selected by ACP for Buckingham wouldallow wide variations in nitrogen oxide (NOx) and carbon monoxide (CO) emissions dependingon the load placed on the turbines by the compressor. US EPA emission factors for this type ofengine (presented in pounds/million BTU heat input) indicate the following:PollutantNOxCOHigher Loads0.09910.0151Lower Loads0.1111.27Increase12%2,490%The comparison of emissions at high and low operating loads indicates more pollution when theplant capacity drops below 80%. For carbon monoxide, the increase is very large. This showsthat the plant runs dirtier for some compounds at low operating loads. On the other hand, certainemissions increase at higher operating loads. The comparison on the following page indicatessignificantly more xylene and toluene pollution when the turbines run above 80% capacity (againpresented in pounds/million BTU heat input):9US EPA AP-42, Section 3.1, Stationary Gas Turbines, Subsection 3.1.3 Emissions
8PollutantXyleneTolueneLower Loads0.00005480.0000937Higher Loads0.00006380.000134Increase 16% 43%Still other factors may cause wide variations in pollution; for nitrogen oxides, emissionvariations of 30% or more are caused by changes in humidity and temperature.10Hazardous Air Pollutant Emissions: Formaldehyde and HexaneThe permit application provides estimates of hazardous air pollutants: formaldehyde and hexane.Over two and a half tons of formaldehyde would be emitted from the four turbines, boiler andheaters every year.EmissionPoint IDCT-01CT-02CT-03CT-04WH-01LH-01—04TOTALTable 3. Hazardous Air Pollutant onspounds/yearpounds/yearCompressor Turbine (100)1,635Compressor Turbine (70)1,101Compressor Turbine (130)1,984Compressor Turbine (50L)688Boiler6146Line Heaters111,0485,4251,194Formaldehyde vapors are highly irritating to the eye and respiratory tract. Formaldehyde causesnausea, headaches, and difficult breathing. Formaldehyde can also cause or aggravate asthma.The US EPA has classified formaldehyde as a “probable human carcinogen” (Group B1). Thecompressor would have many emission points releasing formaldehyde.For decades n-Hexane, an isomer of hexane, has been identified as a peripheral neurotoxin,poisonous or destructive of nerve tissue.12 Isomers of hexane are classified as chronic toxicantsand irritants. Toxic hexane exposure symptoms include numbness and paresthesia, “pins-andneedles,” of the hands and feet. Chronic hexane exposure produces a gradual loss of motorfunction.For this report, Blue Ridge Environmental Defense League ran a US Environmental ProtectionAgency computer model to determine the actual levels of formaldehyde and hexane which wouldbe in the air around the proposed Buckingham compressor station. The map below marks theproposed compressor station site with a yellow tringle. The circle is superimposed on the map ata distance of 2,000 feet from the site. According to the permit application, the Buckingham10US EPA AP-42, Section 3.1, Stationary Gas Turbines, Subsection 188.8.131.52 Nitrogen oxidesProposed Permit Limits for Toxic Pollutants/HAPS, ACP Buckingham Compressor Station, updated permitapplication, Appendix B page 23, submitted to Virginia DEQ June 17, 2016 by Dominion Transmission, Inc.12Yamada S. “An occurrence of polyneuritis by n-hexane in the polyethylene laminating plants” Jpn J Ind Health1964;6:19211
9County ACP-2 Compressor Station would be located at coordinates 37 35'23.29"N78 39'31.48"W (37.589803, -78.658744)Figure B. Proposed Buckingham Compressor Station SiteSee surrounding area map attached as Appendix BThe results of our modeling exercise reveal high levels of formaldehyde out to a distance of1,640 feet (500 meters) from the plant site, and high levels of hexane 246 feet (75 meters) fromthe site. The impacts on residents within this distance would be at special health risk fromchronic exposure to toxic air pollution. The detailed modeling results are attached to this reportas Appendix C.Noise PollutionThe high pressure operation of compressors makes them painfully noisy up close:The basic noise sources are caused by trapping a definite volume of fluid and carrying itaround the case to the outlet with higher pressure. The pressure pulses fromcompressors are quite severe, and equivalent sound pressure levels can exceed 105dB. 1313Occupational exposure to noise: evaluation, prevention and control, Edited by Berenice Goeltzer, Colin H.
10How distance affects the impact of a source of noise varies. Sound can travel longer or shorterdistances depending on the medium through which it moves. For example, sound travels at768 miles per hour in dry air and at 3,300 mph in water. Experts have determined that disruptivesound levels can travel far from the source and over natural and artificial barriers such as treesand walls.The atmospheric effects become most important at distances beyond about 1000 feetfrom the source.The normally humid environment in the southeastern US allowssound to travel further with less reduction in level. Downwind and under many nighttime conditions (cooler air near the surface), sound waves that start upward will benddownward. Thus, the noise reduction benefits of barriers can be negated by theseatmospheric effects.14Thus, although sound generally decreases with distance, under some circumstances noisepollution can have higher impacts at greater distances.Negative Health Effects of Noise15Public Health DangerDisturbing levels of sound become a medical issue when the noise interferes with normalactivities and the quality of life. Being unable to sleep or to have a normal conversation forextended periods or at recurring intervals creates stress. These conditions lead to acute, chronicHansen and Gustav A. Sehrndt, Published on behalf of the World Health Organization by the Federal Institute forOccupational Safety and Health, Dortmund, Germany, WHO, 2001, ISBN 3-89701-721-0, page 11014Evaluation of Environmental Sound in the Community, Stewart ND, Ph.D. FASA FASTM (July 23, 2011), page 3,downloaded 1/16/15 from http://www.sacnc.com15“Environmental Noise Pollution in the United States: Developing an Effective Public Health Response,” MonicaS. Hammer, Tracy K. Swinburn, and Richard L. Neitzel, Environmental Health Perspectives,” Vol. 122, No. 2,February 2014, pp. 115-119
11and long-term problems. And the negative impacts of noise pollution on human health can beserious.Chronic environmental noise causes a wide variety of adverse health effects, includingsleep disturbance, annoyance, noise-induced hearing loss, cardiovascular disease,endocrine effects, and increased incidence of diabetes.16Natural gas compressor stations operate 24 hours a day, 365 days a year. Chronic noise pollutioncan cause ill health effects, including high blood pressure, ulcers, colitis and asthma. Federallaws and regulations attempt to reduce this risk to public health, but state and local governmentsalso have a responsibility to curb noise pollution. Too often, noise pollution from industrialsources is not controlled. For, example, in a Pennsylvania community the owner of a home witha compressor station 3,000 feet away reported, “You lay in bed, you can hear this thing running.It sounds like a truck in the driveway, 30 feet away.” In another community, where a natural gascompressor station had just been brought on-line, the plant neighbors started complaining aboutthe noise. Ambient noise levels in this rural area were measured between 43 and 46 decibels(dBA) at night.Buckingham County Special Use PermitThe Buckingham County Planning Commission has approved a special use permit for the ACP-2Compressor Station. If approved by the Board of Supervisors, the compressor would be allowedto generate 55 decibels at the property line or any adjacent buildin
5 Table C-9 Project Potential Emissions, ACP Buckingham Compressor Station, updated permit application submitted to Virginia DEQ on June 17, 2016 by Dominion Transmission, Inc. 6 Buckingham Compressor station air permit application 9/17/15, page 6-7 7 Buckingham Compressor station air permit application 9/17/15, Table 3.2, page 7
I4 Compressor 2 ready I5 Compressor 3 ready I6 Compressor 4 ready I7 MOS activated Q1 Turn on compressor 1 Q2 Turn on compressor 2 Q3 Turn on compressor 3 Q4 Turn on compressor 4 Q6 Turn off compressor 1 Q2 Turn off compressor 2 Q7 Turn off compressor 3 Q8 Turn off compr
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1 The ACP includes three compressor stations and at least 564 miles of pipeline across West . the Blue Ridge Environmental Defense League (“BREDL”), and its . (Faber, VA), Concern for the New Generation (Buckingham, VA), Halifax & Northampton Concerned Stewards (Halifax and Northampton, NC), No Pipeline Johnston County (Johnston, NC .
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