In Your Opinion: Transco Continues Misleading PR Campaign Regarding Compressor Toxins
By Kirk Frost.
Transco has recently been publishing to newspapers, twitter and media releases in a mad dash to squash the significant and growing number of public input (greater than 2,500 people) that has raised serious issues regarding chemical emissions, environmental impact and long term chronic health impact to the Federal Energy Regulatory Commission (FERC). Transco persistently makes claims that contradict their own application data – even to the extent of claiming that 25 years out there will be no contamination in the local water. As will be laid out in this article, using data Transco has provided to FERC, it will become clear to readers how this claim is impossible.
In a recent article to the Franklin Reporter and Advocate, Transco spokesperson Christopher Stockton states that the proposed compressor station “would not negatively affect water quality.” Stockton adds that the regulatory and permitting process is “robust, protecting the health and safety of the public.”
Both of Stockton’s comments are misrepresentative of the facts and contradict what Transco identifies in the FERC application submission. Included below are tables extracted from Transco’s application file 28_Vol_1_NESE_Resource_Report_9_air-LARGE-20170327-5102(32053902).pdf on pages 47-48 and page 122. Original file can be found on FERC (Full Application, File 28). From these tables, it is clear that annually, the proposed compressor station will emit on a continual basis, literally tons of chemicals into the air. Many of these chemicals are most toxic when airborne and since heavier than air and initially contaminate the surrounding air and will eventually contaminate the nearby soil and water. Nearby is defined as 10 to 15 mile radius depending on weather patterns.
Since the emissions of these chemicals are primarily through the natural gas combustion exhaust from the compressor turbines, the chemicals are launched into the air out of 2 50’ smokestacks (each 8 feet in diameter) at a rate of 210,000 cubic feet per minute, below is a snapshot from Transco File 28 page 48.
Note: Based on documents provided by Transco, the actual run states demonstrate that the Exhaust temperature is actually higher than the temperature reported on page 48. This can be found on page 105 of File 28, where Transco includes the run-states for the 2 MARS100 turbines and denotes temperatures greater than 900°F at the top of the smokestack.
On pages 47-48 and page 122 of File 28, Transco posts ‘estimated’ emissions of chemicals. To date across all of the Transco projects, I have not seen any independent validation of the emission quantities for any of the MARS 100 turbines installed by Transco. Since the run-states are higher than the estimates, there is a likelihood that the chemical emissions are also higher.
Estimated Emissions supplied from Transco
Estimated emissions from proposed compressor, in tons per year (tpy), for:
CO = 56.86tpy; NOx = 22.74tpy; VOC = 8.35tpy; PM10 = 18.94tpy; PM2.5 = 18.94tpy;
SO2 = 3.07tpy; GHG (natural gas) = 132,720tpy.
Estimated caustic chemical emissions, in pounds per year (lbs/yr), for:
Formaldehyde= 660lbs/yr; Ammonia = 29,580lbs/yr; HCHO3 = 320lbs/yr; Acrolein = 6lbs/yr;
Acetaldehyde = 44lbs/yr; Ethylbenzene = 34lbs/yr; Benzene = 14lbs/yr; Toluene = 142lbs/yr;
Propylene Oxide = 32lbs/yr; Xylenes = 70lbs/yr.
Contrary to Transco’s supposition that regulatory and permitting process being robust, Transco’s misleading and inaccurate claims are not fact-checked unless the public pushes FERC and State agencies to validate. Additionally, the permitting process does not even review the chemical emissions mentioned above, since the estimated emissions are for one year only and do not meet toxic thresholds. However, if FERC were to review accumulative emissions over even 10 years for Benzene, for example, FERC would find that Benzene accumulative emission would exceed the hazardous toxic threshold easily. None of this is taken into consideration at the state or federal permitting levels.
As seen throughout the application process, Transco ‘fudges’ numbers, images and descriptions so as to appear benign. To date, we have identified actual false and misleading statements from Transco in their submissions and PR campaign. One example is that in the application, Transco reuses 12+ year old out of date Bing aerial maps and relabels them as if they were created in 2016 in preparation for the application. After numerous people and Franklin Township Council’s comments, FERC acknowledged this and required Transco to update all of the out of date maps. One map actually is missing the Princeton Manor development, but this misuse of outdated maps is throughout the application in all the regions where Transco’s plans to build. Another example is how on August 10, 2016, the Transco operations manager pretended to be in disbelief when a few residents raised up the MARS 100 turbine specifications. The manager then added they have no idea about MARS 100 turbines until after it is installed. Note, Transco has installed at least 3 MARS 100 turbines prior to 2016 in FERC projects dockets: CP12-30 and CP13-551 – both completed before August 2016.
Reviewing Stockton’s comment regarding no impact by 2045 is not only false, but not even possible. To understand potential contamination, the exercise of multiplying the chemical emissions by 25 years gives significant accumulative potential to the surrounding area. Granted, Trap Rock area just one place, but it will still incur significant contamination of these chemicals after 25 years of continued exhaust output.
Several chemicals accumulative potential examples over 25 years
Ammonia = 739,500 pounds; Formaldehyde = 16,500 pounds; Benzene 350 pounds; Toluene 3,550 pounds;
Since these chemicals are airborne, the contamination distribution and concentration will reach most of Franklin Township. Additionally, as airborne, these chemicals are more dangerous to humans and all other living organisms as noted by the CDC, NIH and AMA. Yet, no federal or state permit assesses that real danger to human health or the immediate area. Additionally, with these chemicals as airborne, they are very toxic in quantities of small parts per million. Yet after 25 years, accumulation is in the thousands of pounds for most of these chemicals. These chemicals eventually settle and contaminate streams, soils and water bodies. It would be very hard to conceive the slightest possibility of the area where the reservoir is planned to not have any contamination after 25 years.
If you would like to learn more about Transco’s proposed project and how it will impact your family’s health, contact stopftcompressor@yahoo.com. The more people we have registering with ferc.gov as an intervenor to this project, the stronger our voice becomes for pushing additional safety requirements and contesting the validity of this project being a public convenience. It can also influence FERC to add additional requirements to Transco and perform more health analysis and environmental impact. We have seen from our comments to FERC cause Transco to republish false data and pursue additional impact analysis.
Current open issues in the proposed project on FERC docket CP17-101
- Missing Health Impact Assessment of emissions from Compressor Station 206
- Missing Environmental Impact of the exhaust velocity and temperature emissions from Compressor Station 206.
- Missing consideration of a Heat Recovery System at the proposed Compressor Station 206, which other pipeline companies implement to reduce heat exhaust and transfer to electrical energy.
- Request to perform independent validation of Emissions (including fugitive) for proposed Compressor Station 206 using existing MARS 100 installations at Station 515, station 517 and station 520.
Your voice does make a difference if you use it. It takes little time and a small group of us are more than happy to help you understand the how to register for intervenor and submit comments to FERC to add your voice to protect Franklin Township from this imminent real threat to our health and environment.
Snapshots from Transco Application – Snapshot from Resource Report 8, document 28, page 122
Snapshots from Transco Application – Snapshot from Resource Report 8, document 28, page 47-48
Kirk Frost is a member of a small Steering CMTE that coordinates with NGO’s, municipalities, elected officials and other groups fighting other pipeline projects.