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We recently submitted a follow-up comment on air quality and EJ issues with Enbridge's (non-functional?) compressor in Weymouth, MA.
Why now? Because FERC recently stated that these issues may warrant additional consideration.
t h r e a d
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Why now? Because FERC recently stated that these issues may warrant additional consideration.
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We originally commented to MassDEP that the original air permit application modeling ignored the largest sources of benzene at the facility. This carried through even to the health assessment, which found benzene emissions from the facility wouldn't exceed MassDEP limits.
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Problem is, the application modeling used only the average emission rate for condensate piping fugitives. The AVERAGE TOTAL fugitive emissions rate is actually more than twice as high, and about twice as high as the maximum benzene rate for the compressor (0.0044 lb / hr).
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If we consider the MAXIMUM fugitives emission rate, then the benzene emissions from the facility will be incredibly high compared to the turbine and what was modeled in the application. Perhaps even > 700 times the benzene emission rate as what was modeled, at a maximum.
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Needless to say, we used an EPA air pollution screening model and found that flashing emissions alone could grossly exceed MassDEP benzene limits at their maximum. Just because you didn't consider the emissions doesn't mean they won't pollute your air and your neighborhoods!
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Finally, we see that health-based limits for benzene could be violated when the separator ("flash") emissions are high. Including in the adjacent EJ neighborhoods (*).
Regulatory feigned ignorance is at part to blame.
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Regulatory feigned ignorance is at part to blame.
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In summary, the regulatory process overlooked the largest benzene sources at the facility (and air toxics in general) - a systemic failure of the regulations that exclude these emissions.
FERC stated their concerns re: health, safety, and EJ - may they grant our rehearing.
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FERC stated their concerns re: health, safety, and EJ - may they grant our rehearing.
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(p.s. the comment is accessible from the FERC website here: https://elibrary.ferc.gov/eLibrary/filelist?accession_num=20210129-5401)
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