Busy day in the State House. Not only are tons of school kids having field trips, the recent former Secretary-General of the United Nations, Ban Ki-moon was visiting. Saw him go by a couple of times, surrounded by a cloud of officials, aides, staff of various offices.
As luck would have it, someone sat down next me who looked familiar, but I wasn’t sure if he was who I thought he was. As much as I hated to interrupt him reviewing copy on his laptop, I had to ask:
“Do you work for the State House News (Service)?”
It was none other than Andy Metzger, prolific reporter of the SHNS. We had a short conversation about what I was doing there, he said he had heard of me, and that he was glad I introduced myself. I’m just glad I had the opportunity to.
Other than the accidental couchmate, I was by myself today. This pic was taken before the crowded madness started.
Today’s note was a copy of comments I’m sending to MassDEP regarding their intent to permit the Chapter 91 Waterways to Algonquin/Spectra. I got all of my facts from FRRACS (heh) and I realize now that there wasn’t even a comment period on this intent to permit. I’ll just send comments anyway.
June 7, 2017
MassDEP Waterways Regulation Program
1 Winter Street – 5th Floor
Boston, MA 02108
RE: Waterways License Application Number W16-4600
Dear Mr. Taormina:
Thank you for the opportunity to comment on the Written Determination.
I have some issues with this intent to permit. I wish I had more time than to copy and paste, but I don’t. I do have a GREAT WORRY about the intent to permit for the following reasons that I fully understand and concur with:
- The compressor station is not ancillary to the metering and regulating station, as claimed by the applicant.
- The permit determination is in error by declaring that the proposed project is a water dependent ancillary facility based on the 2002 waterway license No. 9451.
- This 2002 permit was based on managing the juncture to two high pressure natural gas pipelines serving a newly constructed gas fired power plant that replaced the former coal fired and mothballed Edgar Power Plant.
- The 2002 license purpose was to permit the new use at this site to serve a new gas fired power plant during a time of limited periodic capacity problems with the delivery of natural gas to the Northeast market.
- Natural gas is in a glut in the northeast and this proposal is mainly for export, not for supply, like it was in 2002.
- Basing this new determination that a compressor station at the site is somehow an ancillary use for the contrary purpose of reversing pipeline flow from serving the northeast market is inaccurate.
- Alleviating supply constrictions in 2002 to an export pipeline passing the gas to Canada for export is a new use that needs a new determination of the placement of a compressor station in this designated port.
- The proposed compressor station is not water dependent.
- The station provides pressure to maintain forward flow in the pipeline until a terminus point, such as a refinery or a terminal.
- In this case, the intent is to turn a supply pipeline to a transport pipeline to an LNG terminal for conversion and export.
- Allowing a non-water dependent use on the coast because the applicant finds it convenient and cheaper to reverse the function of an existing pipeline from supply to transport to Canada is contrary to Chapter 91.
- Public access to the park and conservation lands is at cross purposes with the safety and security of the facility
- A clear explanation on how the conflicting need between security and access would need to be resolved.
- This state review does not discuss the additional infrastructure that will be installed if Access Northeast is approved, following Atlantic Bridge.
- The applicant, in other statements, has stated that an additional gas fired compressor unit will be added in the future, doubling the capacity to provide pressure to the proposed pipeline to Canada.
SAFETY AND SECURITY
- There are significant potentials for a major event on this site if an explosion takes place or if a major storm event cuts off access to the compressor station. The area would be isolated from access in either scenario.
- For example, in the case of a fire, the shut off system is in Salem and would require the burn off all the pipeline gas from the time it is shut off in Salem to when the pipe is emptied by flaring at Weymouth.
- Compressor crews may not be able to enter the site for lessor events, such asflooded underground utilities serving the compressor station curtailing the ability to control operations.
- There is no mention of the potential for a long duration disaster and its possible impact on MWRA, the adjacent power plant, Twin Rivers flammable storage site, or the new Fore River Bridge carrying 30 thousand plus vehicles a day.
- The applicant has characterized the site as essentially a rural site in terms of density with no adjacent structures or buildings. The applicant had implied this is a larger parcel than it is by creative manipulation of the density and proximity of the local population to give the impression that this site is suitable on a densely populated coastal area.
- A critical regional MWRA pump station is adjacent to this proposed station.
- The submission does not review and analyze the possible adverse impact of changes in site topography and building placement on concentrating flood and surge on this pump station. The detailed site changes from this large amount of fill need to be analyzed for possible impact on the proposed compressor station building itself as well.
- FEMA has designated and mapped this site as an evacuation zone under large storm landings including the impact, not just of flooding, but the danger of storm surge on this parcel. Simply raising the compressor building elevation is wholly inadequate in designing a structure on this parcel.
- FEMA made this designation long after the 2002 waterways license the state seems to depend on as their basis for their review.
- Additional MassDEP modeling and projections for this site are now available that were not in existence for review and consideration in 2002; they should be used.
- There is no evidence in the Chapter 91 permit issuance that actual site visits and reviews were made made MassDEP.
- It appears that MassDEP relied on the applicant’s depiction of the site and an old waterway license permit issued for other purposes. This old permit was issued before the new bridge was approved and the MWRA facility was constructed
Thank you for your time, and thanks to DEP for their time
PS: Please explain the attached incomplete CH 91 Application for the metering station. How can a permit be granted when the Application on file is incomplete?