Re: CP17-101 Northeast Supply Enhancement Project
Pursuant to Senator Cory Booker’s and Senator Bob Smith’s submissions, I am hereby notifying FERC of gaps in data not submitted for CP17-101 and missing analysis required for a full and accurate Draft Environmental Impact Statement (DEIS).
Issue: Missing Data about consideration of a Heat Recovery System
In the Resource Reports and supplemental filings by Williams/Transco, there was no report about consideration of installing a Heat Recovery System added to the proposed gas-fired Compressor Station 206 to reduce heat exhaust and generate electricity – a standard that other pipeline projects have added to reduce heat exhaust impact on the environment and improve efficiency of the turbines by generating electricity.
According to Waste Energy Recovery Opportunities for Interstate Natural Gas Pipelines (report prepared by Energy & Environmental Analysis, Inc. for the Interstate Natural Gas Association of America (NGAA) in February 2008), it states “Gas turbines have relatively high exhaust temperatures (850 to 1100) which make them more suited for heat recovery applications. Additionally, in contrast to reciprocating IC engines, almost all of the energy losses in a gas turbine are contained in the hot exhaust gases.” Additionally, it states that natural gas turbines must operate near maximum output to minimize inefficiencies naturally inherent to natural gas fired turbines. As was noted online at the U.S. Department of Energy – CHP Technical Assistance Partnership:
Compressor stations that use gas-fired mechanical drives are potentially very good candidates for waste heat recovery. Natural gas-fueled engines and turbines (mechanical drives) generate heat as a byproduct. Only about one third of the fuel energy consumed by an engine or turbine ends up as useful mechanical power, with the remaining two-thirds rejected as hot exhaust or in engine cooling systems.
Most of the waste heat associated with gas turbines is in the turbine exhaust. This coupled with the high exhaust temperature (850 to 1100°F) makes them particularly attractive for waste heat recovery. Waste heat recovery from IC engine exhaust (which ranges from 500 to 1200°F) is also practical, although the exhaust gases typically contain only about 40% of the waste heat. Most of the heat from IC engines is removed in the cooling water jacket, producing a low-quality heat source at about 140°F.
In either case, the excess heat produced by the compressor drive can be turned into renewable energy using the Rankine cycle, producing no excess pollution and requiring no additional fuel. More traditional waste heat recovery systems or CHP
A fully submerged heat recovery system for Compressor Station 206 has not been evaluated by Williams/Transco, which would radically reduce the 850 to 950 degrees Fahrenheit noted in the Solar MARS 100 specification. It would also generate megawatts of electrical energy. CP16-496, submission 20161219-5403(31846197) explored an above ground heat recovery system, but noted that it would increase the noise emissions.
However, in the Commission’s 11/02/2012 order for Williams/Transco’s Northeast Supply Link Project (CP12-30), FERC included the following as a footnote [FERC Accession No. 20121102-3065(27738963)]:
Transco states that it considered the potential recovery of waste heat energy at Compressor Station 515, as discussed in the Interstate Natural Gas Association of America White Paper entitled “Waste Energy Opportunities for Interstate Natural Gas Pipelines” issued in February 2008 (INGAA White Paper). Transco states that with the addition of the new gas turbine, Station 515 will meet the initial required threshold of total gas turbine station capacity of at least 15,000 hp. However, Transco asserts that based on annual run hour records since 2007, neither the existing nor the new gas turbine at Station 515 will meet the second required threshold of operating at a rate of more than 5,250 hours per year and concludes that waste heat recovery would not be economical at this time. We note that Transco should continue to monitor Compressor Station 515, and should the station meet the waste heat recovery parameters in the INGAA White Paper, Transco should post such information on its electronic bulletin board.
In the Air Permit application in the 3/27/17 Application for NESE, calculations for operation of Compressor Station 206 were based on 8,760 hours per year which is well above the threshold needed for consideration of waste heat energy recovery.
To this end, please have Williams/Transco provide data for adding a fully submerged heat recovery system, the projected electricity generated, and specifics about the heat exhaust temperature reduction. With the heat recovery system submerged in the ground, it would negate the potential noise emissions of the system. Without this information, FERC neglects an opportunity for reducing the heat exhaust that has a volume output from each smokestack of 210,000 cubic feet per minute (cfm) at 849 or greater degrees Fahrenheit.
An additional study needs to be performed on the benefits of adding a submerged heat recovery system to this project for a complete DEIS.
The above missing data and analysis are significant gaps for the CP17-101 application. This project is meant to be a convenience, not to harm people, damage the environment or increase climate change. I urge FERC to pursue all highlighted gaps in data and analysis for this project to provide a comprehensive DEIS.
I very much appreciate your vigilance and oversight in fully assessing all potential risks, heath threats and environmental impacts that this project poses.