MPSC on Maryland Case 9318 Bench Data Request No 1
On November 15, 2017, Dominion Energy Cove Point LNG, LP (“DECP” or “Company”), the Maryland Department of Natural Resources, Power Plant Research Program (“PPRP”) and the Department of the Environment, Air and Radiation Administration (“MDE-ARA”) (together,“State Agencies”), along with the Accokeek, Mattawoman, Piscataway Creeks Communities Council Inc. (“AMP”), presented additional comments during the Commission’s Administrative Meeting (“AM”) in connection with DECP’s Motion to Amend Certain Conditions of its CPCN.
Referring to the potential increase in project-wide Volatile Organic Compound (“VOC”) emissions from 33.3 tons per year (“tpy”) to 50.9 tpy, please address the following:
1) In view of the entire Cove Point facility, what additional measures could the Company implement to reduce the project-wide emissions from the Liquefaction Facility (“Project”) in a localized, meaningful way—e.g., electrification of all or a substantial portion of the Company’s Facility-related vehicle fleet, integration of solar or other renewable energy source(s), etc.?
2) With regard to the specific alternatives proposed by AMP to offset the additional 17.6 tpy increase in fugitive VOC emissions, please explain in detail whether DECP considered each of the following proposed on-site reductions and, if it did, why the Company believes such measure is unavailable or infeasible:
- a) Adding flare gas vapor recovery to the North and South Flares to minimize VOCs being flared during plant restarts and ship cool-down;
- b) Reducing Frame 7EA gas turbine(s) NOx limit from 2.5 ppm to 2.0 ppm; and
- c) Reduce auxiliary boiler(s) NOx limit from 8.2 ppm to 5 ppm.
3) Please explain the consequences, if any, to the Company of implementing the above proposed on-site alternatives.
MPSC Maryland Case No 9318 Bench Data Request No 2
Referring to the Company’s monitoring and inspection plan for the substantial number of piping and equipment components pursuant to the TCEQ 28LAER LDAR program, please address the following:
1) Please explain how the Company will document its quarterly, bi-monthly, and weekly monitoring efforts using 28LAER LDAR, OGI, and audio/visual/olfactory methods.
2) Please indicate whether the Company will generate written reports of its monitoring efforts, and whether it will produce them to the State Agencies.
3) Please indicate whether the Company will make any of the above written reports available to the public, and by what means.
MPSC on Maryland Case No 9318 Bench Data Request No 3
Referring to the Company’s request for approval to operate its GE Frame 3 combustion turbines and Solar Titan combustion turbine, as needed, to supply power to the Liquefaction Facility, please address the following:
1) Please indicate how frequently and for how long the Company anticipates operating the GE Frame 3 turbines and the Solar Titan turbine over the course of a year.
2) If the Commission approves the Company’s request to operate the GE Frame 3 and Solar Titan turbines as alternatives to the Frame 5 turbines, how will DECP ensure that the emissions controls from the Frame 3 turbines match those of the Frame 5 turbines?
3) If the Company elects not to upgrade the NOx control systems on the GE Frame 3 and Solar Titan turbines, what can DECP do to minimize or mitigate the local impacts from those emissions?
4) Given that the Company’s request to operate the GE Frame 3 and Solar Titan turbines comes after the initial LAER assessment for this Project, how will DECP satisfy LAER emission requirements for this new usage?