Public Advocacy Concerning Natural Gas Compressor Stations in Davidson County, Tennessee

Compressor Station Studies

My involvement began after Tennessee Gas Pipeline, a subsidiary of Kinder Morgan, proposed to build a natural gas compressor station in the Joelton area of Davidson County. At 60,000 Horsepower it would be one of the one of the largest stations in the entire nation and the only station greater than 20,000 Horsepower in a metropolitan county in the southeastern US. The expanded gas transport capacity of the pipelines made possible by this project is intended to send gas from West Virginia down to the gulf coast for conversion to liquefied natural gas intended only for export, not for domestic use. Understandably, the residents of the area were concerned, and a local group formed to oppose the construction. At an early public meeting of this group (which my wife, wisely, made me attend) they asked for volunteers with science and engineering expertise. Thus began my involvement over the next three years.

The gas compressor station in Joelton was to be built on agricultural/residential zoned land. One early lesson for the community was that there would not be a rezoning hearing because the federal Natural Gas Act (NGA) preempts all local zoning requirements. However, the project would need an air permit from the Metro Nashville Health Department (MNHD) as a Clean Air Act requirement which is not preempted by the NGA. My first task was to carefully examine the air permit application. Because of the immense size of the facility and its proximity to residences and schools, I was concerned that the regulated air pollutants might exceed the federally mandated requirements. To address this issue, I created a simple computational model based on a theory known as Gaussian Plume analysis. My model appeared to show that the facility would not meet federal requirements for air quality. I submitted a detailed report to the Metrompolitan Nashville Health department. Based on my study, the MNHD had their engineering staff look more closely at the emissions. Although my study was imprecise because it used some simplified assumptions, the process began a more thorough examination by all parties of the air permit application. Eventually, with technical and legal guidance from the Southern Environmental Law Center and external technical experts hired by the MNHD, the air permit was issued, but with the air pollution limits set to less than half of what had been originally proposed by Kinder Morgan. As the external experts demonstrated, the pollution control technologies proposed in the original air permit application were almost three decades out of date.

Interstate gas transportation is governed by the Federal Energy Regulatory Commission (FERC). As part of the environmental review process carried out by FERC, I submitted numerous technical questions, comments, and analyses. After FERC issued a certificate to go ahead with the project, local groups filed for a rehearing. As part of that rehearing I submitted a detailed analysis of the flow diagrams for the entire project of which the Joelton station formed one part. The flow diagram analysis for a large project involved weeks of work and study. That analysis points to inaccuracies and errors both in the original and in the revised flow diagrams that Kinder Morgan submitted to justify the project and obtain their certificate. FERC ultimately (after an 18-month delay) denied the rehearing, although they did not address in any detail their reasoning. The community decided to appeal the FERC certificate on a number of grounds. The brief filed in November 2018 in the Federal court in the District of Columbia used my reports on overbuild based on the flow diagram analysis and inconsistency in site selection based on material supplied by the applicant.

The long-delayed FERC rehearing decision did not stop construction which was not stayed during the rehearing process. The Joelton station is currently built and operational. Although the community was not happy initially with that result, the compressor is mostly hidden from view and pretty much unnoticeable. The noise level was initially a problem for some nearby residents--I helped make acoustic measurements to document that the level was above Federal guidelines. The company first remediated with barriers, but eventaully discovered the noise was due to as leaking valve. In the end the community attitude is that we "lost" because the facility was built. However, I, perhaps better than many, appreciate the fact that the community effort in which I played a part reduced the air pollution emission by approximately 50% making the air in Middle Tennessee a little less polluted than it might have been. The case in Federal court did not result in any decision in favor of the community. However, pursuing the process ensures that corporations become more careful in addressing issues of pollution, noise, and location of future projects.

During the review of the Joelton station, a second 40,000 Horsepower compressor station was proposed in Cane Ridge in the Antioch area just south of Nashville by Columbia Gas (now TransCanada). The approach of TransCanada was completely different than that of Kinder Morgan. The company made numerous community presentations about their plans before filing with FERC for a certificate and the engineering staff was available to answer questions. The community outreach meant that the project has received little opposition even though it is in one of the most densely populated areas ever chosen for a compressor station this size. My interactions with the engineering staff of TransCanada over their plans allowed me to get many questions answered without having to file through the long and convoluted FERC process. I enjoyed an adversarial but cordial relation with the TransCanada staff. That’s the way this process should work.

Contact

Phone: 615-838-7301
Email: bill@robertsonscience.com
Address: 1310 Roberts Road, Goodlettsville, TN, USA