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SpaceX #13 - I found the exact modular Gas Plant Elon Musk ordered
And what it reveals is stunning environmental disclosure fraud
Let’s talk about forensic accounting.
When your dishonest ex-spouse moves money and retirement accounts into different LLCs, you call a forensic accountant.
When WireCard's (German FinTech) cash holdings don’t make any sense, a forensic accountant is the person for the job.
A famous forensic accountant, Mr. Jim Chanos, used his craft to sniff out fraud at Tyco, Enron, WorldCom and others.
Forensic accounting is the science of sussing out misleading, fraudulent or otherwise deceptive behavior. A good forensic accountant can take a simple statement of accounts or balance sheet, and reverse engineer back to the starting point to catch a criminal in the act.
Someone successfully committing accounting fraud usually depends on established calculations and formulas. This gives the fraud enough legitimacy to remain undetected for months or years while the schemers at the top stuff their pockets with ill earned gains. It also allows the forensic accountant to follow your trail.
Links to previous entries at Bottom
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CHAPTER 13: The Smoking Gun
Now, let’s talk about what it is I do, exactly. I’ve had many people ask me this in the months since I’ve been writing ESG Hound. I’m a “forensic environmental data specialist” (I invented the term just now). I use the troves of free to the public data located in regulatory submittals and permits to extract useful information. People sometimes pay me for my work, in fact, to do such things as: prove a short selling thesis, complete 100% legal corporate “espionage” on competitors about production capabilities, or find flaws in internal auditing and risk management systems. As far as I can tell, I’m one of the few people who have realized the power of exploiting this massive type of public records data in such a way. To keep my ego in check: while currently a very niche skillset, it’s not something that is possible for only mega geniuses.
As an example, I used this “forensic” skill set to reverse engineer the wild claims made by Gevo, a tiny biofuels company, that they could make biodiesel and jet fuel from cultivated corn that acts as a massive carbon sequestration sink. Turns out that using standard Life Cycle Analysis (LCA) calculations, their claims don’t add up.
Getting back to SpaceX, the section on the “Gas Pretreatment System” bothered me from day one, for many reasons. As covered in Part 2, the description is a convoluted, roundabout way of trying to make a normal Cryogenic Gas Plant that you see all over Texas sound like something that’s clean and futuristic.
And while Elon Musk has spent the past week downplaying the significance of Methane….
…the real story has always been here:
You see, Methane isn’t a VOC under the Clean Air Act. It is a potent greenhouse gas, but it doesn’t cause dangerous ground level Ozone pollution. Longer Hydrocarbons, like Propane and Butanes? These are VOCs. They are also present in high levels (15-30%) in wet, untreated natural gas that comes out of production wells.
45.8 tons of VOC emissions from an operation that takes already treated pipeline gas (95% or greater1 methane) and then processes it further to 99%+ pure methane doesn’t make sense. Never has. I’ve been around midstream air permitting for over a decade. The math doesn’t work, as I’ve outlined in this draft item for my public comment to FAA:
But I needed real proof: a smoking gun, a fingerprint, something. And then I had an epiphany:
Elon Musk loves D*cks, C*cks, and Phallic objects
This isn’t a joke or an aside; I put two and two together while scrolling through twitter
Like a pre-teen boy who discovered his dad’s Hustler collection stashed in the attic, Musk (a fully grown man at age 50) has a truly bizarre fascination with penis innuendos, memes, and imagery.
My aha moment occurred just then: this section in the PEA finally made sense:
In a document completely lacking in any sort of detail about the supporting industrial operations, the exact height and dimensions of one piece of equipment was out there for the world to see. As I noted in part 2 of my series, that’s a BIG process column. The diameter had thrown me off, as demethanizers/deethanizers are traditionally only 5-8 feet2 in diameter as this allows energy efficient column fraction separation by length.
Except there is a patented design by Ortloff Engineering (legendary design firm out of Midland, TX) that looks like this:
A big fat d*ck of a process tower, which Ortloff (now fully owned by Honeywell UOP) calls a “Gas Plant in a Bottle.” The increased girth is actually a processing feature, and a very cool engineering accomplishment. Look at that thing: it’s no wonder the draft assessment document, likely micromanaged by Musk himself, had the exact dimensions listed. Now, as to the specific size, the 200 foot tall, 16 foot wide column is the central processing vessel in Honeywell UOPs modular Cryo gas plants. Whereas gas plants used to be unique and stick built, UOP (and others) offer prefab plug and play gas plant options like this:
The SC20 and SC30 plants are the only ones with the largest 200 foot tall column. The 250 MW power plant (plus overhead for rocket fuel) only needs 50 MMscfd (million standard cubic feet per day). And yet signs seem to be pointing towards 4x that size. This is a BIG gas plant. And since there is no nearby gas gathering system, SpaceX appears to be indicating that they need an E&P and gathering system that will number in the Hundreds, if not Thousands of newly fracked gas wells. Woah.
Ortloff/UOP also has integrated, LNG modules, which seem purpose built for SpaceX’s operation as described:
But this is still all circumstantial. I need the smoking gun. Or perhaps a fingerprint will do the trick. Turns out I can look at public data for other known Honeywell UOP Modular cryo gas plant installations over the past 5 years. This is what I came up with, using press releases, publicly available clean air act permitting, and emissions data from multiple states:
The NOx and CO emissions for a modular processing train (post compression) will be really similar from plant to plant as this is a prefabricated plug and play unit and the process heaters are standard sized. Likewise, the steady state annual VOC3 emissions will be similar, varying only a little4 based on the exact input gas speciation5.
Plants 1 through 5 in the above chart are as follows:
Plant 1: Oasis Midstream Wild Basin Gas Plant, N. Dakota (200 mmscfd field natural gas)
Plant 2: Caprock Midstream Pecos Bend Gas Plant, TX (320 mmscfd field natural gas)
Plant 3: Altus Midstream Diamond Cryo Gas Plant, TX (200 mmscfd field natural gas, one out of 3 identical trains, totaling 600 mmscfd)
Plant 4: WTG Martin County Gas Plant, TX (220 mmscfd field natural gas)
Plant 5: Brazos Midstream Comanche Gas Plant, TX (200 mmscfd field natural gas)
There you have it. The emissions profile, much like a fingerprint or DNA familial test, shows that SpaceX all but certainly used preliminary design data, likely directly from Honeywell UOP themselves. The kicker is that the UOP/Ortloff design is best in class at Ethane and Propane Recovery6, with ~100% propane and 99% (or potentially greater) ethane removal from the Residue stream (natural gas or methane), which would be perfect for making nearly pure liquid methane fuel.
The Environmental Disclosure Fraud Of The Decade
All signs point towards SpaceX and FAA conspiring to hide a very large natural gas plant, at a size of >200 MMscfd, as an afterthought in an “insignificant environmental impact” assessment. And it’s not “just methane” as treating that much gas would generate 15,000 to 30,000 barrels of hydrocarbon liquids (NGLs) PER DAY.
That’s in addition to the hundreds or thousands of natural gas wells required and the hundreds of miles of midstream gathering pipeline that must be constructed to support such an operation.
None of this is public knowledge, even though it’s all happening through a process that is designed, explicitly, for full public disclosure. This is shocking to me, still, 3 weeks later. What’s even more shocking is that basically no one knows about any of this.
Reporters, there’s your lead, but only if you want to officially break the story of the year. Happy hunting and good luck keeping up with this bloodhound.
CLICK HERE FOR PART 1 - NEPA Primer / FAA has no business permitting oil and gas facilities
CLICK HERE FOR PART 2 - Elon Musk’s Natural Gas Treatment Plant
CLICK HERE FOR PART 3 - SpaceX is building a pipeline and doesn’t feel the need to mention it
CLICK HERE FOR PART 4 - SpaceX dreams of drilling for a sh*tload of oil
CLICK HERE FOR PART 5 - A discussion on the hugeness of the project, a parade of tankers and a reality check about the Oil and Gas biz
CLICK HERE FOR PART 6 - The Facility would be a Major Source of Pollution under the PSD Rules in the Clean Air Act, which by statutory definition would exclude it from fast track approval under NEPA
CLICK HERE FOR PART 7 - The GHG and CO2 emissions are plainly nonsense
CLICK HERE FOR PART 8 - ESG Hound drops the gauntlet and explains why this is a massive fraud happening in plain sight.
CLICK HERE FOR PART 9 - The End of NEPA as we know it
CLICK HERE FOR PART 10 - ELON MUSK REALITY DISTORTION FIELD
CLICK HERE FOR PART 11 - Pipeline Plans Confirmed!
CLICK HERE FOR PART 12 - It turns out drilling for oil and gas has some negative environmental impacts
FERC Spec Gas is almost always 97% methane because of the economic value of ethane in plastics production
VOC emissions from LNG/Rocket fuel liquification would be extremely minimal as residue ethane percentage would be 1% or less.
Shale gas is commonly 50-70% by mass methane, with the remainder being made up of CO2, Nitrogen and C2+ hydrocarbon liquids and gasses. A majority of emissions from these units will be from “fugitive” leaks, and a modular plant will have nearly identical valve, flange and connector counts. SOCMI emission factors are standard
Amine units, storage emissions removed from comparison emissions, to compare like-for-like “Core Unit” operations
Ortloff Presentation 5TH GENERATION NGL / LPG RECOVERY TECHNOLOGIES FOR RETROFITS, 2017