Addressing Air Emissions from Marcellus Shale Natural Gas Production. Joe Osborne Lauren Burge Group Against Smog & Pollution Pittsburgh, PA

Transcription

1 Addressing Air Emissions from Marcellus Shale Natural Gas Production Joe Osborne Lauren Burge Group Against Smog & Pollution Pittsburgh, PA Pitt Environmental Law Council September 25, 2012

2 Why Air? Natural gas burns cleaner than coal per unit of energy generated. But must consider air impact from entire natural gas production process. Air pollution is generated from: o Well pad, impoundment construction o Well drilling, fracking, venting, and flaring o Truck traffic o Natural gas extraction, processing, transmission, and storage Individually, these sources and activities may seem insignificant, but there are many sources and the total impact is astounding.

3 A 2009 Southern Methodist University Study concluded that in Dallas Fort Worth area annual NOx and VOC emissions from the oil and gas sector exceed emissions from all motor vehicles. Al Armendariz, Emissions from Natural Gas Production in the Barnett Shale Area and Opportunities for Cost Effective Improvements (Jan. 26, 2009) A 2008 analysis by the Colorado Department of Public Health and Environment concluded that VOC and NOx emissions from Colorado s oil and gas operations exceeded motor vehicle emissions for the entire state. Colorado Dept. of Public Health & Environment, Air Pollution Control Division, Oil and Gas Emission Sources Presentation for the Air Quality Control Commission Retreat (May 15, 2008) at 3 4. In 2009 several years of elevated ozone readings (including elevated wintertime readings) lead Wyoming to request its first ever nonattainment designation. WYDEQ states nonattainment is primarily due to local emissions from oil and gas (O&G) development activities. WYDEQ, Technical Support Document for Recommended 8 Hour Ozone Designation For the Upper Green River Basin p. viii (Mar. 26, 2009) _jl.pdf.

4 Pennsylvania, July compressor stations 286 unconventional wells Pennsylvania, July compressor stations 5667 unconventional wells

5 The Marcellus play and other shale formations in the region are perfectly situated to worsen existing ozone and PM nonattainment areas in the Midatlantic and Northeast.

6 What Pollutants are Emitted? 1. Ozone precursors Volatile Organic Compounds (VOCs) A broad class of high vapor pressure organics Some are carcinogenic Can cause eye and respiratory tract irritation, headaches, dizziness Nitrogen Oxides (NOx) Contributes to acid rain Can cause respiratory inflammation; exacerbates asthma

7 What Pollutants are Emitted? 2. Methane Primary constituent of natural gas (~80% by weight) Potent greenhouse gas (~21 times more powerful than CO 2 ) Explosive Oil and gas sector is responsible for 18% of worldwide methane emissions.

8 What Pollutants are Emitted? 3. Air Toxics Benzene, toluene, ethylbenzene, xylenes (BTEX) Known human carcinogen Neurotoxic, reproductive, developmental effects Hydrogen sulfide Causes eye, nose, and throat irritation Exposure at high concentrations results in permanent brain damage, death Generally not present in Marcellus areas Formaldehyde Known human carcinogen Can cause asthma, coughing, fatigue, allergic reactions

9 What are the Emissions Sources?

10 Emissions Sources 1. Compressor Engines Fugitive emissions Engine exhaust A modern 1200 hp compressor will emit approximately: o NOx 6 TPY o CO 1.5 TPY o VOCs 1.5 TPY o HAPs 0.5 TPY (mostly formaldehyde)

11 Emissions Sources 2. Condensate tanks Source of VOCs

12 Emissions Sources 3. Production and Transmission Fugitive emissions o Leaking pipes, valves, flanges 4. Gas Processing o Dehydrators o Heaters

13 5. Well Completions Emissions Sources

14 Limitations of Existing Laws Exemptions Many Sources are exempt from Installation & Operating Permit Requirements No need to provide notice of intent to install emission unit to DEP No notice = No means for permitting authority to verify source meets, exemption requirements, emission rates, employing required control measures Proposed revisions to permit exemption list and general permit 5 would (at least partially) address this. General Permit 5 (GP 5) no notice and comment for many minor source compressor stations Aggregation Circumvention

15 Limitations of Existing Laws: Compressor stations permitted as minor sources

16 Solutions: 1. Notification requirement for all stationary emission units associated with natural gas operations include process description, emission units list, potential to emit not as onerous for source operator as a full permit application, most information can be obtained from vendor spec sheets, AP 42, etc. provides Air Program with knowledge of emission units on site without having to perform an inspection allows Air Program to determine if exemption criteria are satisfied: is source major? are emission limits/rates, pollution control requirements met? provides better estimate of emissions for emissions inventory 2010 University of Texas air monitoring suggests TCEQ Ozone Attainment modeling underpredicted NOx by 20%

17 Solutions: 2. Adopt narrowed permit exemption list well site general permit adding well sites to existing compressor station general permit 3. Control devices for this industry are cost effective. many pay for themselves in a year or less Control Measure Up Front Cost Payback Period green completions $ ,000 1 year vapor recovery units >$10,000 <1 year install low bleed or mechanical valves <$1000 <1 year leak detection program <$500 Varies, Gas STAR participant reported payback in <1 year EPA Gas STAR program, Armendariz Report (2009),

18 Commenting What is a comment? Public has an opportunity to express concerns or provide constructive criticism on a proposed permit or draft regulation Can include anything from personal experiences or concerns to technical or legal arguments Written in the form of a letter to a government agency Why should you comment? Technical or legal arguments are most likely to lead to improved emission controls in a permit Agencies make mistakes the more people that look at a draft permit, the more likely it is that any mistakes will be caught and corrected Agency is required to review and respond to comments. If agency cannot justify its decision, potential issue for appeal

19 Steps in Commenting Process 1. Identify permits open for public comment 2. Schedule a file review 3. Review permitting documents 4. Write and submit comments 5. Agency responds to comments 6. Possible appeal of permit

20 Step 1: Identify Permits Open for Public Comment In Allegheny County, the Allegheny County Health Department (ACHD) issues air permits. o Notice of permits is published periodically on ACHD s website o Company also publishes these in legal notices section of local newspaper In the rest of Pennsylvania, PA Dept. of Environmental Protection (DEP) issues air permits. These are published weekly in the Pennsylvania Bulletin Also published in legal notices section of local newspapers

21 Visit website And see Permits in Public Comment on right side of screen

22 Generally have 30 days to review documents Call ACHD at (412) Submit comments via or regular mail

23 The Pennsylvania Bulletin

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25 Use navigation bar at top and bottom of pages Use Prev and Next to view all pages of this particular issue of the Bulletin Scroll through to find two sections with Air Quality heading

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27 Step 2: Schedule file review Schedule a file review with the appropriate agency (DEP, or ACHD in Allegheny County) and regional office Call office to find out how to schedule; some will do it over the phone, others require you to submit a form DEP usually schedules between 9am 4pm, Monday through Friday Scheduling can be difficult with DEP; be sure to let them know you need to complete review before end of comment period (usually 30 days from date of notice)

28 File Reviews Make copies of documents (you will be charged per page fee) or take a portable scanner Informal file reviews are quickest and easiest way to obtain documents If for some reason you cannot get documents this way, you can file a Right to Know request

29 Step 3: Review Documents Documents you may receive include: o Permit application o Draft permit o Technical review document o Correspondence (DEP, industry) o Maps

30 Step 4: Write and Submit Comments Tips for Writing Effective Comments: Write comments in letter form State who you are and why you are interested Break into sections to make it easy to read Be clear and concise Point out positive aspects, in addition to negatives or anything that does not comply with the law

31 Issues to Address NOx and VOC emissions as well controlled as possible? Correctly calculated? Effect on regional ozone concentrations considered? o Especially given complex terrain in southwest PA Did agency analyze entire gas gathering operation as a single process? (aggregation issue) o May need to aggregate a compressor station with wells, field tank batteries, or liquids impoundments o For example, any wells within ¼ mile? Greenhouse gas emissions accounted for? Correctly calculated? Emissions from intermittent events accounted for? o Such as compressor blowdowns, truck loadout, cold starts Formaldehyde included in VOC calculations? NSPS and NESHAP requirements being met?

32 Step 5: Agency Responds to Comments The agency must review and respond to the comments received, and must justify its decisions May make changes to permit based on comments received, or may explain why changes were not made If decision is not justified or you believe it is incorrect, you can appeal the permit You will usually have 30 days from time final permit is issued to file an appeal DEP permit is appealed to Environmental Hearing Board (EHB) EHB is like a court, so it is highly recommending that you speak to an attorney as soon as possible if you are considering appealing a permit ACHD permit can be appealed to Director

33 Questions?

34 Misc

35 What about DEP s Air Toxics Study? What the press said:

36 What DEP actually said: Due to the limited scope and duration of the sampling and the limited number of sources and facilities sampled, the findings only represent conditions at the time of the sampling and do not represent a comprehensive study of emissions. this short term sampling effort does not address the cumulative impact of air emissions from natural gas operations

37 Limitations of the Air Toxics Study DEP study was focused on Air Toxics, not NOx or VOCs DEP monitored for 44 pollutants at 12 Marcellus Sites focused solely on concentrations high enough that short term exposure would pose a health risk. DEP s monitoring equipment was not sufficiently sensitive to detect several pollutants unless they were well above short term exposure levels

38 Limitations of the Air Toxics Study Measured pollutant concentrations are only reliable to the extent the 12 natural gas sites are representative of routine operation at all PA natural gas sites...

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40 Limitations of the Air Toxics Study No consideration of long term exposure risk. No consideration of cumulative impact on regional ozone or particulate matter levels.