Addressing Air Emissions from Marcellus Shale Natural Gas Production

Joe Osborne
GASP Legal Director

Lauren Burge
GASP Staff Attorney

Matt Walker
Clean Air Council Community Outreach Coordinator Buffalo Township Municipal Building Washington County June 20, 2012

Group Against Smog & Pollution (GASP)

Pittsburgh-based organization Has worked to address air quality issues in southwestern PA for over 40 years Education, advocacy, litigation Specifically related to Marcellus Shale, GASP focuses on: Commenting on draft permits Commenting on proposed regulations or guidance Litigation and advocacy

Clean Air Council Marcellus Shale Program

Lawsuits against polluters or agencies Track current rulemaking and write comments on regulations Workshops on Community Tools Work with residents to comment and testify on natural gas equipment Train residents in monitoring and reporting on existing equipment

Presentation Topics
Why air emissions from the natural gas industry are a concern What pollutants are associated with the industry
Details about proposed expansion to the Welling Compressor Station How individuals can participate in the decisionmaking process by commenting on proposed air permits

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:
Well pad, impoundment construction Well drilling, fracking, venting, and flaring Truck traffic 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.

Active Compressor Stations and Drilled Marcellus Wells (Dec. 2011)

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

The Oil and Gas Sectors Contribution to Ambient NOx and VOC can be Enormous
Consider other areas where drilling is common: Southern Methodist University study (2009) in Dallas-Fort Worth area, NOx and VOC emissions from oil and gas sector exceeded emissions from all motor vehicles. Colorado Dept. of Public Health and Environment (2008) NOx and VOC emissions from O&G development exceeded motor vehicle emissions for entire state. Wyoming DEQ (2009) WY failed to meet federal health-based standards for ozone for first time, primarily due to O&G development.

Wyoming Air Pollution

Worse Than Los Angeles

All Last Year Due To Natural Gas Drilling

ource: http://www.huffingtonpost.com/2011/03/08/wyoming-ait-pollution-gas-drilling_n_833027.html

the gas industry released more smog-forming emissions than all cars and trucks in the Dallas-Fort Worth metropolitan area
New York Times article citing Armendarizs 2009 report, supported by Texas Commission on Environmental Quality
http://www.nytimes.com/gwire/2011/05/27/27greenwire-could-smog-shroud-the-marcellus-shales-natural-3397.html?pagewanted=all

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

What Pollutants are Emitted?

2. Methane Primary constituent of natural gas (~80% by weight) Potent greenhouse gas (~21 times more powerful than CO2) Explosive Oil and gas sector is responsible for 18% of worldwide methane emissions.

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

What are the Emissions Sources?

Emissions Sources
1. Compressor Engines
Fugitive emissions Engine exhaust A modern 1200 hp compressor will emit approximately: NOx 6 TPY CO 1.5 TPY VOCs 1.5 TPY HAPs 0.5 TPY (mostly formaldehyde) Engines at Welling are larger two at 1380 bhp and nine at 1980 bhp

Emissions Sources
2. Condensate tanks Source of VOCs

Emissions Sources
3. Production and Transmission Fugitive emissions
Leaking pipes, valves, flanges

4. Gas Processing
Dehydrators Heaters

Emissions Sources
5. Well Completions

General Points: Natural Gas Air Issues

Complex web of minor pollution sources Widely distributed across regions Cumulative regional emissions add up fast Local Health issues from Hazardous pollutants Poor air monitoring coverage

Adapted from Allen Robinson, Carnegie Mellon

http://iom.edu/~/media/Files/Activity%20Files/Environment/EnvironmentalHealthRT/2012-Apr-30/Robinson.pdf

To reiterate: air pollution is created from a complex web of sources

Whats in the Air?

http://www.npr.org/2012/04/05/150055142/science-and-the-fracking-boom-missing-answers

Truck Traffic

NOx, PM, CO2

Drilling Rig Engines

Flaring/Venting

Source: Frank Finan

HAPs, CH4

Open-Air Water Impoundments

Source: DPCusa.org

Pipeline Leakages

CH4

Fugitive Emissions/Leakages

Leakage from Compressor Stations. Source: EPA

Compressor Stations

NOx, PM, CO2, VOCs, HAPs, CH4

Dehydration Units
Methane, VOCs, HAPs

Condensate Tanks

VOCs & HAPs

Unplanned Events

Lathrop Compressor Station Explosion on March 31st 2012, Susquehanna County

Specifics on Health Impacts from Air Pollution

Potential Health Impacts from Nitrogen Oxides (NOx)

Low levels
eye, nose, throat & lung irritation coughing, shortness of breath tiredness, nausea fluid build-up in lungs

High levels
rapid burning, spasms, and swelling of throat and upper respiratory tract reduced O2 in tissues fluid build-up in lungs death
Source: http://www.atsdr.cdc.gov/toxfaqs/TF.asp?id=396&tid=69

Biggest NOx Contributors

Adapted from Allen Robinson, http://iom.edu/~/media/Files/Activity%20Files/Environment/EnvironmentalHealthRT/2012-Apr-30/Robinson.pdf

Potential Health Impacts from Hazardous Air Pollutants (HAPs)

VOCs
Eye, nose, and throat irritation; headaches, loss of coordination, nausea; damage to liver, kidney, and central nervous system. Some can cause cancer in animals; some are suspected or known to cause cancer in humans. Examples: Benzene, Toluene

Aldehydes (formaldehyde)
-- Skin, eyes, nose, and throat irritation
VOCs: http://www.epa.gov/iaq/voc.html, Formaldehyde: http://www.atsdr.cdc.gov/tfacts111.pdf , Hydrogen Sulfide: http://www.atsdr.cdc.gov/toxfaqs/tf.asp?id=388&tid=67

Biggest VOC Contributors

Adapted from Allen Robinson, http://iom.edu/~/media/Files/Activity%20Files/Environment/EnvironmentalHealthRT/2012-Apr-30/Robinson.pdf

Potential Health Impacts from Ozone

Throat irritation, congestion, coughing, and chest pain Wheezing and breathing difficulties Inflammation of lung linings (like sunburn) Aggravation of asthma, bronchitis & emphysema and increased susceptibility to pneumonia & bronchitis Linked to bladder, breast, and lung cancers, stroke, diabetes, and premature death Permanent lung damage with repeated exposures

Source: http://www.epa.gov/air/ozonepollution/health.html American Lung Association, Health Effects of Ozone and Particle Pollution, State of the Air, 2011; Presidents Cancer Panel, Reducing Environmental Cancer Risk: What We Can Do Now, 2008-2009 Annual Report (National Cancer Institute, May 2010).

How Local Conditions Impact Air Quality

Wet Gas vs. Dry Gas

Wet gas: natural gas that contains chemicals besides methane
Natural gas liquids (NGLs) = ethane, propane, butane, Higher amounts of VOCs

Dry gas: natural gas with lower quantities of NGLs and a low moisture content
Lower amounts of VOCs Marcellus gas is generally dry except for the western end

Air Pollution, Weather and Topography

Inversion
Warm air above cool air No mixing Air pollution trapped Temp. inversion + low wind = severe smog Areas w/ valleys/mts often have high pollution levels

Downwind Air Pollution

Source: http://www.epa.gov/airtransport/whereyoulive.html

How is Air Quality near this Industry being Monitored?

Not well Matched with Shale Plays

http://epa.gov/airquality/qa/monprog.html#SLAMS

PA DEP Monitoring Sites (Criteria Pollutants)

http://www.dep.state.pa.us/dep/deputate/airwaste/aq/aqm/docs/Final_PA_Air_Monitoring_Network_Plan_2013.pdf

PA DEP Monitoring Sites (Other Pollutants)

Washington County Monitors

Four special-purpose VOC monitoring stations will be installed in 2012. These sites will be located in Washington County near permanent natural gas processing facilities. One additional carbonyl monitor will be installed in 2012 (will be sited at one of the four locations in Washington County for the proposed long-term VOC monitoring sites)

DEP Monitors in Southwest Region

Ozone, PM

VOCs, Ozone, NOx, (CO, SO2, PM)

Welling Compressor Station

Location

Location

Location

Welling Station Pollution Sources

(2) Caterpillar G35I6B 1,380 bhp (9) Waukesha P9390GSI 1,980 bhp (2) John Deere 197-bhp diesel (1) Flare, 98% control of dehy VOC (1) Reboiler burner, 2.5 MMBtu/hr (3) Condensate tanks and Vapory Recovery Units Fugitive emissions Blowdowns and emerency shutdown events

 The Welling Station is open for public comment until June 25th Comments can generate an official public hearing with DEP and MarkWest

Air Pollution from Welling Station

Nox reduction guarantee of98.8%

Wellings Potential to Emit

VOCs from Fugitive Emissions

Benzene
controlled benzene emissions from the associated glycol dehydration unit process vent will be 0.12 tpy (5.97 tpy uncontrolled). Since MarkWest has demonstrated that the actual average benzene emissions from the glycol dehydration unit process vent associated with the 130 MMscfd TEG dehydrator at Welling are less than 1 tpy, MarkWest is exempt from the control, monitoring, and recordkeeping requirements for the dehydrator.

Potential Issues
Proper (detailed) greenhouse gas analysis Proper Aggregation Analysis Public health impacts Impacts on regional air quality

A Proper GHG Analysis

Natural Gas Star Program

Voluntary technologies and practices
- EPA Natural Gas STAR Program

Ask MarkWest to Consider these Recommendations:

Replace Gas Starters with Air or Nitrogen Use low-bleed valves Zero Emissions Dehydrators Use practices that prevent blow-downs of methane/VOCs Reduce Natural Gas Venting with Fewer Compressor Engine Startups & Improved Engine Ignition Install Electric Motor Starters Install Electric Compressors
reduce the chance of methane leakage eliminates criteria pollutant emissions emit less noise, require less maintenance, and improve operational efficiency

Technology Example #1
Redesign Blow Down Systems and Alter ESD Practices

Technology Example #2
Zero Emissions Dehydrators

Technology Example #3
Use electric engines

How Can Residents Protect Air Quality?

Public Participation
comment on natural gas equipment like compressor stations and achieve public hearings and stronger permits observe and report possible air quality issues or violations to prevent pollution Request and attend DEP public hearings and local township meetings pressure gas companies to adopt best available technologies

Why Comment?
Air Quality permits affect local air quality and public health Participate in decision making process DEP issued stronger permits Public pressure can sway DEP decisions

PA DEP Public Hearings

DEP will grant hearing and meeting if enough people request it through comments Allow local residents to interact with DEP and gas company Will announce on website or local papers

How to Participate in Public Hearings

Come and Speak Come and Listen Ask Questions during meeting Support a view with quick testimony Write comments after the hearing

How to Write Comments and Testify on Natural Gas Equipment

Comments vs. Testimony

Comments
Written Length can be as long as youd like

Testimony
Oral Usually limited to 5 minutes Public Education (of audience) Can respond to Public Meeting discussion

The Basics
(comments/testimony) How do you start?
Read the DEPs Review Memo

Required Info:
Name Address Phone number Plan Approval #

Where do you send them?

What to Include (General)

Describe your personal story Make your opinion clear Use specific examples when possible Suggest specific changes to parts of the permit Suggest recommendations to permit Ask questions about things you dont understand Always ask for a public hearing

Answer these Questions to Get Started

How long have you lived in or traveled to the area? Why are you concerned about this compressor station? If you could have your way, what would you want to happen with this compressor station? What are your specific recommendations to the PA DEP on this compressor station permit?

Specific Air Permit Issues to Evaluate

the enclosed Comment and Response Document can only address those concerns that specifically pertain to elements of the Plan Approval application for [this specific] compress station. - Northcentral Regional Office of DEP

Cumulative impacts County/State compliance with air regulations

-NAAQs

Green House Gas Tailoring Rule Best Available Technologies

- EPA Natural Gas STAR Program

Air monitoring requirements Call the Clean Air Council or GASP for help

Writing Tips
Focus your testimony on using your strengths tell your own story in your own voice Always relate your points back to the specific piece of equipment you are commenting on Use your experiences and local knowledge Dont worry about having to include legal or technical arguments Nothing is too simple or short to write Dont be intimidated

Clean Air Council Action Alerts

Clean Air Council Action Alerts

Citizen Monitoring on Existing Operations

Citizen Monitoring
Common Senses Monitoring
Monitor about once a week On property or normal route Use form to document relevant information Make a Pollution Complaint to DEP
1-866-255-5158

EPA Natural Gas Drilling Tip line

1-877-919-4372

Agency for Toxic Substances and Disease Registry (ATSDR)

(215) 814-3139

Use keywords to identify the call, such as: natural gas operations, drilling, Marcellus Shale, hydrofracturing

Visible Emission, Noise & Odors Complaint Form

Fill out the Online Form and Make the Call

http://www.surveymonkey.com/s/airwatch

Questions?

Contact Info
Matt Walker, Community Outreach, Clean Air Council
mwalker@cleanair.org Lauren Burge, Staff Attorney, GASP: lauren@gasp-pgh.org