marcellus shale gas extraction air quality issues

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    Marcellus Shale Gas Extraction

    Air Quality Issues

    William C. Kaufell

    Skelly and Loy, Inc

    Director of Environmental Acoustics and Air

    Quality Acoustic/Air Quality Measurement, Modeling,

    Permitting and Mitigation

    Transportation, Mining, Industrial Clients in Mid-

    Atlantic

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    Marcellus Shale Gas Extraction

    Air Quality Issues

    Air Emission Sources

    Air Pollutant Emissions

    PA DEP Permitting in Pennsylvania

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    Extraction Phases

    Drilling and Hydraulic Fracturing

    Gas processing for pipeline distribution andconsumption

    Gas Collection, Dehydration and Compression

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    Construction activity

    Machinery, vehicles, earth disturbance

    Condensate tanks

    Emissions from condensate tanks can be quite significantwhen the gas composition necessitates their use, though this isnot the case most of Marcellus Shale.

    Dehydrators

    If the gas well uses glycol dehydrators to remove water fromthe gas, the dehydrator may release hydrocarbons, dependingon the gas composition of the formation.

    Sources of Oil and Gas Air Pollution

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    Sources of Oil and Gas Air Pollution

    Flaring Flares emit the products of combustion. It is also common to

    flare natural gas that contains hydrogen sulfide in order toconvert the highly toxic hydrogen sulfide gas into sulfur

    dioxide. Flares emit a host of air pollutants, depending on thechemical composition of the gas being burned and theefficiency and temperature of the flare .

    Engines Large IC engines for compression

    Typically run off natural gas Fugitive emissions Venting

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    Air Contaminants

    BTEX Compounds/Volatile organic compounds (VOCs) Benzene, toluene, ethylbenzene, xylene Emitted during flaring, venting, dehydration of wet gas (SW Pa)

    NE PA has dry gas (pure methane)

    VOC emissions depend on gas composition and are not large % inPA/NY Marcellus

    Carbon monoxide (CO) Emitted during flaring, machinery

    Particulate Matter Primarily dust, construction related dirt, unpaved roads Diesel exhaust from vehicles, engines

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    Air Contaminants

    Hydrogen sulfide (H2S) Occurs naturally in some formations Venting, , incomplete combustion of flared gas, fugitive

    emissions from equipment

    Nitrogen Oxides (NOx) Combustion of fossil fuels. Flaring, machinery, compressor

    engine exhaust.

    Sulfur dioxide (SO2)

    Combustion of fossil fuels. Flaring, machinery, compressorengine exhaust.

    Natural gas (methane) Released during venting, fugitive emissions from equipment

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    PA DEP/EPA Permitting

    Permitting subject to PA DEP and EPAregulations

    All gas production/recovery facilities must havean air permit before constructed

    Construction permit or Plan Approval 1st Step

    Operating permit issued with follow-upcompliance testing, record keeping

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    PA DEP/EPA Permitting

    Exemption List (current)

    #38 exempts oil and gas exploration and production facilitiesfrom Plan Approvals/Operating Permits

    Compressor Stations > 100hp need permits Exemption List (proposed)

    Gov. Corbett re-opened public comment until May 26th

    Significantly limits # of facilities exempt

    May be exempt from Plan Approval though not Operating Permit

    Only O&G that meet stringent requirements exempt

    Grandfathering?

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    PA DEP/EPA Permitting

    Minor Sourcevs- Major Source State-only Permits for minor sources (PA DEP GP-5/GP-11)

    Title V/New Source Review requirements

    Single Source Determination/Aggregate emissions of sources

    Emissions for entire facility, or 1 gen set? EPA issued guidance on aggregating O&G sources (2007)

    Rescinded 2009. Case by case basis based on existing NSR regulations

    Under control of same person, located on one or more contiguous or adjacentproperties and belong to same industrial grouping.

    DEP issued Interim Guidance for Performing Single Stationary SourceDeterminations for Oil and Gas Industries Dec 25, 2010

    Interim Guidance rescinded Feb 26 2011

    Single source determinations made on case by case basis based on existing NSRregulations

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    PA DEP/EPA Permitting

    Exploration and ProductionGP-11

    Non-road engines that move site to site

    Comment period re-opened 2-26-11 on proposed revisions

    Production and recoveryGP-5 Engines 100-1500 bhp w. controls

    Separators

    Glycol dehydrators

    Emission limitations

    Minor revisions proposed 2-26-11

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    PA DEP/EPA Permitting

    Air Permit Requirements TBD Exemption List

    Single source determination

    GP-11 Revisions

    GP-5 Revisions Number of interrelated air quality topics regarding gas

    exploration and extraction within the Marcellus Shale whichshould be considered together

    Department believes that it is appropriate to seek acomprehensive public comment period on all three of thesetopics together to guide the Department on what, if any,guidance or action might be taken on any one or more of them

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    DEP Short-term Monitoring

    In response to air quality concerns raised by public, DEPconducted short term measurements in SW PA AprilAugust2010

    5-sampling weeks at 2 compressor stations, condensate tankfarm, a wastewater impoundment and background site.

    Results of the limited sampling initiative conducted in thesouthwest region did not identify concentrations of anycompound that would likely trigger air-related health issuesassociated with Marcellus Shale drilling activities

    Sampling for CO, NO2 and ozone below NAAQS The Department has not yet determined if the potential

    cumulative emissions of these pollutants from many natural gasexploration activities will result in violations of the health and

    welfare based federal standards.

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    Questions?