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?