Air Quality Issues Applicable to Marcellus Shale Gas Extraction Activities

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Air Quality Issues Applicable to Marcellus Shale
Gas Extraction Activities

• Krish Ramamurthy
• Chief, Division of Permits
• Bureau of Air Quality

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Three Phases of Gas Extraction Activities

• Well Drilling and Hydraulic Fracturing
• Gas Collection, Dehydration and Compression
• Gas processing to Pipeline Quality Natural Gas

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Well drilling and Hydraulic FracturingPotential
Air Emissions

• NOx, VOC and PM2.5 emissions from drilling
• PM emissions from construction activities and
  traffic on access roads
• Diesel fumes from equipment operations
• VOC and HAP (methanol from fracturing fluids)
• NOx, CO and VOC emissions from off gas flaring
• Radionuclides such as radium and radon from
  wastewater treatment of fluids

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Gas collection, Dehydration and Compression

• Potential Air Emissions
• NOx, CO, PM2.5, VOC and HAP emissions from
  Reciprocating engines
• VOC and HAP emissions from Condensate tanks)

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Gas processing to Pipeline Quality Natural Gas

• This processing remove moisture and separate
  components such as propane, ethane and Butane
  from the gas.
• Sources include Ethylene Glycol dehydrator with
  flare, Engines, Re-boiler and Storage tanks
• Fugitive Emissions from Equipment Leaks
• Emissions include, NOx, VOCs and CO
• SWRO has a issued a Plan approval for a gas
  processing plant to remove moisture and propane
  from the gas.

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Overview of Air Quality Program

• Pennsylvania has an air quality construction
  permit ("plan approval") program and an air
  quality state operating permit program since
  1972.
• These programs have been administered by the
  Department under the authority of the
  Pennsylvania Air Pollution Control Act ("Act")
  (35 P.S. 4001 et seq).
• On July 9, 1992, the Pennsylvania Air Pollution
  Control Act was substantially amended to provides
  PA DEP the authority to implement the Clean Air
  Act requirements including the Title V operating
  permit program.

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Permitting Process

• Before a new air contaminant source can operate
  in the state of Pennsylvania, an air permit is
  usually required. The purpose of the air permit
  is to legally limit the amount of air
  contaminants that a source can release into the
  atmosphere. If a permit is needed, the type of
  permit a source will require depends on the type
  and amount of pollutants it is capable of
  emitting. Usually, either a State-Only or a Title
  V permit is required.

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Permitting Process

• The process of obtaining the air permit generally
  consists of two steps
• First, an applicant must obtain a plan approval
  from the Department in order to begin
  construction, installation, or modification of
  the source.
• Secondly, once the source is constructed in
  accordance with the plan approval, the applicant
  must obtain a permit to operate the source.

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Plan Approval

• A Plan Approval is a written approval from the
  Department which authorizes a person to
  construct, assemble, install or modify any
  stationary air contamination source. It also
  includes the installation of any pollution
  control equipment or device.

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Exemptions Request for Determination (RFD)

• Pursuant to 25 Pa. Code  127.14, DEP may
  determine sources or classes of sources to be
  exempt from the plan approval and permitting
  requirements of 25 Pa. Code Chapter 127.
• Exempted if it is included in the Air Quality
  Permit Exemption List or determined on a
  case-by-case basis through a Request for
  Determination (RFD)
• RFD form may be submitted to the DEP either in a
  paper form or online electronically
• Currently, the drilling phase of Marcellus Shale
  exploration activities is exempt from plan
  approval requirements.

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Exemption List Re-proposal

• On May 29, 2010 DEP re-proposed the Exemption
  List because of the substantial revisions made in
  response to comments submitted to the Department
  following publication in the Pennsylvania
  Bulletin of proposed revisions on November 22,
  2008. See (40 Pa.B. 2822).
• The proposed conditional exemption pertaining to
  oil and gas exploration, production facilities
  and operations is provided at Category 38.
  Current blanket exemption for the drilling phase
  will be replaced with the conditional exemption.
• The owners and operators of engines not meeting
  the requirements identified in Category No. 38
  are required to submit a RFD to the Department.
  If the RFD is not approved by the DEP, an
  application seeking authorization to use a
  general permit or plan approval must be submitted
  to the appropriate DEP regional office.

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Proposed Exemption List

• In the proposed list, the following language was
  published pertaining to Marcellus Shale activity
  in Section 127.14(a)(8) exemptions that do not
  require submission of a RFD form
• 38. Oil and gas exploration and production
  facilities and operations (include wells and
  associated equipment and processes), not located
  at a major source, meeting the following
  requirements
• i. All engines used at a facility shall not emit
  combined NOx emissions of more than 100 lbs/hr,
  1000 lbs/day, 2.75 tons per ozone season (period
  beginning May 1 of each year and ending on
  September 30 of the same year) and 6.6 tons per
  year on a 12-month rolling basis.
• ii. Sources of uncontrolled VOC emissions shall
  not emit more than 2.7 tpy. If VOCs contain HAPs
  emissions, the HAP exemption criteria in
  Paragraph v of this category must be met.

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Revised Exemption List

• iii. Temporary flares used at the drilling site
  shall not operate more than 14 days at each site.
  
• iv. The owner or operator of liquid storage tanks
  and truck loading facilities shall minimize
  atmospheric emissions to the maximum degree
  possible. The measures utilized to minimize
  emissions shall include carbon canisters on tank
  vents, use of flares, vapor recovery units or
  thermal oxidizers on tank vents, the use of
  pressure relief valves which are maintained in
  good operating condition and which are set to
  release at no less than 0.7 psig (4.8
  kilopascals) of pressure or 0.3 psig (2.1
  kilopascals) of vacuum or the highest possible
  pressure and vacuum in accordance with state or
  local fire codes or the National Fire Prevention
  Association guidelines or other national
  consensus standards acceptable to the Department.
  Loading racks equipped with a loading arm with a
  vapor collection adaptor and pneumatic, hydraulic
  or other mechanical means to force a vapor-tight
  seal between the adaptor and the hatch of the
  tank must also be used to minimize emissions.
• v. Sources of uncontrolled HAP emissions of less
  than 1000 lbs/yr of a single HAP or one tpy of a
  combination of HAPs that does not include
  Polychlorobiphenols (PCBs), Chromium, Mercury
  (Hg), Lead (Pb), Polycyclic Organic Matter (POM),
  Dioxins and Furans.

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EPA Single Source Guidance

• On September 22, 2009, EPAs Assistant
  Administrator for the Office of Air and
  Radiation, Gina McCarthy, withdrew a 2007 EPA
  memorandum entitled Source Determinations for
  Oil and Gas Industries,
• The memo focused primarily on geographic
  proximity for stationary source determinations
  for the oil and gas industry.
• The withdrawal of the policy will result in
  certain operations being treated as major
  sources. This decision will affect how we
  aggregate emissions multiple sites which are
  adjacent and under common control would be
  treated as a single facility for New Source
  Review applicability purposes
• Permitting authorities would also be required to
  consider whether the activities belong to the
  same industrial grouping for Title V purposes. 

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General Permit

• General Permit (GP) includes General Plan
  Approval and General Operating Permit
• GP is optional and is valid for a period of 5
  years. Applicant may opt to apply for a plan
  approval
• The gas production/compression stage is covered
  by the Bureau of Air Qualitys General Permit for
  Natural gas, coal bed methane or Gob Gas
  production or recovery facilities (GP-5). We
  have authorized around 100 applications to use
  GP-5 in 2009
• Work has been initiated to revise GP -5 which
  would be applicable to any natural gas
  exploration and transmission facilities.

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State Only Operating Permit

• A State-Only Operating Permit is for facilities
  with emission rates below Title V thresholds,
  i.e., non major facilities.
• The State-Only Operating Permit application can
  also be requested for facilities that are
  classified as Synthetic Minors.
• A State-Only Operating Permit is usually good for
  5 years.

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Title V Operating Permit

• Title V Operating Permits are for major
  facilities as defined in Pa. Code Title 25
  Section 121.1
• The purpose of the Title V program is to detail a
  companys air quality requirements in a single
  permit document so that industry, the regulatory
  agency and the public know exactly what
  regulations and requirements apply, what are the
  normal and potential emissions, and how the
  company will monitor compliance. These permits
  has a duration of 5 years.

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NEXT STEPS

• Finalize Exemption List Revisions
• Propose revisions to General Permit (GP-5)
• Build an inventory of sources and associated air
  emissions
• Collect and Assess the Mobile Analytical Unit
  Sampling Data