Title: Marcellus Shale Citizen Surveillance and Organizing Skills Training
1 Air Quality and Health Impacts of Milford
Compressor Station Expansion
Prepared for Citizens Meeting Milford, PA July 9,
2014
Presented by Matt Walker and Sam Koplinka-Loehr,
Clean Air Council
2Clean Air Council Marcellus Shale Program
- Lawsuits against polluters or agencies
- Track current rulemaking and write comments on
regulations - Work with residents to comment and testify on
natural gas equipment - Community actions to achieve goals outside of
regulatory pathways
3Presentation Overview
- Introduction
- Health Impacts from Pollutants
- Milford Station Specifics
- How Residents can Protect Public Health
Photo Source Bob Donnan http//www.donnan.com/EP
A_Air-Quality_92711.htm
464 of PA is above Marcellus Shale. In 2013, PA
had over 6,000 wells with 3 trillion cubic feet
of gas production. These gas products have
flooded regional markets and companies are trying
to build infrastructure to expand.
5PA Pipelines and Compressor Stations
Milford Compressor Station is currently one of 10
major pipeline expansion projects in the
Delaware River Watershed.
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7Air Pollution Sources
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9Dallas Fort Worth
- In 2009, the gas industry released more
smog-forming emissions than all cars and trucks
in the Dallas metro area - New York Times article citing Armendarizs 2009
report, supported by Texas Commission on
Environmental Quality
http//www.nytimes.com/gwire/2011/05/27/27greenwir
e-could-smog-shroud-the-marcellus-shales-natural-3
397.html?pagewantedall
10RAND 2013 Air Pollution Study
- Research and Development finds shale gas air
pollution damages already between 7.2 and 30
million in PA. - Health damages increased asthma,
hospitalization, premature death. - Physical damages agriculture and infrastructure.
- Compressor stations accounted for 6075 of the
total damages.
11Biggest NOx Contributors
Adapted from Allen Robinson, http//iom.edu//medi
a/Files/Activity20Files/Environment/Environmental
HealthRT/2012-Apr-30/Robinson.pdf
12Biggest VOC Contributors
Adapted from Allen Robinson, http//iom.edu//medi
a/Files/Activity20Files/Environment/Environmental
HealthRT/2012-Apr-30/Robinson.pdf
13Health Impacts from Pollutants
14Pollutants from Compressor Stations
15Potential Health Impacts from Nitrogen Oxides
(NOx)
- Low levels
- eye, nose, throat lung irritation
- coughing, shortness of breath
- tiredness, nausea
- High levels
- rapid burning, spasms, and swelling of throat and
upper respiratory tract - reduced O2 in tissues
- fluid build-up in lungs
Source http//www.atsdr.cdc.gov/toxfaqs/TF.asp?id
396tid69
16Potential Health Impacts from Hazardous Air
Pollutants (HAPs)
- Includes known and suspected carcinogens
- Skin, eye, nose, and throat irritation
headaches, loss of coordination, nausea damage
to liver, kidney, and central nervous system over
time.
VOCs http//www.epa.gov/iaq/voc.html,
Formaldehyde http//www.atsdr.cdc.gov/tfacts111.p
df , Hydrogen Sulfide http//www.atsdr.cdc.gov/t
oxfaqs/tf.asp?id388tid67
17Potential Health Impacts from Fine Particulate
Matter
- Short-term exposure
- Eye, nose, and throat irritation
- Long-term exposure
- Increase in risk of cancer
- Exacerbates lung disease
18Potential Health Impacts from Ozone
- Aggravation of asthma, bronchitis emphysema and
increased susceptibility to pneumonia
bronchitis - Linked to bladder, breast, and lung cancers,
stroke, diabetes, lung damage, and premature
death - Throat irritation, congestion, coughing, and
chest pain - Wheezing and breathing difficulties
Source http//www.epa.gov/air/ozonepollution/heal
th.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).
19Cumulative Health Impacts
- Taken together, emissions from shale gas
infrastructure have substantial public health
ramifications. - In their 2013 study, McKenzie et al. found
elevated risk of birth defects in populations
residing within a one-mile radius of gas
infrastructure. - Environmental Assessment of East Side Expansion
should consider impacts at the points of gas
extraction and refining as well.
20Milford Compressor Station Impacts
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22Columbia Pipeline Groups Application
- Federal Energy Regulatory Commission and
Pennsylvania DEP. - Includes reductions for removing existing engines
that have operated at a fraction of permitted
capacity. - Less than 200 hours/year since 2004.
- Actual emissions will be much higher than
previously emitted in the neighborhood.
23Columbia Pipeline Groups Application with
Reductions
24Columbia Pipeline Groups Actual 2012 Milford
Emissions
25Columbia Pipeline Groups Actual 2012 Hours of
Operation
2690x Increase in Milford Station
Emissionstons/year
2012 Projected
Carbon Dioxide 125 50,762
Carbon Monoxide 0.55 50.64
NOx 0.46 42.29
Particulate Matter - 6.37
VOC 0.02 3.09
Formaldehyde - 0.42
Sulfur Dioxide 0.31
Source 2014 Columbia Pipeline Group DEP
Application
27Expected Air Pollution Sources
- 2 Natural Gas Turbines
- Emergency Generator
- Heater
- Construction
- Fugitive Emissions
- Blowdowns
- 90 Barrel Condensate Tank
- 45 Barrel Waste Liquid Tank
28EPAs New Oil and Gas Standards
- On Aug. 2, 2013, EPA updated its performance
standards for storage tanks. - All tanks subject to the NSPS must control VOC
emissions by 95 percent.
29Fugitive Emissions/Leakages
Leakage from Compressor Stations. Source EPA
30Fugitive Emissions
- Columbia states greenhouse gas fugitive emissions
will be 208 tons at Milford, and 2,847 tons over
the entire project. - A 2009 survey of the emissions from natural gas
activities in Texass Barnett Shale estimates
that fugitive emissions from transmission account
for 35 of total fugitive emissions from natural
gas activities, or 0.49 of gross production. - Columbia has not stated what emissions are
expected from venting condensate and liquid waste
tanks
31How Residents Can Protect Public Health
32Regulatory Timeline
- Currently in 30-day comment period for DEP Plan
Approval until July 28th - FERC plans to release draft Environmental Review
on August 29th, 2014 - Followed by period of agency and public review
- Columbia has requested FERC release the EA early,
on July 15th - Interveners have opportunity for discovery and
appeal
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34Comment talking points for DEP
- Public Hearing Request
- Best technologies/practices
- Blowdown Injection
- Electric Compressors
- Hazardous Material Management Plan
- Condensate Tank Emission Analysis
35Comment talking points for Potential Public
Hearing
- Are the greenhouse gas emissions from the station
properly accounted for in the current air permit?
- Has DEP performed a proper aggregation analysis
on this station and other facilities? - What will the air monitoring and stack test
requirements be for this facility? - Columbia states aboveground condensate and liquid
waste storage is insignificant, what hazardous
waste oversight will there be of the 90 and 45
barrel tanks? - Ask how often will the station be inspected.
36Electric Compressors
- Electrical hookup present
- Would greatly reduce emissions
- Depending on gas prices, can pay back within 3
years
37Re-routing Blowdown Gas
- EPA standards recommend re-routing blowdown gas
into sales lines or intersecting pipelines rather
than doing an atmospheric release - Would greatly reduce emissions
- Depending on gas prices, can pay back within 2
years
38Comment talking points for FERC
- A true cumulative air quality/health impacts
analysis. - A true cumulative climate impacts analysis.
- Analysis of fugitive methane and VOC emissions.
- Pursuant with NEPA, the Environmental Impact
Statement must take into account all impacts
whether direct, indirect, or cumulative.
39Clean Air Council Action Alert on Milford Station
40Reality Check on Regulatory Process
41Contact Info
- Matt Walker, CAC Community Outreach Director
mwalker_at_cleanair.org - Sam Koplinka-Loehr, CAC Shale Gas Organizer
- SKL_at_cleanair.org
42Questions?
43Air Regulations and Permitting
44General Permit 5 (GP-5)
- PA DEP released the revised General Permit 5 in
2013 - Claimed large reductions in air pollution
- Reality is that new requirements only matches
what the industry has already been doing for the
past two years - Stream-lined permit
- Severely limits public participation
45Federal Regulations
- Clean Air Act
- What can be in the air?
- EPA sets NAAQS based on Public Health
- National Emission Standards for Hazardous Air
Pollutants (NESHAPS) - New Source Performance Standards (NSPS)
- EPAs new Oil and Gas Regulations
- Required Technology
- Nonattainment New Source Review
- Prevention of Significant Deterioration
- Title V Permit Program
46 State Air Quality Permitting
- State permits enforce state and federal regs
- Exemptions (PA)
- All equipment except engines at compressor
stations gt 100 hp - State permits (minor sources)
- Plan approval (construction)
- Combined operating permit and Plan Approval (GP5)
- Federal Permits (major sources)
- Title V
- DEP is required to seek public input on
compressor stations
47Greenhouse Gas Tailoring Rule
- Methane (nat gas) 21 x more potent than CO2
(leaking/venting) - CO2 from engines
- Can trip Title V major source permit
- 100,000 tpy CO2e limit for new or modified site
- EPAs phase 3 of rule would lower this to
50,000 tpy CO2e
48Truck Traffic
NOx, PM, CO2
49Dehydration Units
Methane, VOCs, HAPs
50Condensate Tanks
VOCs HAPs
51Flaring/Venting
HAPs, CH4
Source Frank Finan
52Unplanned Events
2012 Lathrop Compressor Station Explosion,
Susquehanna County