DCNR SHALE GAS ADVISORY GROUP MEETING WEDNESDAY, JULY 30, 2014

STATE COLLEGE, PA

Pennsylvania DEP’s Air Permitting Requirements for

Natural Gas Drilling, Compression, and Processing Facilities

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Headings : White Text 40 pt. Calibri Marcellus Shale Area

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Headings : White Text 40 pt. Calibri Air Pollutants Produced from Combustion

• Nitrogen Oxides – NOx * A precursor to the formation of ground-level

ozone and fine particulate matter

• Carbon Monoxide – CO • Volatile Organic Compounds – VOC

* A precursor to the formation to the formation of ground-level ozone and fine particulate matter

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Headings : White Text 40 pt. Calibri Air Pollution Sources

• Well Pad Non-Road Engines, Storage Tanks and Fugitive Emissions, Pneumatic

controllers • Compressor Stations

Engines, Turbines, Dehydrators, Storage Tanks and Fugitive Emissions, Pneumatic controllers

• Processing Plants Dehydrators, Fractionation Units, Sweetening units, Fugitive

Emissions, Pneumatic controllers.

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Headings : White Text 40 pt. Calibri Pennsylvania Air Permitting Process

• Step 1 – Permit Exemption Criteria (Category No. 38) * If the applicant meets the requirements, they are exempt from permitting

requirements. However, they must demonstrate compliance with all applicable state and federal requirements.

• Step 2 – Request for determination (RFD) * Applicant may request exemption from permitting requirements on a case-

by-case basis. • Step 3 – General Plan Approval / Operating Permit for Natural Gas

Compression and/or Processing Facilities (GP-5) • The applicant must meet all applicable requirements established in the

permit. * Authorizations to use the GP are required by law within 30 days.

• Step 4 – Case- by- case plan approvals and operating permits * May take 180 days or longer (for major sources) for issuance. * Requirements are determined for each source on a case-by-case basis. * Requirements in the applicable GP becomes baseline for the plan approval

requirements.

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Headings : White Text 40 pt. Calibri Applicability of Exemption Category No. 38, GP-5, and Case-by-Case Plan Approvals

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Headings : White Text 40 pt. Calibri Unconventional / Conventional Gas Reservoirs

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Headings : White Text 40 pt. Calibri Natural Gas Well

• Well Drilling • Well

Completion * Perforating the

well * Hydraulic

Fracturing * Flowback

• Reduced Emission Completion

http://www.youtube.com/watch?v=YemKzEPugpk&feature=player_embedded

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Headings : White Text 40 pt. Calibri Drilling Rig at Well Site

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Headings : White Text 40 pt. Calibri Hydraulic Fracturing Operation

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Headings : White Text 40 pt. Calibri Natural Gas Producing Well Pad

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Headings : White Text 40 pt. Calibri Leak Detection And Repair (LDAR)

http://www.epa.gov/region6/6en/a/oil_and_gas_johnson_county.html http://www.youtube.com/watch?v=YZlnV3o4TRk

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Headings : White Text 40 pt. Calibri Natural Gas Compression and Processing Facilities

• 513 compressor stations • 16 processing plants and metering stations

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Headings : White Text 40 pt. Calibri Natural Gas Compression and Processing Facilities

• Top five counties

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Headings : White Text 40 pt. Calibri Sources at Compressor Stations

• Engines – Most common 1340 HP and 1380 HP natural gas powered engines

• Turbines – 5000 HP to 15000 HP

• Dehydrators

• Storage Tanks

• Fugitive Emissions

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Headings : White Text 40 pt. Calibri Emissions from Natural gas compression and processing facilities

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Headings : White Text 40 pt. Calibri GP-5: Applies Only to Minor Facilities

The emissions from all sources located at a facility shall not equal or exceed any of the following on a 12-month rolling sum basis: • NOx, CO, SOx, PM10 or PM2.5 – 100 tons. • VOCs – 50 tons. • Any individual HAP – 10 tons. • Total HAPs – 25 tons. • Greenhouse gases, expressed as carbon dioxide

equivalent (CO2e) – 100,000 tons.

GP-5: Everybody Wins

How does the public and environment win? • More equipment with emission limits. • Limits reduced by 75-90%. • Specific obligation to document operations below

major source thresholds (every month). • Testing requirements and verification of rates every

2500 hours of operations. • The terms and conditions in the GP-5 cannot be

modified during the authorization period. • Comprehensive LDAR program required over the entire

Compressor Station and Processing Plant.

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GP-5: General Plan Approval/ General Permit for

Natural Gas Compression and/or Processing Facilities

How does the permittee win with GP-5?

• Certainty of maximum emission limits.

• 30 days to receive an authorization to use GP-5.

• Ability to install lower emitting equipment and maximize operational flexibility.

• Ability to manage operations consistent with their risk profile.

• Ability to optimize their strategic investments.

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Headings : White Text 40 pt. Calibri GP-5: Lean Burn Engines > 500 HP

75% to 87% reduction in emission limits from previous GP-5

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Headings : White Text 40 pt. Calibri Actual NOx Emissions

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Headings : White Text 40 pt. Calibri Actual CO and VOC Emissions

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Headings : White Text 40 pt. Calibri GP-5: Rich Burn Engines > 500 HP

85% to 90% reduction in emission limits from previous GP-5

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Headings : White Text 40 pt. Calibri Actual NOx Emissions

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Headings : White Text 40 pt. Calibri Actual CO and VOC Emissions

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Headings : White Text 40 pt. Calibri Emissions from Natural Gas Compression and Processing Facilities

The Reported Pollutant Emissions from the Natural Gas Sector for the 2012 Calendar Year

Category Year CO

(TPY) NOX (TPY)

PM10 (TPY)

PM2.5 (TPY)

SOX (TPY)

VOC (TPY)

CO2 (TPY)

Natural Gas

2012 7,350 16,361 600 548 101 4,024 4,291,316

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Headings : White Text 40 pt. Calibri Exemption Category No. 38 • Exemption Category No. 38 for Conventional

wells, wellheads and all other associated equipment such as non-road engines, storage vessels/tanks, flaring activities finalized on August 10, 2013.

• The GP-5 is not applicable to wells, wellheads or all other associated equipment.

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Headings : White Text 40 pt. Calibri Exemption Category No. 38

• Importantly, this is only an exemption from permitting and not from effectively controlling emissions from wellheads, and all other associated equipment.

• VOC and HAP emissions will be controlled to levels that are equal to or better than New Source Performance Standards (NSPS) and BAT.

• Exemption criteria include monitoring requirements better than NSPS.

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Headings : White Text 40 pt. Calibri Regulating Methane and VOC from Sources at Well Pad

Sources Pollutants Applicable PA requirements

Emission reduction strategy

Flowback Hydrocarbons (Methane)

Green Completion (Reduced Emission Completion).

• Capture and send to gathering line • If not feasible flaring with 95% destruction

efficiency

Fugitive Leaks Methane, VOC Exemption Category #38 Leak Detection and Repair (LDAR) program using FLIR (Forward Looking Infrared Camera) or other detection devices.

• Initial inspection within 60 days • Annually thereafter • Any visible leak is leak. • Leaks must be repaired within 15 days.

Storage Tanks VOC Exemption Category #38 • Limit facility wide total VOC emissions to less than 2.7 tons per year. (Federal requirement is 6 TPY per tank)

• If not, install controls capable of achieving

emission reduction of 95% or greater

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Exemption Category No. 38

• While a source may be exempt from permitting requirements, that source is still subject to all applicable Commonwealth and federal regulations

• The criteria that must be met for a well pad to be exempted from permitting requirements are more stringent than NSPS and NESHAPs

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Implementation Instructions for Exemption Category No. 38

• The Department has developed Implementation

instructions for DEP inspectors and owners or

operators of well pads to consistently implement the

provisions of Category No. 38.

• The Implementation Instructions document has been posted on the DEP’s website at:

http://www.dep.state.pa.us/dep/deputate/airwaste/aq/permits/gp.htm

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FAQ for Implementation of GP-5

requirements and Exemption Category No. 38

• The Department has posted a Frequently Asked Questions (FAQ) Fact Sheet about GP‐5 and Exemption Category No. 38.

• The FAQ provides a clear explanation of the applicability and requirements of the general permit and answers questions often posed by applicants.

• The FAQ can be found on DEP's website at: http://www.dep.state.pa.us/dep/deputate/airwaste/aq/permits/gp.htm

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Comparison of Air Regulations

• The PA DEP has posted a spreadsheet on DEP’s website containing comparison of the air regulatory requirements for natural gas industry of OH, WV, PA, CO, EPA and performance standards by The Center for Sustainable Shale Development (CSDD).

• The Center for Sustainable Shale Development (CSSD) is an independent nonprofit organization consists of diverse group of stakeholders from energy companies and environmental groups that has developed performance standards for natural gas industries.

• The comparison Table can be accessed at the Department’s website at the following link:

http://www.dep.state.pa.us/dep/deputate/airwaste/aq/permits/gp/Comparison_Table_CSSD-Colorado-PA-Ohio-WV-EPA-Air_Standards-2014-05-28-1530.pdf

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Questions??

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Naishadh Bhatt Chief, Technical Support Section

Division of Permits Bureau of Air Quality

nabhatt@pa.gov 717.787.2856

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