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
Clean Air Council
Marcellus Shale Program
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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
Presentation Overview
• Introduction
• Health Impacts from Pollutants
• Milford Station Specifics
• How Residents can Protect Public Health
Photo Source: Bob Donnan: http://www.donnan.com/EPA_Air-Quality_92711.htm
64% 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.
PA Pipelines and Compressor
Stations
Milford Compressor Station is currently one of 10 major pipeline
expansion projects in the Delaware River Watershed.
Air Pollution Sources
Dallas Fort Worth
In 2009, the gas industry released more smog-forming
emissions than all cars and trucks in the Dallas metro area
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New York Times article citing Armendariz’s 2009 report, supported by Texas Commission on Environmental Quality
http://www.nytimes.com/gwire/2011/05/27/27greenwire-could-smog-shroud-the-marcellus-shales-natural-3397.html?pagewanted=all
RAND 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 60–75% of the
total damages.
Biggest NOx Contributors
Adapted from Allen Robinson, http://iom.edu/~/media/Files/Activity%20Files/Environment/EnvironmentalHealthRT/2012-Apr-30/Robinson.pdf
Biggest VOC Contributors
Adapted from Allen Robinson, http://iom.edu/~/media/Files/Activity%20Files/Environment/EnvironmentalHealthRT/2012-Apr-30/Robinson.pdf
Health Impacts from Pollutants
Pollutants from Compressor Stations
Potential 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=396&tid=69
Potential 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.pdf ,
Hydrogen Sulfide: http://www.atsdr.cdc.gov/toxfaqs/tf.asp?id=388&tid=67
Potential 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
Potential 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/health.html
American Lung Association, “Health Effects of Ozone and Particle Pollution,” State of the Air, 2011; President’s Cancer
Panel, Reducing Environmental Cancer Risk: What We Can Do Now, 2008-2009 Annual Report (National Cancer Institute,
May 2010).
Cumulative 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.
Milford Compressor Station Impacts
Columbia Pipeline Group’s
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.
Columbia Pipeline Group’s
Application with Reductions
Columbia Pipeline Group’s Actual
2012 Milford Emissions
Columbia Pipeline Group’s Actual
2012 Hours of Operation
90x Increase in Milford Station Emissions
tons/year
2012
Carbon Dioxide
Carbon Monoxide
125
0.55
Projected
50,762
50.64
NOx
Particulate Matter
0.46
-
42.29
6.37
VOC
Formaldehyde
Sulfur Dioxide
0.02
-
3.09
0.42
0.31
Source: 2014 Columbia Pipeline Group DEP Application
Expected Air Pollution Sources
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2 Natural Gas Turbines
Emergency Generator
Heater
Construction
Fugitive Emissions
Blowdowns
90 Barrel Condensate Tank
45 Barrel Waste Liquid Tank
EPA’s 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.
Fugitive Emissions/Leakages
Leakage from Compressor Stations. Source: EPA
Fugitive 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 Texas’s 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
How Residents Can Protect Public Health
Regulatory 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
Comment talking points for DEP
• Public Hearing Request
• Best technologies/practices
– Blowdown Injection
– Electric Compressors
– Hazardous Material Management Plan
– Condensate Tank Emission Analysis
Comment 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.
Electric Compressors
• Electrical
hookup present
• Would greatly
reduce
emissions
• Depending on
gas prices, can
pay back within
3 years
Re-routing Blowdown Gas
• EPA standards
recommend rerouting 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
Comment 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.”
Clean Air Council Action Alert on
Milford Station
Reality Check on Regulatory Process
Contact Info
• Matt Walker, CAC Community Outreach Director
mwalker@cleanair.org
• Sam Koplinka-Loehr, CAC Shale Gas Organizer
SKL@cleanair.org
Questions?
Air Regulations and Permitting
General 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
Federal 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)
– EPA’s new Oil and Gas Regulations
– Required Technology
• Nonattainment New Source Review
• Prevention of Significant
Deterioration
– Title V Permit Program
State Air Quality Permitting
• State permits enforce state and federal regs
• Exemptions (PA)
– All equipment except engines at compressor stations >
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
Greenhouse 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
– EPA’s “phase 3” of rule would lower
this to 50,000 tpy CO2e
Truck Traffic
NOx, PM, CO2
Dehydration Units
Methane, VOCs, HAPs
Condensate Tanks
VOCs & HAPs
Flaring/Venting
Source: Frank Finan
HAPs, CH4
Unplanned Events
2012 Lathrop Compressor Station Explosion, Susquehanna County