Shale Gas Development/Production
Activities and Air Quality
Mike Abraczinskas, Deputy Director
North Carolina Division of Air Quality
Mining and Energy Commission
October 17, 2014
1
Overview
• Characterization of air emission sources and pollutant
profiles
• Regulatory framework
• Learning from others:
– Permitting
– Compliance assurance
• Gather the best emissions data
– Estimate emissions per well pad
– Estimate air quality impacts
• Gather baseline monitoring data
• Sharing knowledge
2
Air Emission Source Profile
Important to consider lifecycle of activities
3
Regulatory Structure – Air Sources
• Overall, a regulatory framework is in place covering air
emission sources (and the permitting process) at shale
gas development and production facilities.
• USEPA’s New Source Performance Standards for Oil
and Gas (Subpart OOOO) and National Emission
Standards for Hazardous Air Pollutants (Subpart HH)
are already adopted by reference into NC’s air quality
rules (02D .0524 and 02D .1111) – August 2012.
•
From USEPA in 2012: “The final rules include the first federal air standards for
natural gas wells that are hydraulically fractured, along with requirements for
several other sources of pollution in the oil and gas industry that currently are not
regulated at the federal level. The rules for fractured gas wells rely on proven,
cost-effective technology and practices that industry leaders are using today at
4
about half of the fractured natural gas wells in the U.S.”
Regulatory Structure – Air Sources
• Most states have not developed air quality rules
specifically for shale gas activities.
– Exceptions: when dealing with unique situations that resulted
in violations of federal air quality standards
– Note: most of the “experiences” with this type of activity have
been during an era void of the federal air emission rules for
unconventional gas exploration
• At this time, DAQ is not recommending:
– any changes to existing rules
– new rules
• Continue to review new studies and information…
especially with regard to leak detection and repair.
5
Air Quality Permitting
• Learning from other states
• How have they handled the different phases of the shale gas
development process?
• None cover the drilling/fracturing/completion stage of the process
in air quality permits.
– Drilling/fracturing not considered stationary sources
– Although, completion may be rolled into permits.
• Several states have developed general permits for the production
stage (mainly small air permits for storage vessels and generators)
• Most compressors require an air permit.
• Processing facilities have the potential to be Title V major sources.
6
Air Quality Permitting of Shale Gas
Activities in other States
States
*
What is Permitted?
Arkansas
Typical*
Colorado
Typical*
Kansas
Typical*
Louisiana
Typical*
Ohio
Typical*
Oklahoma
Typical*
Pennsylvania
Typical*
Texas
Typical*
West Virginia
Typical*
Utah
Typical*
Wyoming
Typical*
Typical equipment subject to permitting after the initial drilling and
fracking phase includes: engines, tanks, and separators at well site; mid –
stream compressor operations; dehydrators, pneumatic controllers,
7
equipment leaks, and sweetening units at processing sites.
Emissions Assessment
per G.S. 113-391(a3)(2)
• Gathering emission factors per pollutant to enable
estimates of emissions per well pad developed.
– Includes:
•
•
•
•
•
truck trips and idling,
land clearing and unpaved roads
drilling and associated activities
fracturing
completion
• Gathering activity data estimates
• Continuing assessment 2014/2015:
– Combine estimates of number of wells in a particular area,
generate emissions estimates.
• Allows local and downwind air quality impacts to be
assessed.
8
Air Quality monitoring
• Assessment of existing monitoring network relative to
shale gas deposits.
• Identified existing, well-placed upwind and downwind
multi-pollutant air monitoring locations in Montgomery
and Wake counties… but nothing in the area thought
to be most promising for development.
• Establish a multi-pollutant air monitoring site in Lee
County.
9
NC Air Quality Monitoring Network
Dan River basin
Deep River basin
Sanford sub-basin
New Lee County air monitoring location
Baseline Monitoring - Summary
• 89 compounds will be measured.
• At least 1 year of baseline data will be collected.
• Continuous sampling for:
– ozone, fine particles, nitrogen dioxide and sulfur dioxide
• Sampling every 6th day for:
– The remaining compounds.
– Ensures that daily, weekly, seasonal patterns are captured.
• Meteorological data will be collected.
– wind speed, wind direction, temperature and relative humidity
• Identical upwind and downwind sites.
11
Opportunities to Share Information
in 2013 & 2014
• Mining and Energy Commission
– Environmental Standards Committee
• Monitoring, testing, permitting, odor, dust, handling of confidential info.
– Coordinated Permitting Study Group
• Comprehensive environmental permit for the development phase
• Air Quality Committee (AQC) of Environmental
Management Commission
• DAQ Stakeholders
– Outside Involvement Committee
– Air quality forums in Greensboro, Hickory and Charlotte
12
Recent activities
• “Oil and Gas Operations, Air Emissions, and Regulations” - 2014
– 8 staff attended
– Oil and Gas operations
– Air Emissions
– Emission calculations
– Hydraulic Fracturing rules
– Federal Regulations
• NSPS, Subpart OOOO
• NESHAP, Subpart HH and HHH
• Attending ECOS Shale Gas Caucus
• Reviewed EPA White Papers
13
Final summary
• Federal rules in place.
• State rules apply.
• Monitoring baseline conditions… Source-oriented
capable, if necessary.
• Complaint driven rules and processes in place. We
respond.
• Potential for additional Federal rules.
• Estimating emissions - air quality impacts.
• Evaluating/learning from other states.
• Sharing information and recommendations.
• No changes to existing rules.. No new rules
14
recommended at this time.
Contact Information
Mike Abraczinskas, CPM, EIT
Deputy Director
NC Division of Air Quality
(919) 707-8447
– Visit our web site:
• http://www.ncair.org/
•
Michael.Abraczinskas@ncdenr.gov
15