Air Quality Sampling — The Good News
This week, there were two good items that are of significant note. First, the Chapter 78 Revisions to the Oil and Gas Regulations, the EQB – Environmental Quality Board voted to move them forward to public comment. This is something to be encouraged about as these are regulation updates we’ve been waiting for several years. Since there is much to tell on this, and the public comment period is not yet open, I’m going to put off the details of this for another week. I am hopeful that in another week, there’ll be more information available worth sharing on this process.
The second item has to do with air sampling that was done at Barto Compressor Station, a PVR facility in Lycoming County. Barto is one of the very first compressor stations in operation within the greater region. What many do not know is that the first compressor engines at this location were diesel engines. These were eventually switched out and presently all compressor engines at the facility are lean burn natural gas reciprocating internal combustion engines aka RICE. When considering compressor engines, lean burn are among the lowest emitters of pollutants.
Backtracking a little bit, there is an organization known as the Clean Air Council CAC – which is a Philadelphia based air quality advocacy group. Barto had been operating a few years by the time CAC arrived in the region. On January 30, 2013 CAC issued a press release with the headline “Marcellus Shale Compressor Station Exceeding Pollution Standard By Nearly Three Times the Allowable Limit.” This press release concerning the Barto Compressor Station is excerpted in part below. CAC references a modeling report they had completed by AMI Environmental from Nevada.
Philadelphia, PA – January 30, 2013 – The Barto Compressor Station in Penn Township, Lycoming County is creating pollution concentrations nearly three times the amount allowed under the federal health-based air quality standards. Recent modeling results show that the compressor station, which pressurizes natural gas extracted from the Marcellus Shale to achieve the desired flow along pipelines, is on its own causing nitrogen dioxide pollution 278 percent over the National Ambient Air Quality Standard (NAAQS). The modeling shows that exceedances can be measured a mile away from the station. Emission of oxides of nitrogen must be reduced by up to 76 percent in order to stay below unhealthful levels.
Now, this can be pretty alarming stuff. So, of course it was of interest to many to discover how this would be. Like any good advocate, besides notifying the public, on January 31, 2013 CAC sent a letter to PA DEP advising them of this serious situation.
On May 14, 2013 PA DEP responded to CAC advising them of several issues. Unfortunately, this correspondence has not been found on the CAC website. PA DEP advised CAC of the following – and this is just in excerpt, this is not the complete details that PA DEP addressed.
- DEP was surprised of the findings due to the fact that they do have NO2 monitors in the Barto area that did not indicate such readings.
- DEP conducted a preliminary review of their findings from the modeling report and requested their modeling input and output data modeling files so they could complete a more detailed review of their results.
- DEP notes that there are issues with the model used in the analysis. CAC used an older version, DEP uses the 2012 version.
- DEP notes that CAC used a different location – and of course there is different topography there from the actual Barto location. This is an easy error being the consultant they contracted is in NV. Topographic situations can create different scenarios when considering air quality AQ impacts.
- DEP notes that stack parameter values may have been incorrect.
- DEP notes that building downwash does not seem to be considered in the CAC analysis and DEP states that this is important because higher impacts can be modeled on the facility. Onsite locations are not considered ambient air.
- DEP notes issues with the terrain data.
- DEP notes that CAC did not exclude areas not within the ambient air.
- DEP notes issues with surface meteorological data.
- DEP notes issues with meteorological data processing.
- DEP notes issues with the background NO2 concentration data.
- DEP notes the model did not account for seasonal variations in NO2.
- DEP questions the model method because ozone was not mentioned in the report.
We’ve got to hand it to the folks at DEP. They received this very serious advisement from CAC and despite their preliminary review citing 11 issues, they still want to see the modeling input/output data and pursue this with staff on the ground. You can read DEP’s response to the CAC letter here. CAC Barto Response (1) 05142013
During the week of July 22, 2013 DEP brought their sampling equipment downwind of the Barto Compressor station. You can read this complete report here. BARTO Sampling Report Final 2013-08-29 What essentially was found were indications contrary to the CAC modeling. Modeling versus actual sampling we are now looking at here.
The one hour NAAQS (National Ambient Air Quality Standards) for NO2 are 100 ppb (parts per billion). CAC indicated in their press release that from their modeling, the Barto Compressor Station was exceeding this standard by 278 percent! That is very serious matter to consider for folks who live near compressor stations. However, that was a model and a model with some issues noted by DEP.
So, what does DEP’s sampling indicate?
- During the four day sampling period all NO2 1 hour results were well below the 100 ppb standard. The maximum 1 hour result was only 5.9 ppb.
- The four day samplings are consistent with the newly placed NO2 monitor in Bradford County. The location of this monitor is within 20 miles of 25 compressor stations not to mention road traffic and well drilling and fracing that all contribute to overall NO2 concentrations. Concentrations at this monitor average between 2.2 ppb and 4.3 ppb.
So, what else can we learn from this?
- During the week of July 22, 2013 for the same sampling days, NO2 concentrations recorded at the Scranton COPAMS data averaged from 3.8 ppb to 7.5 ppb. Please keep in mind, COPAMS data is subject to change as data is verified.
Thus, while the Northern Tier Counties of Bradford, Susquehanna, Tioga and Wyoming all have greater emissions inventory reported than Lackawanna County, it is apparent the Route 81 corridor brings significant NO2 into that immediate area. However, while these numbers are good — and a relief from a serious issue – we still need to be vigilant advocating for our region’s air quality. Compressor Stations are still being built, some that have been operating have had or will have more engines or even turbines added to their facilities. Traffic and associated drilling and fracing all contribute to increasing NO2.
And, please refer to the PA Department of Health’s school age asthma statistics, these are on an upward trend.
So, while this is good news, as this is early in the game and we certainly do not want to have NO2 exceeding NAAQS by 278% or 100% or 50% or 1%. We know our air is changing; the emissions inventory and increasing asthma trend indicates that. How much our air will change — that depends on all stakeholders in the conversation – industry taking an interest in air quality issues in the areas they operate, folks maintaining an awareness within their communities and willingness to advocate for monitoring and reasonable air quality improvements, and our regulators, DEP staying vigilant, balancing industry AQ impacts with the needs of public health and safety, along with the environment.
CAC’s modeling report prompted DEP to do some additional sampling within the greater region. Our greater region and Northern Tier Counties are experiencing a growth of compressor stations to correspond with new pipelines commencing operations and wells coming on line. It is good DEP responded to the public concerns with this modeling. We have gathered more information that does indicate our air is changing. How much it will change, well, this is encouraging. Hopefully, not too much.
Emily Krafjack, President