City of Fort Worth s Natural Gas Air Quality Study Follow-up on Report Recommendations. August 16, 2011

Transcription

1 City of Fort Worth s Natural Gas Air Quality Study Follow-up on Report Recommendations August 16,

2 Outline of Presentation Summary of Conclusions from Eastern Research Group, Inc. (ERG) Compressor Engines regulations (presented by TCEQ) Real-time Ambient Air Monitoring Network (presented by TCEQ) Follow-up on ERG Recommendations Questions 2

3 ERG Conclusions Ambient Air Monitoring and Dispersion Modeling revealed that: Benzene Formaldehyde Acrolein were key pollutants from a public health perspective No health hazard associated with continued exposure to measured levels Ambient Air Monitoring concentrations below both short term and long term screening levels 3

4 ERG Conclusions Required setbacks are adequate for the overwhelming majority of sites Modeled concentrations did not reach levels expected to be associated with adverse health effects Large, line compressor engines may emit acrolein and formaldehyde at concentrations greater than protective health-based screening levels 4

5 ERG Recommendations Encourage the use of air pollution control strategies Catalytic oxidizers on large compressor engines Electric-driven compressor engines Low bleed or no bleed pneumatic valve controls Vapor recovery units on storage tanks Implement enhanced inspection and maintenance of well pads and gas handling operation equipment Conduct additional research evaluating acrolein and formaldehyde emissions Continue ambient air monitoring 5

6 Natural Gas Compressor Engines - TCEQ Ambient Monitoring Network Update Fort Worth City Council Work Session August 16, 2011 Keith Sheedy, P.E., Technical Advisor Chief Engineer s Office Texas Commission on Environmental Quality 6

7 What are we going to discuss? Quick background information What regulations apply to oil and gas compressors in the Barnett Shale area? Federal State An update on the TCEQ s ambient monitoring network 7

8 Barnett Shale Shale and Barnett ozone Shale and ozone nonattainment area nonattainment areas, with Fort Worth area city limits 8

9 Active Oil and Gas Barnett Shale Wells in the 24 formation wells county area 9

10 Barnett Shale Special Inventory Barnett Shale equipment Totals for all inventory types. Emission Source Number of Sources Separators Vented to Atmosphere 16 Total Storage Tanks 20,775 Uncontrolled Glycol Dehydrators 112 Controlled Glycol Dehydrators 184 Stationary Total Engines 3,553 Turbines 37 Turbines Flares Frac tanks 27 Piping Component Fugitive Areas 15,824 Blowdown Vents 7,490 Process Vents 1,191 Heaters/boilers 893 Other Stationary Equipment 1,858 Total Emission Sources 52,038 10

11 Natural gas compressors reported to the TCEQ that are located within the City of Fort Worth Rich-burn engines 0 to to 240 hp hp > 240 hp Lean-burn engines 0 to to 240 hp hp > 240 hp Total Point Source EI Barnett Shale 09 EI Total Approximately 5% of the compressors located in the Barnett Shale area are located within the city limits of Fort Worth. 11

12 Reported compressors 12

13 Emission Controls for Compressors Three generic control techniques have been developed for reciprocating engines: Parametric controls (timing and operating at a leaner airto-fuel ratio) Combustion modifications such as advanced engine design for new sources or major modification to existing sources Post combustion catalytic controls installed on the engine exhaust system. Post-combustion catalytic technologies include: Selective catalytic reduction (SCR) for lean-burn engines Nonselective catalytic reduction (NSCR) for rich-burn engines 13

14 What regulations apply to oil and gas compressors in the Barnett Shale area? Federal regulations State regulations Permit authorization General rules Air rules for specific pollutants 14

15 Federal Air Regulations 40 CFR Part 60 New Source Performance Standards (NSPS) Subpart KKK Equipment leaks of VOC from onshore natural gas processing plants Subpart IIII - Standards of performance for stationary compression ignition internal combustion engines (diesel compressors) Subpart JJJJ Standards of performance for stationary spark ignition internal combustion engines (natural gas fired compressors) 15

16 Federal Air Regulations (cont.) 40 CFR Part 61 National Emission Standards for hazardous Air Pollutants (NESHAP) Subpart V Equipment leaks (fugitive emission sources) mainly a VOC control 16

17 Federal Air Regulations (cont.) 40 CFR Part 63 National Emission Standards for hazardous Air Pollutants (NESHAP) Subpart HH Natural gas production facilities Subpart HHH Natural gas transmission and storage facilities Subpart ZZZZ Reciprocating internal combustion engines 17

18 Federal Air Regulations (cont.) EPA is planning to revise many of the oil and gas regulations found in NSPS (Part 60) and MACT (Part 63) Proposal was published last month Final rules set to be issued by Feb

19 TCEQ Air Rules Texas air rules for gas-fired compressor engines can be separated into three general categories. Permit authorization: Chapter 106 Permit by Rule Chapter 116 Site specific permit or standard permit General rules: Chapter 101 General Air Quality Rules Air rules for specific pollutants: Chapter 111 Visible Emissions and Particulate Matter Chapter 112 Sulfur Compounds Chapter 115 Volatile Organic Compounds (VOC) Chapter 117 Nitrogen Compounds 19

20 What regulations authorize air emissions? A site is authorized to operate under a Permit by Rule (PBR) if its emissions are under prescribed annual emission levels (e.g. 25 tpy VOC and 250 tpy NOx) Common PBRs used in the oil and gas industry: Saltwater Disposal Oil & Gas Handling and Production Facilities (revised PBR became effective April 2011, see handout) Temporary Oil & Gas Facilities Flares Stationary Engines & Turbines 20

21 Air Authorizations Continued Can t qualify for a PBR, a company may be eligible for a Standard Permit. Can t qualify for a Standard Permit, then the company must get a New-Source-Review (NSR) permit. Also Major Sources are subject to Title V of the Federal Clean Air Act and must meet operating permit requirements under that program. TCEQ has delegation of this federal program. 21

22 General Air Rules 22

23 What regulations govern odor issues? Someone has complained to the TCEQ about an odor coming from a compressor station, what TCEQ rule could apply? 30 TAC Nuisance 23

24 What regulation govern upset conditions? A company has an upset at an O&G site that lead to unauthorized air emissions. Are they required to record the information concerning the event? Yes Are they required to report the event to the TCEQ? Depends on what and how much was emitted 30 TAC and have all of the answers 24

25 Other rules that apply regardless of authorization type Chapter 101 State delegation of 40 CFR Part 60 (NSPS rules) and Part 61 (NESHAPS rules) Chapter 111 Control of air pollution from visible emissions and particulate matter Chapter 112 Control of sulfur dioxide and hydrogen sulfide Chapter 113 State adopted 40 CFR Part 63 (MACT rules) Chapter 114 Control of air pollution from motor vehicles - Gasoline and diesel Chapter 115 Control of air pollution from volatile organic compounds (VOCs) 25

26 Chapter 117 NO X Rules for Gas-Fired Compressor Engines Chapter 117 rules for nitrogen oxides (NO X ) are generally associated with specific nonattainment areas for the state implementation plan (SIP), although not necessarily limited to nonattainment areas. The requirements for stationary gas-fired internal combustion engines in Chapter 117 depend on a number of factors: location; site classification: major or minor site as defined in Chapter 117; engine size; burn-type (lean-burn vs. rich-burn); fuel-type; date of installation, relocation, modification, or reconstruction. 26

27 NOx Emission Limits in grams per horsepower hour (g/hp-hr) Rich-burn Lean-burn before 6/1/07 Lean-burn after 6/1/07 >50 hp

28 General Monitoring Requirements for Gas-Fired Compressor Engines In general, the applicable Federal regulations, TCEQ permitting authorizations, and TCEQ Chapter 117 NOx regulations have varying monitoring, recordkeeping, and stack testing requirements. The Chapter 117 rules require initial stack testing for NOx, CO, and O 2 emissions at newly installed and modified compressors. Biennial stack testing is also required. Additional type of monitoring required to show proper operation. NOx and CO emissions are checked/monitored at least quarterly Continuous emissions monitoring system (CEMS) or predictive emissions monitoring system (PEMS) to monitor NOx, CO, and O 2 Totalizing fuel flow meters Run time meters 28

29 An update on the TCEQ s ambient monitoring network 29

30 Current monitors in DFW area Page 30 30

31 Decatur DISH Denton Airport Greenville Eagle Mountain Lake Ft. Worth Northwest Flower Mound Grapevine Fairway Dallas Hinton Auto GC monitors and Canister network Everman Johnson County Luisa Midlothian OFW Kaufman Italy Legend Auto GC monitors VOC canister network 31

32 New Monitors Four new Auto GC monitors TCEQ has a contract with UT Arlington to install and operate the monitors TCEQ is working with a Focus Group to site the monitors. Members include: EPA Texas Department of State Health Services North Central Texas Council of Governments Higher education Public Industry 32

33 SB 527 Regional Air Monitoring Program Established funding for the purchase and operation of a regional air monitoring program TCEQ oversight regarding the type, number, location, and operation of and data validation of the monitors To be operated by a regional nonprofit entity located in North Texas having the following representation: counties, municipalities, higher education institutions, and private sector interests 33

34 Questions? Keith Sheedy, P.E. Ray Schubert Tony Walker Alyssa Taylor, R.E.M. DFW Regional Manager DFW Air Section Manager

35 ERG Recommendations Encourage the use of air pollution control strategies Catalytic oxidizers on large compressor engines Electric-driven compressor engines Low bleed or no bleed pneumatic valve controls Vapor recovery units on storage tanks Implement enhanced inspection and maintenance of well pads and gas handling operation equipment Conduct additional research evaluating acrolein and formaldehyde emissions Continue ambient air monitoring 36

36 Recommendation ERG: Catalytic oxidizers on large compressor engines City actions: Support enhanced controls during future rule making actions 37

37 Permit Certified Emissions Site ID Emissions VOC (tons/yr) CO (tons/yr) Total HAP (tons/yr) Formaldehyde (tons/yr) PS-159 PS-118 PS-119 PS Uncontrolled 80 1, Permit Limits Uncontrolled Permit Limits Uncontrolled Permit Limits Uncontrolled Permit Limits Uncontrolled Permit Limits

38 Standard Permit Example 39

39 Permit by Rule Example 40

40 Staff Recommendation ERG: Electric-driven compressor engines City actions: Currently in use within Fort Worth Continue to work with Industry on compressor engine options 41

41 Recommendation ERG: Low-bleed or no bleed pneumatic valve controls City actions: City of Fort Worth commented to TCEQ in support of these controls: April 2010 Permit by Rule (PBR) proposed revisions August 2010 PBR proposed revisions June 2011 State Implementation Plan (SIP) process Continue to participate in the EPA/TCEQ rule processes 42

42 Point Source Testing Average Annual VOC Emissions from Well Pad Average Tons/Year

43 Recommendation ERG: Vapor recovery units on storage tanks City actions: Most appropriate for oil/condensate tanks Not the only vapor control device City of Fort Worth commented to TCEQ in support of tank controls: April 2010, August 2010 and June 2011 Staff will continue to participate in the EPA/ TCEQ rule process 44

44 Recommendation ERG: Implement enhanced inspection and maintenance of well pads and gas handling operation equipment City actions: Fort Worth Gas Well Ordinance Created in 2001 with last major revision 2009 City Council Resolution ( ) Requested TCEQ to formalize best practices used by most of industry Continue to work with Industry on best management practices including emission controls 45

45 Recommendation ERG: Additional research evaluating acrolein and formaldehyde emissions City actions: Review available permit data Review TCEQ Special Inventory data Research other available data 46

46 Recommendation ERG: Support of continued ambient air monitoring City actions: Continue working with TCEQ on the regional monitoring network 47

47 Next Steps Research available data from compressor exhaust for acrolein and formaldehyde Review and comment on EPA Oil and Natural Gas Industry proposed rules Stay active in State and Federal regulatory enhancements 48

48 Summary Comparison Emission Source Annual VOC Impact (TPY) Residential Natural Gas 1 40 Bulk Gasoline Terminal Dry Cleaning Natural Gas Production Gasoline Stations 1 2,300 Oil and Natural Gas Production 1 4,800 Highway 1 10, National Emissions Inventory (USEPA) Tarrant County wide 2 Natural Gas Air Quality Study (ERG) Fort Worth only All numbers rounded 49

49 Questions? 50