The Gas Drilling activity going on throughout Northern Pennsylvania should be of grave concern to New York residents across the Southern Tier. Bradford and Susquehanna Counties are making some of the most potent air pollution in the Northeast. The Jet Stream for this part of the country is an inverted “L” shape that basically starts in Pittsburgh, PA and continues north toward the Hudson Valley of New York where it moves west toward Syracuse in a wave-like motion. The affected area within the Jet Stream is roughly 210 miles, so if Towanda, PA (in Bradford County) is “ground zero” for Northern Pennsylvania Gas Drilling, The Village of Sidney, NY (in Delaware County) is only 75 miles down-wind in the Northeast Jet Stream. That puts most of the members of the Stop The Pipeline group in the affected area of the Jet Stream.
According to Pennsylvania Marcellus Shale Data on Unique Marcellus Shale permits by County, Bradford County is by far the leader with 1976 permits and 639 plus (they’ve added some since) “live” wells in production. With the exception of Susquehanna County, which borders to the East, Bradford County’s total more than doubles the total of every other county in the State for permits and “live” wells. Susquehanna County ranks second with over 1300 permits and over 400 “live” wells. To give us proximity of what we are talking about, Susquehanna County, PA is located due south from Sidney, NY while Bradford County neighbors them to the west just south of the Tri-Cities of Binghamton/Vestal/ Johnson City. To make matters worse, The Ozone Standards in Northern PA are still being based on 1997 Standards, for compression engines, engine exhaust, re-boilers, ventilators, thermal oxidizers, flaring and fugitive methane. Produced Water Tanks/Containers (flow-back pits) are not even listed and are not subject to any standards. Methane Natural gas is nearly 20 times more potent than Carbon Dioxide as a greenhouse gas(GHG). Most experts say 3-5% of extracted Methane escapes during the production and delivery process. Add that to the fact that 6% of all well casings will fail within the first year, and we have a recipe for disaster.
How Does Gas Extraction And Processing Affect The Air?
Each stage of natural gas production and delivery causes air pollution. Overall the impact on air quality includes emissions of volatile organic compounds (VOCs), nitrogen oxides(N0x), particulates, hazardous air pollutants (HAP) including methanol, ethylene glycol, hydrochloric acid, acetic acid, benzene, diethyl benzene, arsenic, radon and formaldehyde, among others. VOCs mix with air and sunlight to produce ground- level ozone, which is the primary ingredient of smog, along with N0x and HAPs. Other pollutants such as benzene, diethyl-benzene, radon and formaldehyde have been linked to elevated levels of cancer and neurological damage. When you add in all of the truck trips, over 1500 truck trips per well site, and the fact that most of those trips are being done on dirt roads that kick up dust pollution, and you can see why it is essential to speak out at Public Hearings. Every stage of every operation breaks down over time and leaks will add to the pollution. Flow-back pits, compression stations and pipelines are all in need of strict regulation. The Clean Air Council (CAC) has established thresholds for Air Pollutants and the DEP is not supposed to permit until the company doing the filing has proven they can meet the qualifications. As a group, in cooperation with CAC representatives, we have been trying to argue at public hearings for the DEC to demand that all permits be made to qualify at 2008 standards, which are more stringent, and not the 1997 regulations. DEP Air Quality Program Manager, Muhammad Q. Zaman and Northeast PA- Area DEP Rep Mark Wejkszner maintain that they are following 2008 protocol for Air Quality Standards, but the CAC argues against it. Phone calls to the Wilkes Barre, PA office are not returned and haven’t been for some time now. The United States Environmental Protection Agency (EPA) showed some interest in the Susquehanna County air and water situations and even gave us some encouraging words from former Director, Lisa Jackson. “We’re looking into Dimock, PA and we are on this”, said Jackson at a 2011 Philadelphia, PA conference held at the Academy Of Natural Sciences. Upon exiting the agency, phone calls were then directed to Diana Esher who is the Director of the EPA Air Protection Division. Phone calls to Esher are no longer returned as well.
The Problem Is In The Permitting Process
When Tom Corbett became Governor of Pennsylvania, he instituted one of the most extensive Gas Drilling operations in the history of the state. Pennsylvania quickly became the most productive Natural Gas drilling State in the East. He revamped the DEP and appointed Industry Reps to key director positions. Some very good DEP reps and assistants were either let go, or resigned. Corbett took “drill baby drill” to new heights, and is commonly referred to across Susquehanna County as Tom Cabot, a reference to Cabot Oil and Gas, which is the number one Natural Gas speculator in the County. DEP Secretary/Director Michael Krancer, is an industry manager who worked for companies like Exxon/Mobile and Chesapeake Oil and Gas. Krancer was very helpful to our group, early on in the process, but he quickly joined the other industry reps across the state and he hasn’t returned a phone call to any of our group members for nearly a year.
Once Corbett’s ducks were all in a row, he began changing the Energy Policies, which include permits. Most of the current permits are the lowest level and least regulated GP-5 Permit. GP-5 is a very general permit that requires little to no conformation to CAC Standards and is very easily rubber stamped across Bradford and Susquehanna Counties. There are very few Title V permits and the industry avoids these tougher regulations by using equipment that emits HAPs and VOCs that are below the thresholds. For instance, a compressor station permit will include a Caterpillar G3608LE w/ Oxid Cat.- this is a 1490 Horse Power (HP) Diesel compression engine with emissions that fall just below the limits for N0x, VOCs and GHG. The better and more efficient 1500 HP Caterpillar Diesel compression engine would emit pollution that would send the permit into Title V and subject the Gas Company of record to the more stringent thresholds. To make matters worse, most of the pipeline/gathering line companies are including, four 1490 HP Caterpillar Diesel fired compression engines, with each piece emitting the same amount of pollutants, and the DEP is still issuing the permits. Some folks refer to this process as “piece permitting” where the DEP considers a single engine and disregards the Aggregate, Cumulative effect of all of the pieces on the site to be permitted. Aggregation of sources into one Title V permit would ensure proper equipment, monitoring and public oversight. This is all avoided through GP-5 permitting.
Figure one, above, shows an average drilling site and includes all of the pieces that are permitted, such as: the compressor engines, well pad, re-boiler, dehydrator and ventilator among others. Figure two, shows a small 25 square mile cross-section of Susquehanna County from Great Bend down to Hop Bottom and over to Dimock and up to Friendsville. Each push pin represents a Williams owned compressor station. There are 15 of them in that section. There are also some “live wells” in the area as well. There are gathering lines and pipelines included in the mix, and this whole menagerie of gas drilling operations was permitted by the different companies involved, some of which are subsidiaries of the others. Cabot, Chief, Range, Hess and Chesapeake are all Gas Companies that are speculating in that area. Talisman Energy is speculating nearby but outside the perimeter. Angelina, Williams, Laser and Southwest are all in on the gathering lines/pipelines process and their operations are also adding to the pollution of the area. Leatherstocking is permitted just outside the perimeter for service to the Montrose area, but they are only recently under construction. So you see, what happens in Pennsylvania should be of grave concern to New Yorkers, especially those residents that live across the Southern Tier, because they are right in the middle of the down-wind Jet Stream.
What Are The Thresholds Set By The CAC
When you see the following numbers and then look, again at figures one and two, the entire operation and its aggregate pollution becomes mind-boggling.
An average four engine compressor station includes dehydrators, a re-boiler, thermal oxidizers and ventilators. Keep in mind that all of the fittings and hoses and clamps are all sources of possible leakage. The famous Williams Lathrop Compression Station explosion from March 24th of 2012 was the direct result of Human Error in the area of leakage with old compression and hoses and fittings not properly maintained. A Title V permit for that site would have included a monitoring system with shut-down capabilities and the proper oversight in place to head things off before they get out of control. That still may not have been enough in that case, but one will never know, since the entire site was “piece permitted” by GP-5 permits.
The established limits of pollutants are as follows; Nitrous Oxide has a limit of 100 tons per year, Volatile Organic Compounds have a limit of 50 tons per year, and the Green House Gas limit is 75,000 tons per year. An average Williams compressor station will emit as follows; N0x- 44 tons per year, VOCs- 26.4 tons per year and GHG- 71,000 tons per year. Williams is permitting just under the limits in all of the major categories, and the drilling sites are not taken into consideration. And let’s not forget the flow-back pit or the flaring, shall we? So, if we look at the two figures above and see how many drilling operations there are in one 25 square mile cross-section of Susquehanna County, which is the second largest polluting County in PA, these numbers are staggering and we aren’t even at Towanda, which is the absolute worst of the worst.
A regular group of 8 to 10 of us will travel from hearing to hearing trying to convince the DEP to enforce tougher policies and SOP. The CAC holds workshops and puts out power-point presentations and has lots of new and updated information on its website. When we seem to make headway in some crucial areas, Corbett will add a new wrinkle to the regulations or subtract a crucial step in the permitting process which allows the gas Companies to run rough shod across the two PA Counties.
What Can Be Done?
To his credit, Corbett has allowed the State of Pennsylvania to conform to Green Completion by 2014. Green Completion captures fugitive Methane during “Flaring”, reduces gas emissions during initial well drilling, and it also captures some toxic vapors on dehydrators and ventilators.
Corbett should allow the DEP to do what they are supposed to do, their job. Implementing Best Available Technology (BAT) on all pieces to be permitted is another good suggestion. Supporting Aggregation of Sources into a Title V permit would be outstanding, but don’t hold your breath in the gas field waiting for it. Better monitoring equipment on site and allowing local EMS to help as to get a better jump on emergencies is a great suggestion, since current EMS- SOP is to hang back at a designated perimeter and wait for Gas Company officials to arrive. Use of infrared monitors on all sites for flaring and leaks would also be listed as a BAT. Speak up at your public hearings and don’t be afraid to go to other hearings and speak. The more comments and the more people learn to just say no, the better it will be for everyone.
So you see, what happens just below the border in the Northern Pennsylvania gas fields should be of grave concern to New York. Especially those residents living in the Southern Tier and within the down-wind Jet Stream of Towanda, PA, ground zero for Northeast gas drilling.
The following sources are sited; Clean Air Council- Philadelphia, PA, Penn State University, Slippery Rock University, Pennsylvania Marcellus Shale Data, Lock Haven University, Moravian College, Pennsylvania Department of Environmental Protection, New York State Department of Environmental Conservation, Anthony Ingrafia, Cornell University, Stop The Pipeline, Friends of Middlefield, Caterpillar Corporation, Cabot Oil and Gas, Talisman Energy, John Deere Corporation, Friends Of Sustainable Sidne