Air Quality Management in Shale Gas Production

1. Shale Gas Development/Production Activities and Air QualityMike Abraczinskas, Deputy DirectorNorth Carolina Division of Air Quality Environmental Management Commission November 14, 2013

2. Overview • Characterization of air emission sources and pollutant profiles • Learning from others: • Regulatory framework • Compliance assurance/permitting • Gather the best emissions data • What data are available / needed? • Estimate emissions per well pad • Estimate air quality impacts • Assessment of existing air quality monitoring network • Establish baseline monitoring strategy • Opportunities to share knowledge

3. Air Emission Source Profile Important to consider lifecycle of activities

4. 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 about half of the fractured natural gas wells in the U.S.”

5. 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 oil and gas • 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.

6. 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. • This information will help shape DAQ’s permitting approach.

7. Emissions Data • 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 • Further study planned in 2014: • Combine estimates of number of wells in a particular area, generate emissions estimates. • Allows local and downwind air quality impacts to be assessed.

8. Assessment of Air Quality Monitoring Network - Background • 2012 DENR Study – recommended collection of baseline air quality data. • Session Law 2012-143 – requires rules related to collection of baseline data in areas where oil and gas exploration and development activities are proposed. • DAQ has the authority and expertise to accomplish baseline monitoring objectives without additional rule making.

9. Where to monitor? • 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. • Sites near the Triassic Basin, but not within the area that may be considered most promising for shale gas production. • Sanford sub-basin in Lee County • No existing air monitoring in Lee County. • Recommendation: Establish a multi-pollutant air monitoring site in Lee County.

10. NC Air Quality Monitoring Network Dan River basin Deep River basin Sanford sub-basin New Lee County air monitoring location

12. Baseline Monitoring - Summary 127 • 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.

13. Opportunities to Share Information in 2013 • Mining and Energy Commission • Environmental Standards Committee • Monitoring, testing, permitting, odor, dust, handling of confidential info. • Coordinated Permitting Study Group • Working on a report to the Environmental Review Commission • 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

14. 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 Project Plan for Baseline Ambient Air Monitoring near Potential Shale Gas Development Zones in Lee County, NC http://www.ncair.org/news/shale/