DEQ's Presentation to the SAPCB on November 9, 2018 regardng ...
Proposed Article 6 Permit for the Atlantic Coast Pipeline Buckingham Compressor Station Virginia State Air Pollution Control Board Meeting Nov. 9, 2018 Michael Dowd, Director Air and Renewable Energy Division Tamera Thompson, Manager Office of Air Permit Programs Patrick Corbett Office of Air Permit Programs Buckingham Compressor Station Buckingham Compressor Station (BCS) is one of three compressor stations for the Atlantic Coast Pipeline (ACP) o Only ACP compressor station in Virginia o Most stringently regulated of the three Uses four natural gas combustion turbines with a total of ~55,000 horsepower (hp) to pump gas through pipeline Is classified as a minor stationary source per Virginias permit regulations 11/9/2018
DEQ Presentation - BCS (Day 2) 2 Permits Considered by the Board Pollutant BCS (tpy) Dominion - Virginia City Dominion (tpy) Warren (tpy) Dominion Greensville (tpy) NOx 34.2 1,920.54 317.7
159.1 184.5 PM2.5 43.24 329.24 159.1 184.5 Note: BCS emissions includes all units at the facility, other facilities only include major combustion units. 11/9/2018 DEQ Presentation - BCS (Day 2) 3 Proposed BCS ~55,000 hp natural gas-fired natural gas compressor station
*Artist rendering from ACP website 11/9/2018 DEQ Presentation - BCS (Day 2) 4 Location of BCS Buckingham County on the north side of Route 56, 5.1 miles northwest of the intersection of Route 60 and Route 56 Frederick Clarke Loudoun Arlington Warren Shenandoah Fairfax
Alexandria City Fauquier Rappahannock Prince William Page Rockingham Culpeper Stafford Madison Highland Greene Orange King George Spotsylvania Augusta Bath
Albemarle Charlottesville City Caroline Louisa Essex Rockbridge Alleghany Fluvanna Nelson Goochland Amherst Botetourt Buckingham
Powhatan Hanover Richmond City Henrico Craig Lynchburg City Tazewell Dickenson Salem City Roanoke City Roanoke Giles Buchanan Appomattox
Amelia Prince Edward Campbell Montgomery Wise Russell Wythe Nottoway Lunenburg Floyd 11/9/2018 Washington Bristol City Newport News City
Hampton City Sussex Norfolk Pittsylvania Halifax Scott Surry Dinwiddie Charlotte Franklin Smyth Lee New Kent
Charles City Bedford Bland Pulaski Chesterfield Carroll Grayson Henry Patrick Portsmouth City Brunswick Virginia Beach City Southampton Mecklenburg Danville City
DEQ Presentation - BCS (Day 2) Greensville Suffolk City Chesapeake City 5 DEQ Regional and Central Office Collaboration Coordinated effort between the Piedmont Regional Office (PRO) and Central Office (CO) PRO Cheryl Mayo Permit Writer James Kyle Permit Manager Kyle Winter Deputy Regional Director James Golden Regional Director
CO Pat Corbett Permitting Tamera Thompson - Permit Manager Bobby Lute Air Quality Modeling Mike Dowd Air and Renewable Energy Division Director 11/9/2018 DEQ Presentation - BCS (Day 2) 6 Air Permit Process - Overview Source determines activity and location Siting approval is the responsibility of the Local Government via zoning o Need local government approval to have a complete application
Source completes an application for a permit to construct and operate DEQ processes application for statutory and regulatory compliance 11/9/2018 DEQ Presentation - BCS (Day 2) 7 Air Permit Process DEQ Review DEQ reviews application Reviews type and quantity of pollutants emitted o Article 6 uses uncontrolled emission rate (UER) o UER is based on running at maximum capacity for 8,760 hours/year without controls o Pollutants with a UER less than the exemption threshold are not reviewed further Determines what federal and state regulations may apply Reviews Best Available Control Technology
(BACT) to maximize emission reductions Review air quality analyses to ensure protection of public health 11/9/2018 DEQ Presentation - BCS (Day 2) 8 Air Permit Process DEQ Review (contd) DEQ ensures monitoring, recordkeeping and reporting to assure compliance DEQ drafts permit documents o Holds public comment period if required o Holds public hearing if required BCS public comment period and hearing due to significant public interest 11/9/2018 DEQ Presentation - BCS (Day 2) 9
Minor New Source Review Permitting Process Article 6 (9VAC5-80-1100 et seq.) lays out how Virginia manages new construction that is not subject to major new source review BACT review was nationwide and resulted in the most stringent limitations Assured public health protection with extensive modeling Provided for ample public involvement through public comment period and hearing, informational briefing, and local stakeholder meeting 11/9/2018 DEQ Presentation - BCS (Day 2) 10 BCS Application Background Application initially received in 2015 o Local government approval received February 2017 o Application substantially updated in August 2017 and May 2018 o Permit draft completed August 2018 Public Comment Period Start Aug. 8, 2018
Informational Briefing Aug. 16, 2018 Public Hearing Sept. 11, 2018 Comments Considered until Sept. 21, 2018 11/9/2018 DEQ Presentation - BCS (Day 2) 11 Emission Units at BCS Four natural gas-fired compressor turbines: o One 15,900 hp Solar Mars 100 turbine o One 11,107 hp Solar Taurus 70 turbine o One 20,500 hp Solar Titan 130 turbine o One 6,276 hp Solar Centaur 50 turbine Venting of natural gas One natural gas-fired emergency generator (2,175 hp) Exempt by size o One small natural gas-fired boiler for space heat o Four small natural gas-fired line heaters o Two small storage tanks for accumulated liquids 11/9/2018
DEQ Presentation - BCS (Day 2) 12 Generic Compressor - Example 11/9/2018 DEQ Presentation - BCS (Day 2) 13 Pollutants Subject to Article 6 The following pollutants underwent Article 6 permitting based on the application for the BCS: o o o o Nitrogen Oxides (NOx) Carbon Monoxide (CO) Volatile Organic Compound (VOC)
Particulate Matter having an aerodynamic diameter of 10 microns (m) or less (PM10) o Particulate Matter having an aerodynamic diameter of 2.5m or less (PM2.5) o Formaldehyde o Hexane 11/9/2018 DEQ Presentation - BCS (Day 2) 14 BACT Review Article 6 BACT for Article 6 is defined at 9VAC5-50-250 BACT is a case-by-case determination Evaluation of the sources proposal includes: o Review of similar permits issued across the State o Review to ensure BACT is at least as stringent as applicable Chapter 40, NSPS, MACT standards BCS review looked for permits nationwide 11/9/2018
DEQ Presentation - BCS (Day 2) 15 BACT Limitations Emission limitations are set based on the BACT analysis Any BACT limit must have a compliance component and be enforceable as a practical matter Limits in an Article 6 permit are generally federally-enforceable 11/9/2018 DEQ Presentation - BCS (Day 2) 16 Pollution Control Technology Overview NOx Selective Catalytic Reduction (SCR) o Most turbine permit limits are generally 15 ppm o BCS turbines without controls achieve 9 ppm CO, VOC, Formaldehyde Oxidation catalyst
o Most turbine permit limits are 25 ppm for CO and 2.5 ppm for VOC Catalysts enable pollutant reductions over a shorter time and wider temperature range SCR Adds ammonia to reduce NOx 11/9/2018 DEQ Presentation - BCS (Day 2) 17 SCR Overview 11/9/2018 DEQ Presentation - BCS (Day 2) 18 BACT - Turbines The proposed air permit does not specify a control efficiency for the SCR or the oxidation catalyst o Limits emissions to 3.75 ppm NOx, 2 ppm CO and 1.25
ppm VOC, <0.24 lb/hr formaldehyde Performance testing every two years o ongoing monitoring of temperatures and ammonia flow rate ensures emission standards are continually met Most stringent permit requirements found for natural gas compressor turbines 11/9/2018 DEQ Presentation - BCS (Day 2) 19 Natural Gas Emissions Natural gas contains: o Methane (88%), Ethane (5.1%), VOC (2.6%), Hexane (0.16%) Natural gas is emitted by the following mechanisms: Equipment leaks Emissions from line cleaning operations pigging Emissions from start-up and shutdown of compressor turbines
Emissions from emergency system testing 11/9/2018 DEQ Presentation - BCS (Day 2) 20 Equipment Leaks Piping connection points o Valves o Pumps o Flanges Minimize by on-going inspection and repair o Leak detection and repair, also known as LDAR 11/9/2018 DEQ Presentation - BCS (Day 2) 21 BACT - Equipment Leaks
Daily Audio, Visual, Olfactory (AVO) site walk-thru Quarterly Leak Detection and Repair Survey o Uses camera to see leaks Fix leaks as quickly as possible o Potential penalties if leaks are not fixed within a specified timeframe Most stringent requirements found 11/9/2018 DEQ Presentation - BCS (Day 2) 22 BACT Pigging operations Pig industry term for the method of removing condensation from natural gas as safety measure Uses natural gas pressure to push Pig pushes liquids to collection point Minimize number of events 11/9/2018
DEQ Presentation - BCS (Day 2) 23 Compressor Start-up and Shutdown Turbines do not run continuously Work on compressor may require opening of piping If turbine is shut down, dry seals normally stop operating Shutdown venting requires start-up purge to remove oxygen 11/9/2018 DEQ Presentation - BCS (Day 2) 24 BACT Compressor Start-up and Shutdown Compressor case pressure increases Use Vent Gas Reduction System (VGRS) to reduce pressure Avoids need for venting event 11/9/2018
DEQ Presentation - BCS (Day 2) 25 BACT Compressor Start-up and Shutdown (contd) Minimize number of vented shutdowns Minimize pressure in compressor case before venting Ongoing monitoring of VGRS pressures Some compressor stations have a VGRS, but its use is voluntary and not required by permit 11/9/2018 DEQ Presentation - BCS (Day 2) 26 BACT - Emergency Shutdown System Testing Test of system for emergency situations Opening emergency valve during test vents natural gas Testing required once per year (PHMSA)
Capping blocks pipe after the emergency valve Tests valve with little vented natural gas Some compressor stations use caps but its use is voluntary and not required by permit 11/9/2018 DEQ Presentation - BCS (Day 2) 27 ACP Limit Comparison Pollutant / Process Buckingham Application Buckingham Draft Permit West Virginia (ISSUED)
0.00001 tpy 0.3 tpy 0.02 tpy 5 ppm 5 ppm 1.25 ppm No limit No limit 5.8 tpy 0.36 tpy 25 ppm No limit No limit No limit 0.04 tpy No limit 1.5 tpy 11/9/2018 DEQ Presentation - BCS (Day 2)
28 Co-Benefit Methane Reductions Capped ESD testing 4.1 Million Cubic Feet of natural gas venting avoided - 2,013 tpy (CO2e) o 99+% reduction Reduced startup and shutdown venting 100 million cubic feet of natural gas venting avoided almost 51,000 tpy (CO2e) o 99+% reduction Unquantifiable reductions from daily AVO and quarterly LDAR analysis assumes no reductions 11/9/2018 DEQ Presentation - BCS (Day 2) 29 Air Quality Analysis - Modeling National Ambient Air Quality Standards (NAAQS) o Health-based concentrations
o Rules for entire U.S. A variety of averaging times depending on pollutants o As short as one (1) hour o As long as one (1) year Buckingham County meets and will continue to meet all standards 11/9/2018 DEQ Presentation - BCS (Day 2) 30 Modeling Background Background values are based on measured air concentrations Selected background monitor sites are conservative o Higher population o Higher emissions from facilities, vehicles and other sources DEQ modeled local industrial sources in the vicinity of BCS o Modeled impact includes these local sources and BCS
Background concentrations are added to the modeled impacts to determine NAAQS compliance 11/9/2018 DEQ Presentation - BCS (Day 2) 31 Modeling Emissions Emissions from BCS Worst-case emissions maximum or peak values Analyzed multiple operational scenarios Dependent on pollutant and averaging time 11/9/2018 DEQ Presentation - BCS (Day 2) 32 Modeling Results The following NAAQS were modeled following EPA procedures:
1-hour NO2 Annual NO2 1-hour CO 8-hour CO 24-hour PM2.5 Annual PM2.5 24-hour PM10 8-hour ozone All results are less than the applicable NAAQS and protect public health 11/9/2018 DEQ Presentation - BCS (Day 2)
33 Air Toxics Air Quality Analysis Virginia Regulation for toxic pollutants Significant Ambient Air Concentration (SAAC) o Health-based standard o One-hour and annual guidelines o Dependent on pollutant impact Emissions from BCS o Worst-case emissions maximum or peak o Analyzed multiple operational scenarios 11/9/2018 DEQ Presentation - BCS (Day 2) 34 Air Toxics Modeling Results The following standards were modeled: o One-hour formaldehyde o Annual formaldehyde o One-hour hexane
All modeled impacts are less than their significant ambient air concentrations and are protective of human health 11/9/2018 DEQ Presentation - BCS (Day 2) 35 Public Comment Public comment period started Aug. 8, 2018 Informational briefing held Aug. 16, 2018 Public hearing conducted Sept. 11, 2018 Public comments considered until Sept. 21, 2018 Public Hearing o 191 persons signed in as attending the hearing
o Oral comments were received from 60 individuals Written comments o More than 5,300 comments received Various elected officials Dominion Various Environmental Groups Southern Environmental Law Center, Appalachian Voices, Natural Resource Defense Council, Chesapeake Bay Foundation, etc. 11/9/2018 DEQ Presentation - BCS (Day 2) 36 Summation of Comments Main issues raised during the comment period included:
11/9/2018 Limits do not reflect BACT Facility should use electric turbines Facility impacts are undetermined/too high Risk analysis should have been required NAAQS and SAAC standards are not adequately protective Any increase in air pollutants is unacceptable Monitoring is inadequate Opposition to the use of fracked gas and fossil fuel use Environmental Justice issues Site Suitability issues Support for the facility DEQ Presentation - BCS (Day 2) 37 DEQ Response to Permit Comments Permit is clarified that ppm is by volume on a dry basis NOx CEMS are not required due to extensive monitoring already in permit
Quicker repair times are not required o Requirements in permit are more stringent than in any DEQ could find o Requirements already require rapid attempts Operation below 50% load is prohibited Warranties are not relevant given permit requirements Permit language is adjusted to reflect accurate nomenclature of operational mode 11/9/2018 DEQ Presentation - BCS (Day 2) 38 DEQ Response to BACT Comments Limits in initial draft permit have not been changed in the current draft o Permit limits are most stringent o Referenced sources are much larger electricity generating facilities, not compressor stations Electric turbines do not represent BACT o Redefinition of the source
Most stringent permit requirements DEQ found 11/9/2018 DEQ Presentation - BCS (Day 2) 39 DEQ Response to Air Quality Comments Air quality impacts are not underestimated o Modeling conforms to the Guideline on Air Quality Models (40 CFR Part 51, Appendix W) o Modeling assumptions are designed to be conservative to protect human health and the environment Selected background monitor sites are conservative o Population density higher at selected monitors o Number of area sources higher at selected monitors o Transportation emissions higher at selected monitors 11/9/2018 DEQ Presentation - BCS (Day 2)
40 DEQ Response to Air Quality Comments NAAQS and SAAC standards are protective o Standards are health-based and set acceptable ambient air concentrations with ample margin of safety o Modeling demonstrates that the proposed facility will not cause or contribute to a violation of any applicable NAAQS or SAAC Revisions to the air quality standards may require facility to reduce emissions DEQ used maximum emissions for applicable NAAQS and SAAC averaging times Chesapeake Bay Impacts o No air regulatory authority TMDL issue o Clean Air Act already generating sufficient reductions 11/9/2018 DEQ Presentation - BCS (Day 2) 41
DEQ Response to Risk Analysis NAAQS and SAAC health-based Standards fully protect human health with ample margin of safety Compressor stations cited not comparable to BCS o Gas quality, permit requirements, proximity to gas fields No regulatory authority for the multitude of aspects o Individual health impacts genetics, stress, health history o Regulate water, traffic, noise, etc. 11/9/2018 DEQ Presentation - BCS (Day 2) 42 DEQ Response to Environmental Justice Comments Proper regulatory implementation to protect human health Community Outreach o Posting of notice on website early (Aug. 4, 2018)
o Published notice (Farmville Herald and Buckingham Beacon) o Dedicated web page continually updated o Explanations of regulatory concepts in analysis o Local stakeholder meeting o Local informational briefing o Documents at library o Many calls and emails with interested persons o Posting of all comments o Posting of board documents 11/9/2018 DEQ Presentation - BCS (Day 2) 43 DEQ Considered the Four Factors in Va. Code 1307E 1. The character and degree of injury to, or interference with, safety, health, or the reasonable use of property which is caused or threatened to be caused 2. The social and economic value of the activity involved 3. The suitability of the activity to the area in which it is located 4. The scientific and economic practicality of reducing or
eliminating the discharge resulting from such activity 11/9/2018 DEQ Presentation - BCS (Day 2) 44 DEQ Considered 1307E.1 and 4 1. The character and degree of injury to, or interference with, safety, health, or the reasonable use of property which is caused or threatened to be caused Worst case air quality modeling to assure protection of public health 4. The scientific and economic practicality of reducing or eliminating the discharge resulting from such activity BACT analysis to assure application of best available control technology 11/9/2018 DEQ Presentation - BCS (Day 2)
45 DEQ Addressed the Economic Value and Site Suitability requirements 1307E.2 and 3 2. Buckingham County Board of Supervisors required to certify BCS met all local zoning requirements before DEQ issued draft permit and commenced public comment 3. Certification means county thoroughly examined BCS and determined it complied with all local ordinances and other requirements 11/9/2018 DEQ Presentation - BCS (Day 2) 46 Site Suitability DEQ has never interpreted 1307E as giving it authority to overrule decisions of local elected officials on economic, safety, or site suitability matters not related to clean air Although 1307E appears to contain no boundaries,
DEQ has always interpreted the section as limiting 1307Es application to clean air matters 1307E must be read in the context of the State Air Pollution Control Law and Virginia Code in its entirety 11/9/2018 DEQ Presentation - BCS (Day 2) 47 Site Suitability Local Zoning Authority Va. Code 15.2-2200, et seq., confers zoning authority on local jurisdictions oEncourage localities to improve the public health, safety, convenience and welfare of citizens and take into consideration of needs of agriculture, industry and business in future development 15.2-2212 requires planning commissioners to be residents of the locality, qualified by knowledge and experience to make decisions on community growth and development 15.2-2280 provides localities may regulate and determine the use of land, buildings and structures for agricultural,
business, industrial, residential and other specific uses 11/9/2018 DEQ Presentation - BCS (Day 2) 48 Site Suitability Local Zoning Authority (contd) 15.2-2283 describes the purposes of zoning and sets forth a long list of factors locality should consider when making zoning and land use decisions based on intent of 15.2-2200 15.2-2311 and 15.2-2314 set forth detailed procedures for those aggrieved by local zoning decision to appeal first to the board of zoning appeals and then to Circuit Court Appeal to court, not DEQ No indication 1307E intended to trump local jurisdictions zoning authority under VA Code 15.2-2200, et seq. 11/9/2018 DEQ Presentation - BCS (Day 2) 49 Site Suitability
Buckingham County Special Use Permit Buckingham County Board of Supervisors approved Special Use Permit for BCS by 5-0 vote (2 abstentions) on Jan. 5, 2017 Letter from Buckingham County zoning administrator to ACP on Jan. 11, 2017, contained 41 comprehensive conditions Board of Supervisors attached to the Special Use Permit o Requirements related to operations, safety, emergency procedures, facility design, appearance, location, construction, noise, light, traffic, compliance and enforcement Certification received on Feb. 21, 2017 11/9/2018 DEQ Presentation - BCS (Day 2) 50 Permit DEQ approval Board approval
State Water Control Board State Corporation Commission Federal Energy Regulatory Commission Local approval Local approval Local approval Article 6 Chapter 20 Chapter 50 Chapter 60
Chapter 80 Regulations for the Control and Abatement of Air Pollution Air Pollution Control Board NAAQS Department of Environmental Quality HAPS Clean Air Act Local Authorities BACT Board Decision
Information the Board will consider when making a decision on todays permit action: Verbal and written comments received during the public comment period that have been included in the record Any explanation of comments previously received during the public comment period made at the Board meeting Comments and recommendations from DEQ DEQ files 11/9/2018 DEQ Presentation - BCS (Day 2) 52 Questions? 11/9/2018 DEQ Presentation - BCS (Day 2) 53
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