U.S. EPA Classifies Fracking Equipment as Non-Intermittent
Posted: April 5th, 2012Author: All4 Staff
U.S. EPA has determined that emissions from drilling and well completion equipment at high-volume hydraulic fracturing (fracking) operations should not be considered intermittent emissions sources in relation to dispersion modeling for short-term National Ambient Air Quality Standards (NAAQS). The U.S. EPA determination means that fracking operations that are required to conduct NAAQS dispersion modeling because they trigger major source permitting requirements or because they receive a request to perform modeling at a state’s discretion will be required to model their short-term maximum emission rates just as any other “full-time” emission source would be required to do. Industry had argued that although fracking operations occur over a period of months they are intermittent over a 24 hour period and therefore should be exempt from short-term NAAQS modeling requirements.
The New York State Department of Environmental Conservation (NYSDEC) was originally concerned with short-term modeling requirements for fracking operations because they had prepared a draft Supplemental Generic Environmental Impact Statement (SGEIS) which employed short term nitrogen dioxide (NO2) NAAQS emissions modeling to develop emissions control guidelines and an environmental impact analysis for fracking equipment. It is ALL4’s experience that inexact and ultimately conservative dispersion modeling is not an appropriate tool to develop and implement prescriptive and specific control requirements. The Independent Oil and Gas Association of New York (IOGA) argues that fracking equipment should not be included in a dispersion modeling analysis since the engines meet the non-road sources definition, and instead a “performance-based” regulatory approach should be developed. Modeling well completion and drilling equipment as stationary sources at unrealistic operating hours ultimately results in exceedingly worst-case modeled concentrations, potentially causing the requirement of impractical emission controls. Industry fears overestimating the environmental impacts of fracking could specifically cause the shale-gas development in New York State to lose its competitive edge compared to other states oil and gas markets.