Columbia Gulf Transmission Co. Clementsville Station, Source I.D. 21-045-00021
Columbia Gas Transmission Corporation Inez Station, Source I.D. 21-159-00022
Kentucky West Virginia Gas Company, LLC. Beaver Station, Dema, Source I.D. 21-119-00030
Texas Gas Transmission, LLC. Dixie Station, Corydon, Source I.D. 21-101-00124
Kentucky West Virginia Gas Company LLC. Perry Station, Jeff, Source I.D. 21-193-00105
Midwestern Gas Transmission Company Station 2105, Hartford, Source I.D. 21-183-00085
Texas Gas Transmission, LLC. Calvert City Station, Source I.D. 21-157-00037
Tennessee Gas Pipeline Company Station 96, Campbellsville, Source I.D. 21-217-00034
Kentucky West Virginia Gas Company, LLC, Dwale Station, Source I.D. 21-071-00138
Kentucky West Virginia Gas Company, LLC. Line Fork Station, Cornettsville, Source I.D. 21-133-00098
ANR Pipeline Company, Madisonville Station, Source I.D. 21-107-00134
Texas Gas Transmission LLC. Slaughters Station, Source I.D. 21-233-00074
I have reviewed the draft permits for those facilities and activities, and am writing to request that your agency consider revising these specific permits, and the General G-04-001 Title V permit to require reporting, monitoring, inspection and maintenance obligation and imposition of cost-effective controls on emissions of methane from various emission points and activities associated with natural gas compression, transmission and processing activities.
The case for controlling methane emissions from natural gas systems is compelling. Methane emissions from the U.S. gas industry account for some 19-21% of all U.S. anthropogenic methane emissions. Kirchgessner et al., Estimate of Methane Emissions From The U.S. Natural Gas Industry, Section 5.0. Of that, natural gas transmission and processing facilities together were responsible for almost half (49%) of the estimated 33.5 MMTCE (5.8 Tg) of emissions of methane from natural gas systems in the United States, based on 1997 figures. (U.S. EPA Natural Gas Systems, September 1999). 2004 numbers show an increase in the relative contribution from natural gas systems, with such systems responsible for contributing over half (5,658 Gg) of the emissions of methane from energy sources. Inventory of U.S. Greenhouse Gas Emissions and Sinks 1990-2004, p. 3-2, Table 3-2.
In the processing sector, emissions of methane (which comprises 95% of the processed gas) come from compressors and compressor seals, piping, pneumatic devices, and processing equipment, and released (in 1997 totals) 12% of the total emissions of methane from oil and gas activities, or 4.1 MMTCE or 0.7 Tg. In the transmission and storage sector, compressor stations (including blowdown vents, compressor packing, seals, valves), pneumatic devices, pipeline maintenance, accidents, injection and withdrawal wells and dehydrators vent or unintentionally release 37% of the total emissions from the oil and gas sector, or 12.4 MMTCE or 2.2 Tg. Fugitive emissions from compressor stations and from metering and regulating stations account for the majority of the emissions from this stage. Inventory of U.S. Greenhouse Gas Emissions and Sinks 1990-2004, p. 3-50. Production and Distribution account for the remainder of the emissions.
Venting and inadvertent release of methane from processing and transmission is of concern as a pollutant for several reasons. Methane is a chemically reactive greenhouse gas (GHG) and is, molecule for molecule, 20 times more potent as a greenhouse gas than the more-abundant but largely-unreactive CO2. According to research funded by the EPA, NASA and the National Science Foundation and conducted by scientists at Harvard University, Argonne National Laboratory and the EPA, controlling methane emissions would both reduce global warming and air pollution, since methane is directly linked to the production of ozone in the troposphere as well as being a potent greenhouse gas. The researchers found that a reduction of manmade methane by 50% would have a greater impact on tropospheric ozone than a comparable reduction in manmade nitrogen oxide emissions, which do improve air quality by decreasing surface ozone levels, but in a more localized manner and without yielding much benefit in terms of reducing greenhouse warming. According to the researchers, reductions in methane emissions would, however, help to decrease greenhouse warming by decreasing both methane and ozone in the atmosphere worldwide, and this would also help to reduce surface air pollution.
The Climate Change Action Plan Natural Gas STAR Program, is a voluntary EPA-industry partnership, has identified cost-effective technologies and practices that can significantly reduce methane emissions, including low-bleed pneumatic devices; improved inspection, leak detection and maintenance of compressor station pipes and valves; control of glycol recirculation for dehydrators, fuel gas capture retrofits; ring and seal replacement scheduling; and numerous others. Replacement of pressure is natural gas with compressed air in pneumatic control devices would eliminate the constant bleed of natural gas into the atmosphere from these devices, which are one of the largest sources of methane emissions in the natural gas industry. Changing operational practices could reduce the volume of natural gas vented to the atmosphere during maintenance blowdown and purging and when pipeline components are taken offline. Implementing DI&M programs can eliminate an estimated 80% of fugitive methane emissions that result from equipment and pipeline leaks throughout the system. Global Mitigation of Non-CO2 Greenhouse Gases, II-16.
The Division should consider modification of the Title V permit for this industrial sector in order to require the sources to report methane emissions from all sources and equipment, and the adoption of cost-effective I&M programs for reduction of intentional and inadvertent release of methane from processing and compressor stations. In addition to other sources of authority to impose such conditions, 401 KAR 63:020 is plainly broad enough to support such requirements, since methane emissions fall squarely within the ambit of matter which may be harmful to the health and welfare of humans, animals, and plants for which [p]ersons responsible for a source from which hazardous matter or toxic substances may be emitted shall provide the utmost care and consideration, in the handling of these materials, to the potentially harmful effects of the emissions resulting from such activities.
Thank you in advance for your consideration of these comments in conjunction with the issuance of the specific proposed Title V permits for the facilities referenced in this letter, and in conjunction with a possible revision of the general conditions of Title V Permit G-04-001 Revision with respect to all similarly-situated facilities.
cc: Ms. Kay Prince, EPA Region IV (by email)