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Do air emissions from compressor
stations pose serious health risks?
Pipeline Safety Trust ConferenceNovember 21, 2008Chris Nidel, MS, JD
Serious? Risk?• serious |ˈsi(ə)rēəs| adjective• 1 (of a person) solemn or thoughtful in character or manner : her
face grew serious.• • (of a subject, state, or activity) demanding careful consideration
or application : marriage is a serious matter.• • (of thought or discussion) careful or profound : we give serious
consideration to safety recommendations.• • (of music, literature, or other art forms) requiring deep reflection
and inviting a considered response : he bridges the gap between serious and popular music.
• 2 acting or speaking sincerely and in earnest, rather than in a joking or halfhearted manner : suddenly he wasn't teasing any more—he was deadly serious | actors who are serious about their work.
• 3 significant or worrying because of possible danger or risk; not slight or negligible : she escaped serious injury.
• risk |risk|noun• a situation involving exposure to danger• the possibility that something unpleasant or unwelcome will
happen
Air Emissions of ConcernFormaldehyde - Reasonably anticipated to be a human carcinogen (NTP), genotoxic
Acetaldehyde - Reasonably anticipated to be a carcinogen (NTP), genotoxic
Acrolein - weakly positive for genotoxic assays
PM - respiratory toxicant, cardiac disease
NOx, Methane, CO, CO2, - asthma, secondary particulates, greenhouse gases, etc.
Dose Makes the Poison?
General premise of toxicology that the dose makes the poison
The idea is that many things are toxic at some dose
However, not all doses of toxic substances have toxic effect
Poison Makes the Dose?How general is the general premise?
Very little is known about synergistic and compound exposures.
Children and other populations may be significantly more susceptible to exposures at the same dose
Exposures to genotoxic compounds do not play by the rules
Cancer, Genotoxins, and No-threshold EffectsGenotoxicity is the presumed mechanism of many carcinogens
Theoretically, one molecule of a genotoxic compound (e.g. formaldehyde, acetaldehyde) can cause a mutation --> leading to cancer
This theoretical possibility leads to the conclusion that there is no “safe” exposure to genotoxins or carcinogens
This means that any exposure creates cancer risk
Compressor Station
Transco 130 - Comer, GA“Actual” emissions estimated using emissions factors from the EPA
Pollutant Emissions (tons/year)
VOCs 396.5
Formaldehyde 182.3
Acetaldehyde 25.65
Acrolein 25.69
Methanol 8.206
Benzene 6.423
NOx 4143.4
PM10 73.7
Emissions Estimates for Compressor StationNOx, CO, and total hydrocarbon (THC) emissions based on testing done in the early 1990’s.
VOC component of the THC estimated by EPA database, approximated at 9.31%
The “actual” emissions for specific VOCs then estimated using the EPA AP-42 emissions factors
Emissions Estimates for Compressor StationNOx, CO, and total hydrocarbon (THC) emissions subject to uncertainty
Testing is ~15 years old
No information regarding overhaul status or age of equipment at testing vs. current performance
VOCs not tested directly
EPA’s SPECIATE database is subject to uncertainty in converting THC to VOCs
AP-42 Emissions factors used to get individual VOC emissions is limited and may significantly underestimate actual emissions
Compressor Age at Transco Station 130Compressors and Manufacture or Reconstruction
DateMainline Unit 1 1951 Mainline Unit 10 1958
Mainline Unit 2 1951 Mainline Unit 11 1959
Mainline Unit 3 1951 Mainline Unit 12 1962
Mainline Unit 4 1951 Mainline Unit 13 1962
Mainline Unit 5 1951 Mainline Unit 14 1968
Mainline Unit 6 1951 Mainline Unit 15 1969
Mainline Unit 7 1951 Mainline Unit 16 1971
Mainline Unit 8 1951 Mainline Unit 17 1980
Mainline Unit 9 1951 Mainline Unit 18 1990
AP-42 and UncertaintyCanadian study looked at emission from a petroleum refinery
Direct testing of emissions using laser based “DIAL” testing
Generated an emissions inventory for facility operations and compared to inventory based on AP-42 estimates
DIAL measurements showed actual VOC emissions almost 15X AP-42 estimates
Dial measurements showed actual benzene emissions 18X AP-42 estimates
Emissions vs. ExposureEmissions estimates in tons/year need to be translated into concentrations such as ppm, ppb, or ug/m3
This is typically done using an air disperson model
Air Dispersion ModelingResulting model is only as good as the inputs, remember, garbage in equals garbage out
The emission rates of the pollutants of concern are the most important inputs to the model for its accuracy
Also dependent on climatological variables, wind speeds and direction, temperatures, and pressures
What We Don’t Know About the Health RiskUncertainty in actual emissions from facility
AP-42 may significantly underestimate or mischaracterize the actual emissions
Transco test data may not be representative of current emissions
TPH emissions may not be accurately represented by the EPA database
No estimates of exposure or dose information from an air dispersion model or equivalentNo understanding of individual susceptibilities downwind of the stationNo appreciable understanding of synergistic or compound risk from multiple exposures
What We DO Know About the Health RiskCancer risk begins even at low exposuresCancer risk for children is estimated at 10-100X the risk for adults at the same exposureRespiratory and other effects of exposure to these VOCs may occur at low exposures (e.g. formaldehyde effects in FEMA trailers)Formaldehyde, acetaldehyde, and benzene (carcinogens or reasonably anticipated to be) are released in significant quantitiesPM and greenhouse gases present both regional and global health risks
Is There a Serious Health Risk?There certainly is some risk based on what is known.How serious is that risk?
We need a better understanding of the uncertainties that we have identified before we can qualify or quantify the riskShould start with improving our understanding of the actual emissions ratesAnd then use these inputs in an air dispersion model
Without Knowing What the Risk Is...The surrounding public should not be subjected to the industry’s experiment - the industry should bear the burden of showing that there is no risk.Currently regulations require almost no control on these emissions - permits merely report emissions
older and higher polluting equipment is effectively grandfathered - similar to coal-fired power plants
Significant improvements in emissions could be achieved by installing new compressors and:
Selective Catalytic Reduction (SCRs) - to reduce NOx emissions
Catalytic oxidation equipment to reduce carbon monoxide emissions (yielding more CO2 however)
ConclusionsHazardous emissions from compressor stations have been largely overlooked by current regulationsRegulatory programs must be improved to address the “loophole”Short of regulatory programs, pipeline operators should take steps to minimize the threat to neighboring populations as well as the regional and global environment by:
better understanding emissions and associated risks
upgrading to modern compressors with control equipment
increasing the use of engineering controls, such as enclosing compressor facilities and treating or scrubbing compressor emissions