Do air emissions from compressor stations pose serious health risks?

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Do air emissions from compressor stations pose serious health risks?. Pipeline Safety Trust Conference November 21, 2008 Chris 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.
Do air emissions from compressor stations pose serious health risks?
  • Pipeline Safety Trust Conference
  • November 21, 2008
  • Chris 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 Concern
  • Formaldehyde - 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 Effects
  • Genotoxicity 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 StationTransco 130 - Comer, GA
  • “Actual” emissions estimated using emissions factors from the EPA
  • Emissions Estimates for Compressor Station
  • NOx, 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 Station
  • NOx, 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 130AP-42 and Uncertainty
  • Canadian 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. Exposure
  • Emissions 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 Modeling
  • Resulting 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 Risk
  • Uncertainty 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 equivalent
  • No understanding of individual susceptibilities downwind of the station
  • No appreciable understanding of synergistic or compound risk from multiple exposures
  • What We DO Know About the Health Risk
  • Cancer risk begins even at low exposures
  • Cancer risk for children is estimated at 10-100X the risk for adults at the same exposure
  • Respiratory 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 quantities
  • PM 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 risk
  • Should start with improving our understanding of the actual emissions rates
  • And 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)
  • Conclusions
  • Hazardous emissions from compressor stations have been largely overlooked by current regulations
  • Regulatory 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
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