Introduction
LNG terminal developers are finding themselves
under close scrutiny from local and state air-control
boards as well as the EPA to limit emissions from
compressors, vaporizers, ships, harbor tugs, support
vehicles, gas-turbines, construction dust and
a myriad of other sources. Both fugitive and routine
releases are regulated and monitored. According
to the EPA's Office of the Inspector General,
the Gulf Coast has the largest ambient air toxics
monitoring network in the country, larger than
California's, New Jersey's, Oklahoma's, Mississippi's,
and Florida's combined. The Texas Commission on
Environmental Quality (TCEQ) regularly conducts
mobile fenceline monitoring. It is utilizing technologies
like the GasFindIR camera that allows a person
to "see" emissions that can't be seen
by human eye.
Fines for minor infractions are common. For example,
Eastern Shore Natural Gas was fined about $10,000
recently because it did not submit either a Title
V permit application or a Synthetic Minor permit
for the potential of the internal combustion engines
and a natural gas-fired emergency generator to
emit nitrogen oxide at their Bridgeville facility.
Kellogg was fined about $20,000 because a pressure
relief valve on a rooftop refrigeration system
released some anhydrous ammonia. Kellogg was supposed
to report the release immediately, but it took
the company two hours. The actual amount of the
penalty was reduced from $43,829 because the amount
released was 130 pounds, not 820 pounds as originally
estimated.
This workshop will consider LNG terminal air-emission
risks, compliance obligations, potential sources,
regulations and fines, best practices and alternatives
for addressing the challenge.
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