National Enforcement Investigations Center Case Results - MarkWest Clean Air Act Violations Field Investigation & Analytical Support NEIC's Support: • Forensics-based field investigations and analytical support under ISO/IEC: 17025, General Requirements forthe Competence ofTesting and Calibration Laboratories • CAA expertise • Infrared (IR) camera utilization NEIC's Other Capabilities: • Statistical services • Toxicological expertise • CAA 112r, CWA EPCRA and RCRA expertise • Training NEIC'sfindings were instrumental in developingthe enforcement action, which allegedthat MarkWest had failed to apply for, and comply with, the required permits and/or recordkeeping requirements underthe Clean Air Act (CAA) and the Pennsylvania Air Pollution Control Act for venting activities that release VOC emissions. The case was prosecuted by the U.S. Department of Justice (DOJ), and is the first environ mental case to recognize and address the significant VOC emissions associated with pigging and other maintenance operations in shale gas formations. Enforcement results: In April 2018, a settlement was reached with MarkWest resultingin: • $2.6 million in injunctive relief to install and operate technologies to reduce VOC emissions at MarkWest facilities in western Pennsylvania and eastern Ohio • $610,000 civil penalty • $2.4 million to implementthree supplemental environmental projects to install and operate ambientair monitoring stations, and the implementation of a technology for reducing VOC emissions • Emission reductions of 706 tons per year of VOCs and 91.5% annual emission reductions throughout the natural gas collection system How to obtain NEIC's support NEIC provides environ mental fore nsics support for criminal and civil enforcement cases. If you would like more information on NEICorto request laboratory analysis, toxicological support, an investigation, technical assistance, or training from NEIC, please contact us at nei'c project requests@epa.gov. You may also contact your regional enforcement coordinator for more information on requesting NEIC's support on civil projectsand EPA's CIDfor supporton criminal projects. NEIC | Denver Federal Center, Building 25 | Denver, Colorado | 303.462.9000 ^Dst% jSkj \ PRO^ Background: MarkWest and two of its subsidiaries (MarkWest Liberty Midstream Resources, LLC and Ohio Gathering Company, LLC) operate facilities in eastern Ohio and western Pennsylvania designed to gather and transport natural gas and natural gas condensatesthrough pipelines. As part of regular maintenance activities, MarkWest uses devices called "pigs" in pipe lines to remove debris and push through accumulated liquids, in an operation known as "pigging." Pigging requiresthe operatorto depressurizeand vent pipe line gas from the equipment designedto launch and receive pigs. NEIC's support: In July 2015, NEIC investigators provided field technical supportforan investigation of a MarkWest facility in McDonald, Pennsylvania. NEIC investigators recorded infrared (IR) videofootage of air emissions at the pig launching/receiving station, and collected air canister, liquid condensate, and soil samples for analysis at the NEIC laboratory. Chemical analysis identified volatile organic compounds (VOCs) and light hydrocarbons in the air samples. ------- |