resource advisory councils conference grand junction, colorado february 25, 2009
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BLM’s management of air resourcesAddressing air analysis in NEPAStatus of Field Office air analyses for RMPsAir pollutant emission controlsRegional assessments
Air Resource Management Air quality manual
Manual sets forth the authority, policy, objectives, program structure
BLM must analyze the potential effects of BLM-authorized activities on air quality as part of the planning, environmental review, and decision making processes
Air quality is determined by atmospheric emissions and pollutants, and includes noise, smoke management, and visibility
Associated guidanceSpecific guidance on when and how to conduct air quality
analyses within RMPs and EISsGuidance on emission calculations, air models,
monitoring, BMPs, and example applicationsFocuses on the question of whether proposed activities
are reasonably foreseeable
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Air Resource Management Air quality manual
Inventory, model, analyze, and monitor air resources in order to evaluate conditions and trends
Evaluate and recommend appropriate emission control and mitigation measures to ensure compliance with appropriate Federal, State, Tribal, and local air quality standards
BLM has an “affirmative responsibility to protect the air quality and related values (including visibility)” (Section 165 (d)(2) of Clean Air Act)
BLM will consider the potential effects of BLM projects, programs, activities, and BLM-authorized activities on air quality at both the planning and the project level
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Air Resource Management Air quality manual
Ensure an appropriate level of information and analysis is incorporated into applicable RMPs, NEPA documents, use authorizations, and BLM permits.
Assure appropriate stipulations and conditions of approval are included to ensure air pollution emission control, protection methods, and ambient air quality levels are addressed
Cooperate with regulatory entities in evaluating impacts to air quality, and determining potential influence on existing and future BLM activities
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Air Resource ManagementAdverse Impacts (or thresholds)
Air Quality National and State Ambient Air Quality Standards Prevention of Significant Deterioration Increments Particular case of ozone
Air Quality Related Values (AQRVs for Class I areas) Visibility (light extinction) - 1.0 or 0.5 deciviews Nitrogen and Sulfur Deposition – 5 and 3 kg/ha/yr for N and
S, respectively NPS has proposed 0.005 kg/ha/yr for each
Lake Acidification – 10% change in acid neutralizing capacity (ANC)
Hazardous Air Pollutants Acceptable ambient concentration levels (AACLs)
Air Quality ChallengesSize of Projects, Density of Development,
Long Term Pad Drilling, Number of ProjectsProjects are Now 1,000’s of Wells Rather than
100’sDensity of development coupled with long term
pad drilling has “near field” NAAQS implications
Analysis expectationsOzoneVisibilityOther AQRV’s
Air Quality Challenges - New Ozone Standard
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EPA promulgated new NAAQS to 0.075 ppm (75 ppb)
Rural Western “High Background” is close to standard
“Winter Ozone” issues observed in other parts of the region
Several areas will probably become either non-attainment areas or “transport” areas.
It is unclear how to do a major project EIS in a non-attainment or transport areas
It is unclear if BLM can or will issue a ROD with predicted design value exceedences
It is clear that more appeals will be filed
Implications for BLM planning activitiesImpacts for plans using photochemical grid
modeling will be assessed against a tighter threshold
Greater scrutiny of emissions from oil and gas development
If new nonattainment areas overlap with oil and gas development, our activities would have to conform with the state air quality plans through General Conformity under Clean Air Act
Need to be proactive to ensure that all RFD is included in the state plan due 2013
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Air Quality Challenges - New Ozone Standard
Analysis ProcedurePhoto Chemical Grid Models Likely to be New
StandardComplex, Expensive, Lengthy, Limited Contractor
AvailabilityBetter “State of Science” ResultsYields Much More and Better Information for Decisions
Inventories Historically a ProblemMost Analyses Relied on WRAP Inventory (Does not
have VOC’s)More Complete, Accurate, and Speciated Inventories
Will be Required IPAMS Wrap Phase III Will HelpKeeping Inventories Updated Will be Challenge for
Both Industry and Agencies
Status of Air Quality for RMPsBLM began using air quality models to disclose
impacts from RMPs a few years agoMethods and models used for air quality models
have evolved due to:A need to better quantify cumulative impactsA need to address ozone impactsGreater scrutiny of analysis techniques
Unlike air quality modeling conducted for large stationary point source permitting, methods for spatially distributed small sources within NEPA are not well established
New direction is to use models capable of large-scale regional assessments in areas with dense oil and gas development
Status of Air Quality for RMPsDifferent AQ models used to support RMPs in
Colorado Adverse impacts have varied tooSee table on subsequent slide that provides
Model(s) used in the analysisAdverse air quality impactsEPA NEPA rating
Status of Air Quality for RMPsVarious air quality models used to support RMPs
AERMOD (a “plume” model”) Used for near-field impacts up to <50 km Limited chemistry for particulates, not capable of simulating ozone Assumed to give most conservative results $15 -$75k and weeks to a few months to run
CALPUFF (a “puff” model) Used for far-field analysis up to 300 km Limited chemistry for particulates, not capable of simulating ozone $100 - $300k and 2-6 months to run
CAMx or CMAQ (photochemical grid models) Used for regional impacts from a multitude of sources up to
continental scale with gridded, nested “domains” Full chemistry, including ozone Use massive meteorological and emissions data sets as inputs $200k - $750k and 6 -18 months to run Ultimate cumulative impacts tool
Status of AQ for Various Plans
Plan Plan Status Models Used Potential Adverse Impacts
LSFO RMP Between Draft and Final EIS
Emissions only / CALPUFF-lite (hypothetical)
Visibility
CANM RMP Between Draft and Final EIS
AERMOD Cumulative N dep
WRFO RMPA Impact Analysis AERMOD, CALPUFF, CAMx
------
KRFO RMP Impact Analysis CALPUFF-lite ------
GSFO RMP Impact Analysis AERMOD, CALPUFF, CAMx
-----
SJPLC LMP Draft AERMOD (to be revised)
Visibility, cumulative N dep, lake chemistry
Oil Shale PEIS Draft CALPUFF (not in EIS)
GJFO RMP Scoping --- -----
UFO RMP Scoping --- -----
Roan Plateau RMPA / Vernal RMP
Final AERMOD, CALPUFF
Visibility (cumulative only), HAPs
NSJB CBM PEIS Final AERMOD Visibility,lake chemistry, Colorado
sulfur AAQS*
Role of StakeholdersFederal Agency Partners expect involvement in:
Conduct of air quality analysisSynthesis and interpretation of analytical resultsDetermination of significant impactsDevelopment of mitigation and control measures
Ongoing dialogue to determine appropriate analysisState Office meets frequently with State, USFS,
EPAFederal Leadership Forum meets regularly
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Air Emission ControlsAs air quality impacts from both federal and non-
federal development increase, BLM sees a need to adopt controls
Both CDPHE, COGCC and EPA have passed regulations that address a host of oil and gas sources:Colorado Regulation 7COGCC RegulationsNew Source Emission Standards (NSPS) for stationary
engines and turbinesNONROAD diesel engine emission standards
Will the existing emission control regulations be sufficient to mitigate regional impacts?
Is the adoption of strict emission controls more feasible than phasing or limiting development?
Air Emission Controls Cont.Colorado Reg 7 Emission Standards (SIP and statewide)
Tanks standards: New and existing condensate tanks emitting 20 tons per year or more of VOCs required to control emissions by 95 percent commencing May 1, 2008
Engine Standards for new or relocated engines from out of state commencing July 1, 2007:
Source: CDPHE
Glycol Dehydrator controls: New and existing glycol dehydrators emitting more than 15 tons per year of VOCs are required to control emissions by 90 percent commencing May 1, 2008.
Air Emission Controls Cont.
EPA has promulgated “Tier” NONROAD emission standards for diesel engines , including drill rigs
Emissions are progressively reduced until 2015 through Tier 1 – 4 emission standards
An associated diesel fuel standard will reduce the sulfur content for nonroad engines form 500 ppm to 15 ppm
The nonroad engines emission standards address several pollutants, but primarily NOx (see next slide)
Air Emission Controls Cont.So why would BLM implement further control
measures?State and federal regulations may not be
sufficient to avoid unacceptable impactsNot all air emission source categories are
addressed by state and federal regulations (fugitive dust, venting emissions, methane, etc..)
Some emission standards will not be implemented until future year (e.g., Tier 4 nonroad standards in 2014)
What is BLM’s obligation?
Air Emission Controls Cont.Does BLM have authority to require stricter
emission standards?A question of law, not BLM air quality policyIn practice, this has been addressed on an ad-hoc
basis in coordination with state DEQsLikely not an easy answer as due to
Regulatory framework for source type (mobile vs. stationary vs. area)
EPA delegation of authority to state and the state’s preference
Legal precedents (case law) Example: Green completions
Generally, yes, as various sections of FLMPA and the Clean Air Act direct BLM to protect air quality
Mitigation Measures under NEPAActions that can reduce, avoid, minimize,
rectify, or compensate adverse impactsRequired mitigation measures must be
described in the decision documentMonitoring is required to ensure the
implementation of mitigation measuresFor an EIS – all relevant and reasonable
measures are to be identified (even if outside the agency’s jurisdiction)
For an EA – mitigation should be used and required to reduce the impacts below significance
Management StrategiesPlan Projects for “Low Emissions”
Condensate and water collection rather than tanks and trucks
Controls on start-upContract low emission rigs when turn-over occursUse low or ultra-low sulfur diesel Use low bleed pneumatics, solar for chemical and
methanol pumpsAvoid pneumatic pumps (gas) if possibleAvoid well venting for completion, unloading or
blowdownAutomation In a regional sense electrification is not a silver bullet
Management StrategiesBe Prepared to Make Emission Mitigation
CommitmentsIt is Better to Plan These for the Most Cost Effective
and Largest EffectsIn Jonah, EPA Threatened Unsatisfactory Rating if
Engines Not Restricted to 1gr/hp-hr. BLM AgreedOzone Issues May Require Controls of
Existing EquipmentFormal Off-sets in Non-attainment AreasModel Predicted Impact Reduction Where Analysis
Shows Design Value ExceedenceGoal is to Demonstrate No or Very Deminimis
Impact
Regional Assessment Air quality analyses are currently being conducted on a plan-by-plan or
project-by-project basis Air quality impacts from wide-spread oil and gas development are
inherently well suited to be assessed with photochemical grid models
Advantages include: Cost efficiencies Consistencies in data, methods, and projected results
Disadvantages include: Not well suited for assessing near-field impacts Predicted impacts from an individual plan
Several existing air quality studies could be leveraged, including: Uinta Basin / IPAMS modeling White River CAMx modeling Four Corners Air Quality Taskforce
CDPHE, EPA, and USFS have indicated support for this approach
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