A DISCUSSION ON VOLUNTARY EMISSION

REDUCTION PROGRAMS ON THE SOUTHERN UTE INDIAN RESERVATION

Environmental Programs DivisionAir Quality Program

May 18th, 2016

SHOULD WE BE CONCERNED ABOUT OZONE?

EPA lowered the National Ambient Air Quality Standard for ozone from 75 ppb to 70 ppb (8-hour standard).

Attainment of the standard is determined by an area’s “design value”, the pollutant concentration (in parts per billion) recorded by air quality monitoring stations.

The design value for the eight-hour ozone standard is the fourth highest hourly reading measured during the most recent three-year period.

The 2015 ozone design value for the Reservation is 68 ppb based on data from the Tribe’s air quality monitoring stations, Ute 1 and Ute 3.

The design value trend for the Reservation appears to be increasing

WHAT ARE LOCAL 2015 DESIGN VALUES FOR OZONE?

Station Name CY 2014

AQS Data Certified

CY 2015

AQS Data Certified

Ute 1 67 Y 68 Y

Ute 3 67 Y 66 Y

Mesa Verde National Park 65 Y 66

Bloomfield 62 Y 61

Navajo Dam 63 Y 68

Substation 63 Y 61

Weminuche Wilderness Area Shamrock Station 64 N 68

106 W. North Street in  Cortez 62 S 61

WHAT ARE THE OZONE TRENDS ON THE RESERVATION

2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 20180.055

0.057

0.059

0.061

0.063

0.065

0.067

0.069

0.071

0.070 0.070 0.070 0.070 0.070 0.070

f(x) = NaN x + NaNR² = 0

Ute 1 and Ute 3 Design Value concentration from 2007 to 2015

Ute 1 Ute 3 ozone NAAQSDesign Value Year

Ozo

ne D

esig

n Va

lue

conc

entr

ation

(ppm

)

AQP has an opportunity to submit an attainment designation recommendation using 2013-2015 Ute 1 and Ute 3 station’s air quality data to EPA before October 1, 2016

OR in the absence of a recommendation by the Tribe EPA will issue a final area designation for the Reservation

by October 1, 2017.

■ Currently the Air Quality Program (AQP) anticipates the designation will remain attainment for the Reservation but, this could change in the future based on the design value trend.

WHAT IS HAPPENING NOW WITH THE 2015 OZONE NAAQS

ATTAINMENT DESIGNATION?

WHAT COULD BE EXPECTED IF THE RESERVATION WAS IN NON-

ATTAINMENT OF THE OZONE STANDARD?

More stringent emission reduction measures would be required.

A Tribal Implementation Plan (TIP) would be required to propose enforceable emission reduction measures (Reservation Air Code requirements) to bring the Reservation into attainment.

Failure to submit an adequate TIP could result in an EPA imposed Federal Implementation Plan (FIP).

FIPs typically contain stricter regulations than TIPs.

CAN PROACTIVE MEASURES BE TAKEN TO ENSURE COMPLIANCE

WITH THE OZONE NAAQS IS MAINTAINED?Regulatory

The SUIT/CO Environmental Commission adopts measures for existing sources, such as Colorado Regulation 7, to reduce ozone precursor emissions.

Voluntary

Participation in voluntary EPA programs. Natural Gas Star Program Enhanced Natural Gas Star Program (Methane

Challenge) Ozone Advance

WHY SHOULD WE BE INTERESTED IN PROACTIVE MEASURES?

Early efforts to reduce ozone precursors could help the Reservation avoid a future non-attainment designation or result in a lower non-attainment designation, should the Reservation be designated non-attainment

Early efforts to keep an area in attainment are less resource intensive than efforts necessary after a non-attainment designation

Voluntary programs preferable over mandated requirements

Better to be proactive than reactive when it comes to NAAQS attainment.

Benefits to regional air quality.

Ozone Advance is a voluntary EPA program to preserve or improve air quality in ozone attainment areas with ozone levels close to the standard.

Participants choose best fit strategies to reduce ozone precursors (nitrogen oxides and volatile organic compounds).

Participants determine their own goals and the measures they want to implement in order to reach them

Can result in multi-pollutant reductions, such as methane.

Participation in Ozone Advance has key benefits should an area go non-attainment.

WHY IS AQP INTERESTED IN OZONE ADVANCE?

Should the Reservation be designated non-attainment with a Marginal classification:

EPA may consider any voluntary control measures implemented under the program and allow extra time to see if the control measures are working, prior to requiring a TIP or FIP.

Areas may continue to participate in Ozone Advance until reclassified as Moderate or higher (will not exempt area from non-attainment NSR permitting)

WHY IS AQP INTERESTED IN OZONE ADVANCE? CONTINUED….

Should the Reservation be declared non-attainment with a Moderate or higher classification:

Voluntary emission reduction measures that occur before the baseline year may be credited toward total emission reduction goals required by a TIP/FIP; and

If the requirements are incorporated in a TIP or FIP after the baseline year, as a measure to show progress toward attainment.

Voluntary measures selected by participants may be adopted as TIP or FIP requirements.

WHY IS AQP INTERESTED IN OZONE ADVANCE? CONTINUED….

Wyoming Upper Green River Basin Resulted in year to date emission reductions (tons per

year) from 2008 through March of 2015: Volatile Organic Compounds: 5,874.7 tpy reduced Nitrogen Oxides: 1,862 tpy reduced

Emission reductions were achieved by: Installing controls on storage tanks Installing low bleed/no bleed pneumatic controllers Installing controls on drill rig engines Installing centralized gathering facilities Expanded green completion requirements

WHAT ARE RELEVANT EXAMPLES OF OZONE ADVANCE

PARTICIPATION?

Utah, Uinta Basin Utah’s Board adopted four proactive measures on

October 1, 2014 for existing sources. The measures were aimed at retrofitting oil and gas industry equipment to assist in VOC emission reductions.

The four measures include: Properly maintaining and operating equipment. Accelerated implementation of NSPS standards

including replacing high-bleed controllers with low-bleed or no-bleed controllers.

Equipping new flares with an automatic igniter and retrofitting existing flares.

Tank truck loading required to be bottom filling or submerged pipe filling on tanker trucks.

WHAT ARE RELEVANT EXAMPLES OF OZONE ADVANCE PARTICIPATION?

CONTINUED…

For a list of Ozone Advance participants and descriptions of their programs, follow the link below: https://

www.epa.gov/advance/advance-program-participants

For general information on Ozone Advance follow this link: https://www.epa.gov/advance

For detailed guidance on Ozone Advance follow this link: https://www.epa.gov/sites/production/files/2016-04/

documents/guidance_update.final_.april_2016.pdf

OZONE ADVANCE RESOURCES

THE SOUTHERN UTE AIR QUALITY PROGRAM WOULD

LIKE TO THANK YOU FOR TAKING THE TIME TO JOIN US

TODAY!THIS IS WHERE WE ASK FOR YOUR INPUT ON VOLUNTARY

EMISSION REDUCTION MEASURES.

ARE THERE COST-EFFECTIVE, VOLUNTARY VOC OR NOX EMISSION REDUCTION MEASURES YOUR COMPANY IS ALREADY IMPLEMENTING?

IS THERE POTENTIAL FOR OTHER COST-EFFECTIVE EMISSION REDUCTIONS STRATEGIES THAT COULD BE IMPLEMENTED?

WHAT PROCESS AREAS/EQUIPMENT COULD YIELD THE GREATEST VOC AND NOX EMISSION REDUCTIONS?

DOES YOUR COMPANY PARTICIPATE IN ANY VOLUNTARY EPA PROGRAMS, SUCH AS NATURAL GAS STAR?

WOULD YOUR COMPANY HAVE INTEREST IN AN OZONE ADVANCE PROGRAM?

A summary of today’s meeting will be presented at the June 8th, 2016 Environmental Commission

Meeting, being held at the Environmental Program’s Building at 71 Mike Frost Way, Ignacio,

Colorado.

To submit comments or ideas on the Ozone Advance Program please send comments to Matt Wampler or Danny Powers at the following email

addresses by June 1st, 2016:Danny Powers: dpowers@southernute-nsn.gov

Matt Wampler: mwampler@southernute-nsn.gov