Resource Advisory Councils ConferenceGrand Junction, Colorado

February 25, 2009

Topics

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 Resource Management - Standards

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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