Oil and Gas Issues WESTAR Spring 2008 Park City, UT
Issue: Emission Factors Completions, venting/flaring, fraccing Tanks Dehydration units Pumps Pneumatic controllers Well blow downs Pipeline venting Truck traffic Fugitives Malfunctioning systems
Uncertainties • Uncontrolled versus controlled emissions • Do we account for all the sources? • Are controls reliable?
VOCs or NOx? • If ozone is the issue, what should be controlled? • Modeling tools? • Rural versus urban? • Model performance? • Episodic conditions? • Wyoming so far: $1.1 million and growing
Feds v. States • Coordination issues with BLM, DEQ, EPA • State capacity to evaluate regional impacts • Inconsistent emission inventories, modeling assumptions, consideration of future projects • Conflicts with EPA R8 • Visibility issues
Future Actions • One or more revisions to Wyoming’s oil and gas BACT guidance: • Add controls for all pumps; replace pneumatic controllers; control pipeline venting; control water tanks; control well blowdowns; control fugitives; expand more stringent JPDA requirements to ‘other concentrated development areas’. • Control drill rig emissions • Drive compression BACT lower • Modeling • Additional controls to prevent nonattainment • To avoid episodic conditions; • To lower ozone generally