nepa air quality 2008 pla nepa workshop denver colorado june 12 2008
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NEPA & Air Quality 2008 PLA NEPA Workshop Denver, Colorado June 12, 2008. Air Quality – Game Changes. Pre-History <1996 – Qualitative 1996 – Moxa Arch – Set Many Precedents 1997 – 1 st Jonah EIS – 1997 – 1999 – SWWYTAF 1999 CD & SUIT – 1 st to Use CalPuff for Cumulative Analysis

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air quality game changes
Air Quality – Game Changes
  • Pre-History <1996 – Qualitative
  • 1996 – Moxa Arch – Set Many Precedents
  • 1997 – 1st Jonah EIS –
  • 1997 – 1999 – SWWYTAF
  • 1999 CD & SUIT – 1st to Use CalPuff for Cumulative Analysis
  • 2000 – FLAG Issued
  • 2004 – 2006 – Jonah Infill EIS
  • 2007 – Pinedale Supplemental EIS
  • 2007-2008 – 4-Corners Interagency AQ Task Force Analysis
  • 2008 Planned – CDC – Use PGM for Visibility
moxa 1996 precedents
Moxa (1996) Precedents
  • 1st Cumulative Analytical Approach
    • Demanded by USFS (Visibility Driver)
    • 1st Air Quality Related Values (AQRV)
  • Required Use of “dv” Method – Genesis of 1dv and 0.5 dv Thresholds
  • Required Acid Deposition Modeling
  • Scheffe Ozone Method 1st Used
  • Secondary Organic Aerosols Implicated in Visibility Impacts
  • BLM Established Cumulative Emissions Cap
    • Appealed by Project Proponents and Overturned
jonah 1 and swwtaf
Jonah 1 and SWWTAF
  • Jonah (1997)
    • EPA Threatened Unsatisfactory Rating if Engines Not Restricted to 1gr/hp-hr. BLM Agreed
  • SWWTAF (1997 – 1999)
    • Examined CALPUFF for Visibility and Deposition Modeling
    • Conclusions
      • Over prediction of NO3 by “order of magnitude”
      • Analysis showed ammonia limiting
      • Secondary organic aerosols shown to be biogenic
cd 1 and suit 1999
CD#1 and SUIT (1999)
  • First Cumulative Analyses to Use CALPUFF
  • Configured Using SWWTAF Conclusions
  • Visibility Analysis Using Hourly Transmissometer Data
  • Model Showed Significantly Lower Visibility Impacts – However Impacts at All Class 1 Areas Modeled
  • SUIT Analysis Had Similar Results
flag 2000
FLAG (2000)
  • FEDERAL LAND MANAGERS AIR QUALITY RELATED VALUES WORKGROUP (FLAG)
  • Developed by USFS and USPS and FWS
  • Prescribed Detailed Methodology and Became the “Bible” for AQRV Analysis
  • Mostly Relied on EPA IWAQM Guidelines
  • Comparison of Model vs Monitoring Indicates Significant Over-prediction
jonah infill pinedale supplemental
Jonah Infill & Pinedale Supplemental
  • Jonah Infill (2004-2006)
    • First Use of “Iterative” Modeling Approach to Set Mitigation Levels (pseudo cap)
    • Drilling Rigs Considered Significant Sources
    • Appealed for Scheffe Ozone Methodology
      • Dr. Scheffe said his method is: “antiquated and useless”
      • Appeal still underway
  • Pinedale Supplemental (2005-??)
    • First Use of Photochemical Grid Model (PGM)
      • Ozone Only (CALGRID then CAMx)
    • FLAG/CALPUFF Used for AQRV Analysis
    • EPA Issued Unsatisfactory Rating on Draft
four corners interagency air quality task force analysis
Four Corners Interagency Air Quality Task Force Analysis
  • Regional Model for AQRV’s and Ozone
  • Using CAMx (PGM Model)
  • Baseline Year Run Underway/Done
    • Very Complete Inventory
  • Preliminary Model Performance Evaluation Done
  • Will Develop “Relative Response Factors”
  • Will Conduct Source Apportionment Analysis
    • Both Particulate and Ozone
cdc 2007
CDC (2007-??)
  • Will Use PGM Model for Both AQRV and Ozone Analysis (CAMx or CMAQ)
  • Two Years of Baseline Runs Planned
  • Formal Model Performance Evaluation Planned
  • Development of “Relative Response Factors” Planned
  • Very Complete Inventory Developed
  • Source Apportionment Analysis Planned
  • Should Yield “Best Science” Information for Decision Making
  • CDC and 4-Corners Similar to SIP Demonstration Modeling in Detail, Complexity, and Completeness
forward challenges
Forward Challenges
  • “Mega Projects”, Density of Development, Long Term Pad Drilling, Number of Projects
  • Analysis Requirements
  • Ozone
  • Visibility
  • “Other AQRV’s
  • Climate Change (GHG Emissions)
    • Why are Polar Bears Important in the Rockies?
projects
Projects
  • Projects are Now 1,000’s of Wells Rather than 100’s
  • Density of Development Coupled with Long Term Pad Drilling Has “Near Field” NAAQS Implications
  • SW Wyoming Example
    • Jonah Infill – 3,100 wells
    • Pinedale Supplemental – 4,400 wells
    • CDC – 9,000 wells
    • Moxa – 1,800 wells
    • Hiawatha – 4,200 wells (may be less now)
    • Desolation Flats – 400 wells
    • Atlantic Rim – 2,000 wells
  • All of These Exist in Essentially the Same Airshed
analysis requirements
Analysis Requirements
  • Photo Chemical Grid Models Likely to be New Standard
    • Complex, Expensive, Lengthy, Limited Contractor Availability
    • Better “State of Science” Results
    • Yields Much More and Better Information for Decisions
  • Inventories Historically a Problem
    • Most Analyses Relied on WRAP Inventory (Does not have VOC’s)
    • More Complete, Accurate, and Speciated Inventories Will be Required
    • IPAMS Wrap Phase III Will Help
    • Keeping Inventories Updated Will be Challenge for Both Industry and Agencies
ozone
Ozone
  • NAAQS Lowered to 0.075 ppm (75 ppb)
  • Rural Western “High Background” is Close to Standard
  • “Winter Ozone” Issues
  • Several Areas Will Probably Become Non-Attainment
    • Sublette County Wyoming
    • San Juan County New Mexico
    • Other Areas Likely to Be Included As “Transport” Areas.
  • Analyses Show Modeled Design Value Exceedence of Standard (Pinedale Supplemental)
  • It is Unclear How to Do a Major Project EIS in a Non-Attainment or Transport Area
  • 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 With More Substance
visibility
Visibility
  • Class I area Visibility Impacts
    • Longstanding Issue – Has Not Diminished
  • Mostly Nitrate and Sulfate Secondary Particulates
    • Past Model Predictions Show Significant Impacts
    • Monitoring Data Shows No Trend
    • Issues with Modeling System and Application
  • Extensive Mitigation Driven by Model Output
    • Wamsutter/Continental Divide II – Impacts Predicted at Bridger and Zirkel
    • Jonah EIS & ROD – Extensive Mitigation Required
    • Pinedale Supplemental EIS – Extensive Mitigation – Still Shows Impacts @ Bridger
      • EPA Issued “Unsatisfactory” Rating
    • Moxa Draft EIS – Shows Significant Impact @ Bridger
acid and fertilizer deposition
Acid and Fertilizer Deposition
  • Overshadowed by Ozone and Visibility Issues
  • Still Need to be Mindful of These Parameters
  • Lake Acidification May Become Problem in Some Highly Sensitive Areas
  • Fertilizer Deposition Has Been Issue @ Rocky Mountain National Park
climate change
Climate Change
  • Emerging Issue
    • Likely to Be Basis for Appeals
    • Petition for CEQ Guidance Rule Change is in Washington Now
    • Rumor That BLM is Working on Guidance
    • Difficult to Deal With Mitigation
  • Plan to Develop and Disclose Project GHG Inventory
    • Highlight Low Emissions Technologies Applied
  • Stay Tuned for More Developments
forward aqrv and ozone analysis strategy
Forward AQRV and Ozone Analysis Strategy
  • Past Approaches Will Likely Not Be Successful
  • Develop Detailed and Agency “Approved” Protocols
  • Develop Detailed and Agency “Approved” Inventory
  • Use PGM Model for PM and Visibility in Addition to Ozone
    • Run Model in “Relative” Sense for PM, Visibility, and Ozone – Output Calibrated to Monitoring Records
    • Do “Formal” Model Performance Evaluation
    • Should “Eliminate” Visibility Impact Issues
    • Conduct Source Apportionment Analysis
    • Will Bring “Tools” to Understand and Address Ozone Issues
  • Stay Involved as Much as Allowed
analysis strategy goals
Analysis Strategy Goals
  • Craft an Analysis That is Approvable by BLM
    • Ensure Agency Support for Analysis and Approval
      • Avoid EPA “No-Cert” Issue
      • Avoid Inter Agency Conflict and “Escalation”
    • Ensure Agency “Buy-in” at Critical Steps in Process
  • Ensure Analysis will Withstand Appeals
    • “State of Science” Approach and Tools
    • Clear, Transparent and Well Documented
project emissions strategy
Project Emissions Strategy
  • Plan Projects for “Low Emissions”
    • Condensate and Water Collection Rather than Tanks and Trucks
    • Controls on Start-up
    • Contract Low Emission Rigs When Turn-over Occurs
    • Use Low or Ultra-low Sulfur Diesel
    • Use Low Bleed Pneumatics, Solar for Chemical and Methanol Pumps
    • Avoid Pneumatic Pumps (gas) if Possible
    • Avoid Well Venting for Completion, Unloading or Blowdown
    • Automation
    • In a Regional Sense Electrification is Not a Silver Bullet
project approval strategies
Project Approval Strategies
  • Be Prepared to Make Emission Mitigation Commitments
    • It is Better to Plan These for the Most Cost Effective and Largest Effects
  • Ozone Issues May Require Controls of Existing Equipment
    • Formal Off-sets in Non-attainment Areas
    • Model Predicted Impact Reduction Where Analysis Shows Design Value Exceedences
  • Goal is to Demonstrate No or Very Deminimis Impact
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