Post on 18-Jan-2016
Westar Energy ConferenceDenver, ColoradoOctober 22, 2008
Topics
Oil and Gas Development and NEPAAddressing air analysis in NEPAStatus of Field Office air analyses for RMPsAir pollutant emission controlsRegional assessments
Land Use Planning and NEPABLM plans for, and analyzes oil and gas decisions
at two distinct levels:RMPsMaster Development Plans
RMP – leasing decisionsAnalyze reasonably foreseeable development
scenarios related to the leasing decisionsConduct determination of NEPA adequacy before
each leaseMaster Development Plans – development decisions
BLM promotes MDPs over individual APDsAnalysis and decision should be consistent with RMP
Master Development PlansOperator may submit master development plan
(MDP) for 2 or more APDs that share a common drilling plan, a common surface use plan and future plans for development
More like geographic area plans and plans of development
May or may not include field (regional) development by other operators
Application for Permit to DrillEarly Notification – voluntary initial conference
with BLM Notice of Staking – casual use, staking only
followed by BLM onsite inspection Good Faith Efforts – to notify and include
private surface ownersDrilling Plan – engineering specificationsSurface Use Plan – an outcome of the onsite
visit including design criteriaAPD Processing – BLM has 30 days to Deny,
Defer, ApproveBegin NEPA analysis
Purpose of a NEPA DocumentSupport decisions through an understanding of
environmental consequences and alternative actions
Promote public involvement in decision making (including other governmental agencies)
Disclose and analyze the potential environmental consequences
Take action to protect, restore, and enhance the environment
Encourage productive and enjoyable harmony between people and the environment
NEPA Screening ProcessDoes proposal conform to the Land Use Plan?Is proposal an exception from NEPA
requirements?Is proposal listed as Categorically Excluded?Is existing analysis and documentation
sufficient?Is proposal listed as normally requiring an EIS?Are environmental impacts expected to be
significant?
Determining SignificanceContext – the potential significance of an impact
will vary based on the setting of the proposed actionLocal vs regionalShort-term vs long-term
Intensity – refers to the severity of impactMust assess direct, indirect and cumulative effectsAlso beneficial effects, controversy, public health,
uncertainty, precedent, sensitive resources, etc.
Mitigation MeasuresActions 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
Recent NEPA ChangesBLM NEPA Handbook
Detailed procedural guide for BLM specialists and the public
DOI NEPA Regulations (Departmental Manual)Clarifying CEQ regulations, Departmental guidance, and
evolving case law
ChangesConsensus management approachAdaptive management Purpose and needImpact analysis Connected actionsCumulative effects
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 include 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 AQ for RMPsDifferent AQ models used to support RMPs in
Colorado Adverse impacts have varied tooSee table on subsequent slide that provides
Number of wells (RFD federal only)Model(s) used in the analysisAdverse air quality impactsEPA NEPA rating
Status of AQ for RMPs Cont.Various 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 RMPs Cont.Adverse Impacts (or thresholds)
Air Quality National and State Ambient Air Quality Standards (e.g., 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 Emission ControlsAs air quality impacts from both federal and non-
federal development increase, BLM sees a need to adopt controls
Both CDPHE and EPA have passed regulations that address a host of oil and gas sources:Colorado Reg 7New Source Emission Standards (NSPS) for
stationary engines and turbinesNONROAD diesel engine emission standards
Will the existing emission control regulations be sufficient?
Adoption of emission controls may be more workable than phasing or limiting development?
Air Emission Controls Cont.Colorado Reg 7 Emission Standards
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)
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 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
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
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