Emission questions loom large over oil and gas industry
Emission questions loom large over oil and gas industry | Natural gas projects in Wyoming
By Dustin Bleizeffer
March 5, 2013
Robert Field is on a marathon mission, driving a Jeep Grand Cherokee packed with high-tech air-sniffing equipment on a 120-mile loop of dirt roads, weaving through the Pinedale Anticline natural gas field. Field and his research partner will drive this circuit 32 times over a four-week period this winter.
On a recent run of the circuit, Field, a research scientist at the University of Wyoming’s Department of Atmospheric Sciences, stopped near a pipeline compression station to take another type of air sample with a shiny canister the size of a milk jug.
“We travel upwind, downwind of the development, through the development, so we can get a good picture — like literally a map, a contour map of the pollution levels at different times of the day and on different days,” Field said in his thick English accent.
It may sound counterintuitive, but Field and his research partners, Shane Murphy, an assistant professor, and Jeff Soltis, an associate research scientist, both also at UW’s Department of Atmospheric Sciences, are hoping to witness a few daytime spikes in dangerous ground-level ozone during this mobile data collection effort. But Mother Nature isn’t cooperating.
In a way, neither are the natural gas producers.
Highly concentrated ozone forms at ground level here when a number of forces all come together at the same time. The “precursor” pollutants for wintertime ozone are volatile organic compounds (VOCs) and nitrogen oxides (NOx), most of which come from emissions related to natural gas development in this region, particularly the Pinedale Anticline field. If the valley is blanketed in snow, and there’s a temperature inversion forcing the pollutants to stagnate low, the exposure to sunlight above and light reflected from snow below causes a photochemical reaction creating ozone.
“That’s really the key factor; snow on the ground, sunlight and inversion all create this perfect cooking pot for ground level ozone,” said Charis Tuers, air resource specialist for the U.S. Bureau of Land Management’s Cheyenne, Wyo., office.
Despite Field’s hopes — for research purposes — there hasn’t been a strong ozone event so far this winter. From a human health standpoint, that’s good news. But from the research side, the lack of snow cover, and a reduced amount of NOx and VOC emissions, means Field and his colleagues might not witness that critical, elusive threshold point that sets off a spike in ozone.
“So we may not see ozone events and we may not be able to define that critical point where ozone is formed due to (a certain) level of precursors. … But, we will be able to say what levels don’t form ozone,” said Field. “We can’t do anything about the meteorology, but we can potentially do something about the emissions. The question is; do we need to do anything about the emissions, yes or no?”
Feds force ozone compliance
Regulators and natural gas producers desperately want to understand the recipe that triggers a wintertime ozone event. Future gas development here, or at least the pace of future gas development, may depend on it.
On July 20, 2012, Sublette County and portions of Lincoln County were declared to be in marginal non-attainment for ozone under the Clean Air Act. What that means is that the federal 8-hour average threshold for ozone — 75 parts per billion (ppb), a standard set many years ago under the Clean Air Act to protect human health — had been exceeded enough times to declare the region out of compliance with the federal law. The non-attainment designation set a 3-year clock for Wyoming to bring the area back into compliance.
If EPA is not convinced that the area is no longer under the threat of high ozone events federal officials could impose stiff restrictions on new drilling, or any other activity that could potentially contribute to ozone. Such an action could spell serious trouble for, among other natural gas projects, EnCana Oil & Gas’s ambition to drill 350 wells per year for its 3,500-well NPL (Normally Pressured Lance) natural gas project, which mostly encircles the Jonah gas field south of the Pinedale Anticline.
In fact, the 3,500-well NPL project proposed by EnCana, and the 838-well LaBarge Infill project are both located in the Sublette County non-attainment area, requiring special consideration. The projects may only be approved if they comply with a set of emission limits that federal regulators agree will not contribute to the formation of ozone. One major emissions-cutting strategy for EnCana’s NPL project is the operator’s proposal to power field operations with electricity, eliminating a lot of natural gas-fired facilities that are common in the industry.
Operators of the Pinedale Anticline and the Jonah (also in the Upper Green River Basin) gas fields were able to reduce their NOx and VOC emissions in large part by consolidating facilities — by installing pipeline networks, for example, for water and associated oil, eliminating the need for thousands of semi-trucks each year.
But there are many more natural gas projects still on the drawing board throughout Wyoming, and many of them include more wells than have been drilled in the Pinedale Anticline and Jonah gas fields. BP’s sprawling 1.1 million acre and 8,950-well Continental Divide-Creston project near Wamsutter, for example, is outside the Sublette County non-attainment area for ozone. Yet ozone is still a consideration, and the operators will have to come up with alternative emissions-cutting technology to avoid contributing NOx and VOCs to the Upper Green River Basin.
Relying on a local utility to “electrify” BP’s Continental Divide-Creston field isn’t a readily available option, said Tuers, although BLM’s air quality experts say that much of the concern for pollution emissions from the activity are downwind, in northern Colorado, rather than in the upwind Upper Green River Basin.
Future air quality is a little foggy
After more than five years of scrambling to figure out the recipe of pollutants from oil and gas activity combined with topography and meteorological conditions that cause dangerous spikes in ground-level ozone in the Upper Green River Basin, regulators are still short of answers.
There hasn’t been a single 8-hour ozone spike measured in the region since the winter of 2011 when there were 13 such events. One ozone spike that winter was measured at 124 ppb — higher than Los Angeles’ worst ozone day during that year. In 2011, ozone events forced the state to issue nearly a dozen warnings to local residents to stay indoors for health reasons — a startling outcome of full-scale natural gas development that the community hadn’t bargained for, nor did regulatory agencies anticipate.
The absence in ozone spikes during the past two years may be attributed to lesser snow-cover in the basin area. It may also have much to do with lower NOx and VOC emissions from the gas fields (attributed to emission-cutting efforts by industry and slowed production activity), or a combination of both emissions and the right atmospheric conditions.
Regardless, researchers and air quality regulators in Wyoming may still not know enough about the ozone phenomenon to guarantee a pathway out of the non-attainment status.
That may sound like a small bureaucratic matter to the layperson who lives outside of Sublette County. But it’s not.
Natural gas production is Wyoming’s single largest source for state revenue. And for the past several years, natural gas developers have been pushing plans to greatly expand production in the Cowboy State — in the Upper Green River Basin and elsewhere across Wyoming. In all, regulatory agencies are being asked to approve some 24,000 new natural gas wells as part of seven separate projects in Wyoming.
The Pinedale Anticline region in the Upper Green River Basin may be particularly prone to ozone, in part, due to topography and atmospheric conditions. But even less is known about whether ozone or other air quality problems could occur when it comes to drilling some 9,000 new wells in the Wamsutter area, or 4,200 new wells south of Rock Springs, or 3,500 new wells south of the Pinedale Anticline.
Conventional wisdom suggests that many of these other intense natural gas drill projects occur in areas where temperature inversions are less likely because they’re not contained within topographical bowls. But that doesn’t guarantee that Mother Nature will always cooperate, blowing NOx and VOC pollutants away without being baked into ozone, on occasion, or contribute to the ozone-prone conditions in the Upper Green River Basin.
“It raises questions of whether we’ll see new non-attainment areas or an expansion (of the current non-attainment area in Sublette County). I think that’s a real possibility,” said Bruce Pendery, staff attorney for the Wyoming Outdoor Council.
In fact, Wyoming Outdoor Council, Environmental Defense Fund, Natural Resources Defense Council, and other environmental groups this week will submit comments and a 53-page independent air quality mitigation analysis of BP’s 8,950-well Continental Divide-Creston natural gas infill project in south-central Wyoming.
That independent air quality analysis, headed by Megan Williams, “found that the (U.S. Bureau of Land Management’s) draft analysis of the project underestimates emissions from project sources, does not consider the likely negative contributions to ozone pollution levels in the nearby Upper Green River Basin non-attainment area, and fails to ensure compliance via adequate emissions monitoring and self-certification requirements, among other things,” the environmental groups stated in a press release.
The BLM’s emissions analysis for the Continental Divide-Creston project, now in the environmental impact statement (EIS) permitting process is important, said Tuers, because it’s the first major natural gas project under analysis in this new, post-Upper Green River Basin ozone era. In other words, the scrutiny over emissions from natural gas production operations is much higher than it was in the early 2000s when regulators mostly guessed there would be no major air quality issues when they approved plans for the Pinedale Anticline and Jonah gas fields.
Now, some 10 years later, regulators know better. They have much more air quality data in-hand, and Wyoming residents are ultra-aware of the potential hazards this time around. Tuers said the analysis that has gone into the Continental Divide-Creston natural gas proposal is much larger in scope, and the modeling — or predictions about what will happen to the air quality if the project moves forward as planned — is much more detailed, and it will serve as a template for all the other major natural gas projects moving forward.
Yet, some environmental groups are not convinced BLM’s air quality analysis and modeling for Continental Divide-Creston is thorough enough. Pendery said that not only is ozone still a concern under the BLM’s current analysis of the project, but also particulates and the deposition of nitrogen sulfur (the buzz phrase is acid rain) in Class 2 areas in south-central Wyoming that include high-quality trout fisheries.
“We are not categorically opposing the project (Continental Divide-Creston),” said Pendery, “and there’s 4,400 existing wells there already, so it’s hardly an untouched landscape. But we analyzed (the project) and want the strongest mitigation possible.”
Studying wintertime ozone
The University of Wyoming’s “spatial air quality assessment” led by Robert Field this winter almost didn’t happen.
In December, the multi-agency Pinedale Anticline Project Office (PAPO), which was created to oversee resource management and mitigation efforts related to the Pinedale Anticline natural gas field, rejected Field’s $128,000 grant proposal to conduct a 2-part study; a mobile assessment of where VOCs and NOx accumulate in the Pinedale Anticline region, and a pollution plume assessment to better pinpoint the biggest pollution sources.
Wyoming Department of Environmental Quality (DEQ) administrator Todd Parfitt sits on the PAPO board, and made a recommendation to not fund Field’s proposal. The board followed Parfitt’s recommendation. The PAPO board normally grants these types of grants once a year, in May. In addition, the PAPO board was already somewhat committed to using most all of its available funding for other projects; most notably the Trust for Public Land’s effort to buy back the Plains Exploration & Production Co. oil and gas leases in the Wyoming Range. PAPO granted $200,000 toward that successful effort.
DEQ drew criticism from a citizen stakeholders group for its role in the PAPO board turning down Field’s grant request.
Elaine Crumpley, who served on the Ozone Advisory Task Force, told WyoFile in December, “That was part of our (the ozone task force) main concern; that we continue on with very good site monitoring and other kinds of off-site monitoring as well.”
Afterward, DEQ officials met with Field to negotiate. The parties agreed to drop the plume assessment portion of the study, and DEQ helped find $73,892 to carry out the mobile pollution assessment this winter. Field may go back to the PAPO board with a revised grant application in May.
DEQ has an extensive network of fixed air quality monitoring stations in the Upper Green River Basin. But the mobile sampling aspect of Field’s research does add a layer of refined air sampling data.
“It provides much more information,” said Field. “We can take our measurement systems, apply them to places where we can’t put a normal, fixed monitoring site, which are incredibly expensive to set up and establish.”
But, as with many regulatory matters, there are complications.
DEQ Air Quality Division administrator Steven Dietrich said Field’s particular type of mobile pollution assessment is not currently included in EPA’s approved methodologies for such work. “It’s still considered research,” Dietrich told WyoFile, but added “I’m not sure if we can use the data to make permitting decisions.”
Field’s research this winter is just a part of a larger, multi-agency Upper Green Ozone Study with several years of work already completed. DEQ, with the help of the University of Wyoming and other cooperating entities, have focused on monitoring and analyzing meteorological conditions in the area. Other years they have focused on NOx and VOC emissions.
Dietrich explained that, unlike urban ozone, there’s not much known about wintertime ozone events. Whereas the EPA has proven “off-the-shelf” models to curb urban ozone, Wyoming DEQ is left to create its own wintertime ozone model to address the problem in the Upper Green River Basin. And that’s been proven a difficult task.
Despite having avoided 8-hour ozone events for the past two years, Wyoming and Pinedale Anticline operators Shell, Ultra Petroleum and QEP Resources cannot point to specific emission parameters and guarantee there will be no more high ozone events.
The particular non-attainment designation attached to the region is classified as “marginal,” meaning the region was labeled with an ozone infraction of 76 ppb — just one mark above the current 75 ppb limit for the 8-hour standard under the Clean Air Act. That might make Wyoming DEQ’s job of meeting compliance a little less daunting if it wasn’t for the fact that EPA is scheduled to consider a new, lower 8-hour ozone threshold.
Based on scientific consensus that suggests human health is threatened at levels below 75 ppb for ozone, EPA was prepared to lower the threshold to 60-70 ppb back in the summer of 2011. But president Obama delayed the rule-making for two years, hoping to avoid adding to the nation’s unemployment problem with an estimated $90 billion in associated costs to implement the tougher standard (some argued that the savings in human health and health care will more than make up for that estimate in implementation). EPA may move forward with a tougher standard later this year. Two year’s after Obama’s decision to delay, there’s added pressure to curb wintertime ozone and lower the 8-hour threshold, thanks in large part to ongoing ozone spikes in Utah’s Uintah Basin.
“First, we’re trying to get into compliance with the current standard. … But it’s a moving target,” said Dietrich.
In the past, industry officials have discussed possibly lowering either NOx or VOCs, thinking that removing one leg from the stool negates wintertime ozone altogether. Two years ago, EnCana officials even suggested that by reducing NOx and VOC emissions (current NOx and VOC emissions are actually in compliance, although resulting ozone spikes are not) the producers should get credit allowing them to emit pollutants at higher rates elsewhere in the state.
But Dietrich said DEQ’s plan to bring the Upper Green River Basin back into compliance for ozone is being built on reducing both NOx and VOCs. It’s not clear whether DEQ will consider a sort of cap-and-trade approach, allowing for higher emissions outside of the Sublette County non-attainment area for good deeds done (mandated) in that region. And although Wyoming is not technically required to develop a full state implementation plant (SIP) to meet the EPA’s non-attainment requirements, Dietrich said Wyoming DEQ is developing a such plan. Also, the agency will aim to meet a lower than 75 ppb 8-hour ozone threshold assuming EPA will follow through with such a rule-making this time around.
“So we’re looking at measures we’d have to (take) if we were classified higher, so we can draw on every type of measure to … draw down ozone more and faster,” said Dietrich.
No clean air guarantees
Because of evolving science and changing regulations, getting a region back into compliance with the federal Clean Air Act is tricky. Avoiding an air pollution problem in the first place should be the priority, but priorities regarding oil and gas development are sometimes foggy due in part to divided authorities among multiple federal and state agencies.
While Wyoming DEQ has authority to permit major emission sources in oil and gas development, it has no authority to determine the pace of drilling and other emissions-related activities. Those pre-development decisions are typically left to BLM, which manages minerals on federal lands.
Wyoming BLM was the lead environmental analysis and permitting agency for the Jonah natural gas field and the Pinedale Anticline, both in the Upper Green River Basin. Yet BLM and others said they were broadsided by ozone, claiming nobody had anticipated that wintertime ozone spikes were even a possibility due to emissions from producing natural gas.
While citizens and regulators have much more information about pollution emissions today, and better scientific modeling about what’s needed to protect human health, BLM and others make it a point to not guarantee there will be absolutely no air quality problems. Making an EIS record of decision litigation proof is different than assuring the public there will be no human health impacts related to the natural gas projects BLM approves. The so-called best available control technology (BACT) on the books today may not be enough to avoid pollution problems from drilling projects of the future.
Case-in-point was the Pinedale Anticline and Jonah gas fields, which were approved with BLM’s promise of applying “adaptive management,” which implies that if a problem arises, regulatory parameters will change to address them. Many in the environmental community see the current — and perhaps successful — efforts to address ozone in the Upper Green River Basin as a forced response to the non-attainment status, and less about the promise of adaptive management.
“I am no big fan of adaptive management,” said Pendery. “On one hand, of course it makes sense. You have to adapt and modify based on reality, and a lot of times you don’t know that reality in advance. But all too often adaptive management is an opportunity to wriggle out of things and avoid decision making.”
— Click here to read the Upper Green River Basin Citizens Advisory Task Force recommendations to address air quality.
— Dustin Bleizeffer is WyoFile editor-in-chief. He has reported on the energy industry in Wyoming for 14 years. Contact him at 307-577-6069 or firstname.lastname@example.org. Follow Dustin on Twitter @DBleizeffer.
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