OIL PRODUCTION AND AIR POLLUTION IN ROUTT COUNTY

April 10, 2012

Rodger SteenCommunity Alliance of the Yampa Valley

Where the air pollution battle is• Everyone appreciates the clean air• No one talks of reducing air quality because it is

unnecessarily clean• The technology for decreasing emissions is available• The emissions from all of the sources are quantifiable• Once the controls are installed the source gets

comfortable with it (in some cases is even proud of it)• No one wants to be blamed for it (or pay for it)• US EPA is the designated arbitrator of who to blame (and

pay). EPA is our national health & safety officer and air emission grand policeman

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Regulated Air Pollutants• Particulate matter (PM10, PM2.5)

• Sulfur dioxide (SO2)

• Carbon monoxide (CO)

• Nitrogen oxides (NOx)

• Volatile organic compounds (VOC)• Lead (Pb)• Toxins (Hg, BTEX, As, POMs, “chlor.” 188 listed)

• Greenhouse gases (GHG) mainly CO2 and CH43

How are These Pollutants Regulated? (by Ambient Conc.)Maximum ambient concentration limits, the most common of which are the National Ambient Air Quality Standards (NAAQS) There are NAAQS for PM2.5, SO2,CO, NOx, O3, Pb

The USA is divided into “attainment” and non-attainment” areas. The emissions limits are tighter for non-attainment areas. Offsets are required for larger sources

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How are These Pollutants Regulated? (by Ambient AQRVs)

• Special ambient limits for Class 1 areas. These include very low concentrations, acidification of alpine lakes, visibility degradation.

• Class I areas include national parks and the

older wilderness areas

• Important to Routt County because we are located between Flat Tops and Mt. Zirkel Wilderness Areas

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How are These Pollutants Regulated? (by Emissions)

• Emission limits defined for each class of emission units. Steam boilers, refineries, steel plants, gravel crushing operations, municipal incinerators, many more.

• There are emission limits for all of the regulated pollutants

• EPA is scheduled to issue emission limits for O&G production (and gas fracking) April 17, 2012. We do not know if industry will contest these, in which case they will be delayed.

• Newer IC engines, both gasoline and diesel are limited (the Tier 1 through 4 engines)

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How are These Pollutants Regulated? (by Fuel Quality)

Fuel quality is regulated at the refinery

• Natural gas – always been clean, getting slightly cleaner

• Gasoline - lower BTEX to breathe at pumps

• Diesel - the sulfur is being eliminated

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Why Do We Care About Air Emissions? • We are starting as of today with very clean air in Routt County,

some of the cleanest in the nation

• PM (mostly elemental carbon) or soot is so fine it lodges in our lungs)

• PM (mostly elemental carbon) causes regional haze

• SO2 aggravates respiratory infections

• SO2 and NOx are acids, cause acidification of environment

• VOC cause ozone which aggrivates respiratory diseases

• Toxins are poisons

Oil Exploration & Production and Sources of Air Pollution• Wellsite Drilling equipment - IC engines to generate

electrical power which powers drill rig. NOx, PM

• Well Development and maintenance - flow-back & flaring. VOCs (GHG if not combusted)

• Well production gases from separator, tanks, and leaks. VOCs (GHG if not combusted)

• Trucks used to transport the liquids away from the well pad – IC engines. NOx, PM

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What Are The Hydrocarbons That Escape From Oil Production (field gas)?

Methane (CH4)– about 94% (by volume)

Ethane (C2H6)– about 3% (by volume)

VOCs (C3 and higher including BTEX & aeromatics) – about 3% (by volume)

By allowing 5 tons per year of VOC we are also allowing about 50 tons per year of CH4 & C2H6

Photos of Current-Technology Well-Site

First photo: Well site showing emission units – all of which are enclosed and vented to a high-efficiency incinerator

Second photo – closeup of heater treaters with operating incinerator behind

Third photo – closeup of operating incinerator exhaust (invisible exhaust is one sign of near-complete combustion)

Incinerator Operating Properly

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Typical Oil Production Well Site

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ProducedWater

Oil

Incinerator or other combustor

Heater - Treater

Well

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Oil Production Well Site – Mechanical Pump Jacks

Can the Industry Easily Control its Air Emissions Better than Required by COGCC

• Wellsite Drilling equipment - IC engines to generate electrical power which powers drill rig. Yes – by restricting drill engines to recent-vintage (Tier 2 or better)

• Well Development and maintenance - flow-back & flaring. Yes – through closed loop systems and offgas flares or incinerators. Already being offered by operators in RC

• Well production gases from separator, tanks, and leaks. Yes - through capturing of gases and combusting them (incinerator, heaters, IC engines, pipelines to other hosts)

• Trucks used to transport the liquids away from the well pad – IC engines. Yes - by operator requiring well-maintained trucks

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Why Should We Not Tolerate Out of Date Emissions Control Technology

• All of the above are required in other Colorado locations and adjacent states

• Currently available drilling and production equipment can easily meet tighter emission limits – than CAPCD requires for Colorado attainment areas (Routt County)

• Why should we have to live with dirtier projects simply because we are starting with clean air?

• We become the dumping ground for equipment not good enough for the North Front Range and Wyoming.

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Photo of incomplete combustion

Butane from well is exhausted through a flare (poorly-controlled combustion)

Substantial elemental carbon (soot) indicates that the flare is not designed or not operating properly

Opacity is at or near 100%, which is well above the Colorado Air Regulation 1, Section II.A.5 which limits plume opacity to lower than 30% (averaged over 6 minutes).

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