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What are theWhat are the Air Quality Regulation Changes Air Quality Regulation Changes About?About?

• Require the use of best management practices and technologies to reduce oil and gas emissions into the atmosphere.

• Require the industry to conduct self-inspections and to repair any leaks that are discovered.

• A forward attempt to REGAIN attainment in some areas and RETAIN attainment in other areas in the continuing development of resources.

Examples of Best Management and TechnologyExamples of Best Management and Technology

“Green Completion” SchematicHaving 2 stage separator reducing pressure allows greater removal of VOCs from gas

stream and reduced pressure surges on storage tanks

Little known fact: 8 drips per second = 1 bbl in 24 hrs. the reportable amount by COGCC rules.

WHY?WHY?

Regional •Front Range in Non-Attainment for Ozone•NW Colorado in Non-Attainment for Ozone.

Local•Dust •Toxic emissions•Carcinogenic

(Benzene)

Global•Methane is 34 X more potent greenhouse gas than CO2

OZONE IS ONE PROBLEM

BUT, there are many others•SO2 is Sulfur Dioxide

•NOx is a group of different gases made up of different levels of oxygen and nitrogen

•Two of the most common nitrogen oxides are: Nitrogen Dioxide and Nitric Oxide•NOx is given off in many forms, such as smog or particles

•VOCs are Volatile Organic Compounds that are a large group of carbon-based chemicals that easily evaporate at normal temperature.

Image: http://www.epa.gov/acidrain/what/index.htmlImage: http://www.epa.gov/acidrain/what/index.html

The Local Community Organizations are putting forward a proposalthat addresses the issue of LOCAL emissions by requiring those oil and gas facilities within 1,320 feet of a building unit or outdoor activity area to:

• Control O&G Facility VOCs down to 2 TPY.

• Have more frequent inspections (although still tiered to potential VOC emissions).

• Require faster repair times for any leak with a concentration of hydrocarbons of 10,000 ppm or above.

• Would also require annual inspection reports that are proposed to be submitted by operators to be posted online by the Air Pollution Control Division (APCD) and have safeguards to ensure transparency.

• Support the new regulations as a way to bolster agricultural production which is likely diminished by at least 5% through high ground level ozone level.

What is involved?What is involved?

PadsCompressors Condensate and

Produced H2O Tanks

Glycol Dehydrators

Regulation Area Existing Rule New State Proposal

Pollutants Regulated VOCs only Hydrocarbons (including methane)

Leak Detection and RepairXVII.F.

None

Covers well sites, storage vessels (all tanks), gathering compressors.

Requires instrument-based detection methods as primary detection method. Creates incentive for continuous emission monitors.

Tiers and thresholds based off VOC, but control requirements apply to all hydrocarbons (i.e. VOC and methane).

Leak inspection frequency for well sites and condensate tanks(tiers based on TPY):0-6: One time instrument-based detection; only monthly auditory-visual-olfactory (AVO) thereafter6-12: Annual instrument-based, monthly AVO.13-50: Quarterly instrument-based, monthly AVOOver 50: Monthly instrument-based.Multi-well sites >20TPY without tanks: Monthly instrument basedLeak inspection frequency for compressors:0-12: Annual instrument-based.13-50: Quarterly instrument-based. Over 50: Monthly instrument-based.Leak threshold: 500 ppm for new and existing well sites; 2,000 for existing equipment not at well sites.

Repairs within 5 days, or within 15 days of receiving a part if not in stock.

Source: MATTHEW SURA Attorney at Law, 2014

Pollution Source Existing Rule New State Proposal

Tanks (Control requirements)

XVII.C.1

Condensate tanks with uncontrolled emissions 20 TPY must control all hydrocarbons by 95%.

New and existing condensate, crude oil and produced water tanks (all tanks) with uncontrolled emissions 6 TPY must control all hydrocarbons by 95%.

98% destruction and removal efficiency (DRE) required on combustion devices.

Tanks (Venting prohibition)

XVII.C.2. None

Prohibit venting during normal operations from all tanks with 6 TPY of VOCs or controlled as part of an operator's nonattainment system-wide program.

Must employ storage tank emissions management plan (STEM) designed to assure compliance with no venting provision. Must “route all emissions to air pollution control equipment”

Monthly AVO (audio-visual-olfactory) inspections.

Must certify that plan will minimize emissions.

Venting from well maintenance and liquids unloading activities.

None

Require capture from well maintenance and liquids unloading unless venting necessary for safety. Operators must use best management practices to minimize emissions, including remaining on site during well maintenance to minimize emissions. Record keeping documenting cause, date, time and duration of venting.

Glycol Dehydrators90% control of VOCs from

dehydrators that have at least 15 TPY of VOCs

New dehydrators: 2 TPY threshold, 95% control requirement, combustion devices must have 98% DRE.

Existing dehydrators: Same as new, except 6 TPY threshold. Existing dehydrators located within 1/4 mile of homes, buildings and recreation areas have same requirements as new dehydrators

Required Permits 5 TPY statewide and 2 TPY in

nonattainment area must have permits

No rollbacks to existing requirements.

Source: MATTHEW SURA Attorney at Law, 2014

But Garfield is under NAAQS limits!But Garfield is under NAAQS limits!

> <

Garfield County is under the PSD of > .075ppb

There is more to the picture There is more to the picture ––

Fig. 2 from Exhibit 8.pdf of Local Community Organization party filing for AQCC Hearing.

From 2010 through 2012 there are spikes > .075. The overall trend is rising. As O&G development continues, non-attainment will become a Garfield problem. Non-attainment is not a limit to be filled – it is a level

to stay under for healthier air.

00

O&G AREA POINT CONDENSATETPY 62361.7 22157.9 125800.2

2011 - VOC Regional Tab

State O&G VOC in TPY by SourceTotal = 576.2 tons/day

22,157.911%

125,800.259%

62,361.730%

O&G AREA

POINT

CONDENSATE

With 576.2 tons/day, 30% Area source would be 172.9 tons/day.

Garfield’s share is 32.2% or ~55 tons/day or 20,080 TPY.

2011- % of Total State O&G VOCs Sources for Select Counties

0.00%

10.00%

20.00%

30.00%

40.00%

50.00%

60.00%

70.00%

80.00%

Highway Vehicles O&G Area Sources O&G Point Sources O&G CondensateTanks

Sources

% o

f Sta

te T

otal

O&

G V

OC

s

ADAMSGARFIELDMESARIO BLANCOROUTTMOFFETWELDYUMA

Garfield County is the highest in the State for Area and Point source VOC emissions. Weld County is the highest in the Condensate tanks. There is about 2/3 more development in Weld. A reason that Weld and Rio Blanco have lower emissions (with the exception of Condensate) may be the higher number of oil wells and subsequent less venting in efforts to prevent liquid losses.

Source for both charts: APCD spreadsheet, 2011InventoryValues.xls, Tab VOC Regional

ADAMS GARFIELD MESA RIO BLANCO ROUTT MOFFAT WELDTotal County VOCs 20055.7 66643.2 39327.2 55123.3 26569.0 33372.0 136010.2

O&G Area Sources 788.2 20080.1 2335.2 3639.7 39.7 829.9 15119.6

O&G Point Sources 436.2 6374.1 864.5 3277.7 6.2 2033.1 6181.1

O&G Condensate Tanks 1507.0 9284.2 330.4 18325.9 240.3 1262.0 85060.4Total O&G TPY by County 2731.4 35738.4 3530.0 25243.3 286.2 4125.0 106361.1

% of Total by O&G 14% 54% 9% 46% 1% 12% 78%

Remove Biogenic of: 5,442 27,966 30,300 29,101 25,055 28,263 19,927

14614.0 38677.6 9027.1 26022.1 1513.9 5108.6 116083.6

19% 92% 39% 97% 19% 81% 92%

T o tal C o unty VOC s minus B io genics

O&G % of Total County - Bio

Of the total VOCs from all sources in Garfield County, O&G produces 54%. When the biogenic sources are removed to reveal the anthropogenic causes, O&G is producing 92%. Correspondingly high shares are seen in Moffat, Rio Blanco and Weld Counties.

HAP O&G totals Other totals O&G % of all State Amts.acetaldehyde 202.32 63.07 76.23%

acrolein 145.63 3.05 97.95%benzene 680.21 87.52 88.60%

ethylbenzene 47.17 26.35 64.15%formaldehyde 1096.82 235.49 82.32%

hexane 180.78 63.77 73.92%toluene 953.51 293.77 76.45%xylene 729.63 244.32 74.91%

Methanol 810.81 73.15 91.73% From T ab (2)

Source: Air Pollution Control Division spread sheet "2011pointHAPS" (2 Tabs)

2011 County % of State Total HAP From O&G Point Sources

0.0%

10.0%

20.0%

30.0%

40.0%

50.0%

60.0%

70.0%

80.0%

Acetal

dehyd

e

Acrolei

n

Benze

neEthyl

Benze

neForm

aldeh

yde

Methano

l

Toluene

Xylene

s (Mixe

d Iso

mers)

Hazardous Air Pollutant Emission

% o

f Sta

te T

otal

GarfieldMesaMoffatRouttRio BlancoAdamsW eldYuma

Of the compared Counties, Garfield County is the highest followed by Rio Blanco.

O&G is the highest producer of Hazardous Air Pollutants.

~ 5000 people die in US prematurely every year due to elevated ambient air ozone (Bell et al., 2004)

“The researchers found that an increase of 10 parts per billion (ppb) in weekly ozone levels was associated with a 0.52 percent daily increase in deaths the following week. The rate of daily cardiovascular and respiratory deaths increased 0.64 percent with each 10 ppb increase of weekly ozone. The average daily ozone level for the cities surveyed was 26 ppb.”

John Hopkins School of Public Health, Nov.16, 2004, “Ground-Level Ozone Linked to Increased Mortality”, http://www.jhsph.edu/news/news-releases/2004/dominici-ozone.html, “Ozone and Short-Term Mortality in 95 U.S. Urban Communities, 1987-2000” was written by Michelle L. Bell, PhD; Aidan McDermott, PhD; Scott L.

Zeger, PhD; Jonathan M. Samet, MD; and Francesca Dominici, PhD.

Figure 1. Percentage Change in Daily Mortality for a 10-ppb Increase in Ozone for Total and Cardiovascular Mortality, for Single-Lag and Distributed-Lag Models

The single-lag model reflects the percentage increase in mortality for a 10-ppb increase in ozone on a single day. The distributed-lag model reflects the percentage change in mortality for a 10-ppb increase in ozone during the previous week. Error bars indicate 95% posterior intervals.

NO ENTITLEMENTNO ENTITLEMENTRodger G. Steen, 2014 (edited)Rodger G. Steen, 2014 (edited)

• Clean air is a community resource and no individual or industry is entitled to consume it without restrictions.

• The old concept that clean air is a free resource, available to the first source to consume it up to the level that makes people sick was dispelled 37 years ago in the Clean Air Act of 1977.

• The 1977 CAA (and amendments) established the concepts of concentration increments (Prevention of Serious Deterioration - PSD increments), New Source Performance Standards (NSPS) to be applied to all sizes of sources, and Best Available Control Technology (BACT) to be applied to the larger sources.

• All of these are founded in the current concept that sources areonly allowed to emit that which is necessary for operation with current technology and management tools. Operation or permits are subject to regulation or changed regulations to keep levels below PSD increments.

ConclusionConclusion• Anyone, with even a basic knowledge of airflow, knows that it does not respect human made political

boundaries; and, pollution in one area can have significant impacts in another. An example is Rangely, CO where oil and gas emissions from oil and gas facilities both in Colorado and nearby Utah have recently brought that Western Slope town out of compliance with federal ozone standards .

• Even where ozone has not reached non-attainment status many areas of the Western slope DOexperience air quality problems which is increased by oil and gas operations.

• The EPA has agreed to reconsider the 2008 75 ppb designation stating that the 75 ppb was legally indefensible. The US will likely end up closer to 65 ppb where Canada and most other countries have set their limits.

• Tisha Schuller continually states, “it is not possible to safely and efficiently develop the state’s mineral resources under a patchwork of inconsistent local rules” [1] – It is very inconsistent that COGA is now criticizing that this is a “one size fits all regulation”.

• Capturing methane is a win, win, win. If proper leak controls are put in place, methane, along with volatiles, can be captured and put back into operators’ sales lines.

• EPA Energy Star website states that the payback for many of the technologies that are encouraged by these rules actually pay for themselves within one to two years.

• Already supported by EnCana USA, Noble Energy and Anadarko.

• Every Coloradan deserves to have the air we breathe free from toxic air pollution.• [1] See more at:

http://www.coga.org/index.php/Newsroom/PressReleasesArticle/cogas_statement_regarding_the_longmont_hydraulic_fracturing_ban_lawsuit#sthash.sRHVen5g.dpuf• Bullet statements derived from paper “Point and Counter Point”, Matt Sura , 2014