Oil and Gas Issues WESTAR Spring 2008 Park City, UT
Issue: Emission Factors Completions, venting/flaring, fraccing Tanks Dehydration units Pumps Pneumatic controllers Well blow downs Pipeline venting Truck traffic Fugitives Malfunctioning systems
Uncertainties § § § Uncontrolled versus controlled emissions Do we account for all the sources? Are controls reliable?
VOCs or NOx? § If ozone is the issue, what should be controlled? § Modeling tools? § Rural versus urban? § Model performance? § Episodic conditions? § Wyoming so far: $1. 1 million and growing
Feds v. States § § § Coordination issues with BLM, DEQ, EPA State capacity to evaluate regional impacts Inconsistent emission inventories, modeling assumptions, consideration of future projects § Conflicts with EPA R 8 § Visibility issues
Future Actions § One or more revisions to Wyoming’s oil and gas BACT guidance: – Add controls for all pumps; replace pneumatic controllers; control pipeline venting; control water tanks; control well blowdowns; control fugitives; expand more stringent JPDA requirements to ‘other concentrated development areas’. § § Control drill rig emissions Drive compression BACT lower Modeling Additional controls to prevent nonattainment – To avoid episodic conditions; – To lower ozone generally