Operators claim they're not at fault.
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Operators on the Pinedale
Anticline Project Area said last week they
checked their facilities for potential emissions
leaks that could have caused the extremely
high ozone exceedances in March.
The 2019 winter ozone season ran long,
with five “ozone outlook” notices, 16 “ozone
action days” and 10 days of exceedances of
the federal eight-hour ozone threshold of 70
parts per billion.
Winter ozone is created when sunlight
cooks emissions of volatile organic compounds
and nitrogen oxides to form a groundlevel
layer of the pollutant, which can cause
and exaggerate respiratory problems.
And although Pinedale Anticline operators
followed ozone contingency plans, reduced
emissions and found only “minimal” emissions
leaks during high ozone levels, no further
information emerged about the potential
pollution sources that peaked in March.
The Pinedale Roundup asked DEQ administrators
if they have investigated other possible
sources such as uncovered ponds at the
Anticline Disposal Facility; no one responded
before press time.
Operators’ reports
The operators’ annual meeting on April
25 took place at the Bureau of Land Management’s
Pinedale Field Office.
Ultra Resources’ environmental and
regulatory manager Kelly Bott of Denver
addressed ozone contingency plans and emissions
reductions. The company is “phasing
out” pneumatic pumps to replace them with
solar power and converting some facilities to
electricity, she said.
Bott also outlined how Ultra and its employees
prepared for the 2018-2019 winter
ozone season.
“Almost all our staffers subscribe to the
(DEQ’s) ozone notification and we really emphasize
(training) in the pre-season. … Ultra
has a policy of no vehicle idling, ever.”
With the DEQ calling 16 ozone action days
in March, Ultra deferred deliveries, fueling
snowplowing and noncritical travel. Exceptionally
high ozone readings in the Boulder
air-quality monitoring station led Ultra to
check possible high sources of NOx and
VOCs.
“We talked with DEQ with some additional
measures,” she said. Ultra checked its
major emissions sources “and we confirmed
our leaks were very minimal during that time
frame. There was nothing anomalous found
with Ultra.”
Charles Prior of Pinedale Energy Partners
Operating related that PEPO also submitted
an ozone contingency plan to DEQ with employees
pre-trained and emission reductions
implemented the days around an official
ozone action day. This year, PEPO deferred
or postponed tank hauling, nonemergency
construction, fueling and deliveries as well
as shutting down ancillary equipment in the
field. The operator also plans to use solar
power for some equipment.
“We also want to have no idling on our
vehicles,” including contractors, Prior said.
PEPO conducts “rigorous leak detection
full-time, all the time.” He said facilities in
the Riverside and Boulder areas were inspected
and “confirmed leaks were minimal.”
Paul Ulrich of Jonah Energy said due to
its small holdings in the Anticline, there was
no activity last year and none is expected this
year.
Jonah uses fluorescent gas-leak detection
cameras and the majority of its operations are
in the Jonah Field. By the end of 2020, at least
nine locations will have emissions controls on
tanks, he said.
Ulrich also described a pilot project to
evaluate consolidating well-site compression.
He described it as tying more wells to a single
central delivery point for less surface disturbance
and lower air emissions.
“We would be reducing the overall footprint,”
Ulrich said. “There are a lot reasons
why consolidating reduces emissions overall.”
He reported Jonah’s use of a large drone
mounted with leak detection cameras is
“looking very, very promising.”
Attainment?
Janet Bellis, BLM’s liaison with DEQ,
presented the Pinedale Field Office’s overview
of 2018 Pinedale Anticline air quality
in respect to the Upper Green River Basin’s
federal “marginal nonattainment” status, assigned
in 2012 after previous ozone standard
exceedances.
She said the Environmental Protection
Agency assigns responsibility for being
ozone compliant to the DEQ. The UGRB’s
nonattainment status came after not meeting
the 2008 ozone threshold of 75 parts per billion.
In 2015, the current ozone standard was
revised to 70 ppb.
DEQ’s Darla Potter, on the phone, went
into more detail, explaining that EPA regulations
for ozone attainment “are very
confusing. It is not simple and it is not
straightforward.”
The DEQ determined the UGRB is in attainment
– but is nowa waiting EPA clarification
about its standards and regulations. “We
have not gone through every step so in fact
we are still ‘nonattainment’ (with the EPA)
for 2008.”
Last year, the EPA divided the UGRB to
appoint Sublette, Sweetwater and Lincoln
counties as in “attainment.”
“That’s why it’s so complicated for
(DEQ),” Potter continued. “We are awaiting
some clarity from the EPA.”
Ozone action days
Potter described high ozone alerts and
actions late in the winter season as “the longest
stretch of ozone action days since we’ve
started the program.”
Boulder posted nine days of 105 ppb while
Daniel reported a maximum of 72 ppb. Pinedale,
Big Piney and Juel Spring showed no
exceedances.
“What’s unique about this winter ozone
season, the majority occurred at the Boulder
monitoring station,” she said. “It was different
than any other station. We did not have
any days (at the others) that were above that
level.
DEQ staff performed quality control because
Boulder levels were high throughout
the day instead of late afternoons. “We’re
very much in the process of looking at all that
information.”
Inspectors visited facilities and did walkthroughs
to verify compliance or look at a
particular area or source.
Carmel Kail asked Potter what will happen
if the Boulder station’s ozone data show
a high average she calculated at 72 ppb.
“The EPA is not explicitly clear on what
happens in a situation such as this,” Potter
said.
Regulations “do not specifically address”
this situation with three counties, she added.
“We are actively exploring this.”