EDF Presentation in Support ofblogs.edf.org/.../files/2014/02/EDF_APCD_Presentation.pdf ·...
Transcript of EDF Presentation in Support ofblogs.edf.org/.../files/2014/02/EDF_APCD_Presentation.pdf ·...
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EDF Presentation in Support of the APCD’s Proposed Rule
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Proposed Rules Make Sense for Colorado
• Widespread support from:
– Industry Leaders
– The Environmental Community and
– Local governments
• State-wide reductions in ozone precursors and methane emissions are necessary to protect Coloradan’s health and environment
• Highly cost effective
• Common sense and practical, with appropriate flexibility and accommodation for smaller, lower emitting facilities
• Highly Effective: Will remove over 93,000 tons of VOCs and more than 110,000 tons of CH4 from the atmosphere
• Ensures Colorado continues tradition as national leader in clean air measures
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O&G activities are a large and steadily increasing source of ozone precursor and methane emissions
– Oil and gas activities: • The largest source of anthropogenic VOCs in Colorado
• The largest industrial source of methane in Colorado
– Other sources of VOCs are decreasing while oil and gas VOCs continue to grow
– Existing regulations have failed to keep pace with burgeoning development
– NSPS will not address • The hundreds of thousands of tons of pollutants currently being emitted
from many existing sources
• Fugitive emissions and vented well maintenance emissions from new sources which are the two leading sources of methane emissions in the state
• The over 60,000 tons of VOCs leaked from tanks with inefficient capture
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COLORADO MONTHLY ACTIVE WELL COUNT
51,69350,500
52,500
54,500
12-06-13
42,500
44,500
46,500
48,500
,
IVE
WE
LL
S
34,500
36,500
38,500
40,500
,500
ER
OF
AC
TI
26 500
28,500
30,500
32,500
34,500
NU
MB
E
22,500
24,500
26,500
N 2
002
AP
RJU
LO
CT
N 2
003
AP
RJU
LO
CT
N 2
004
AP
RJU
LO
CT
N 2
005
AP
RJU
LO
CT
N 2
006
AP
RJ
UL
YO
CT
N 2
007
AP
RJ
UL
YO
CT
N 2
008
AP
RJ
UL
YO
CT
N 2
009
AP
RJ
UL
YO
CT
N 2
010
AP
RJ
UL
YO
CT
N 2
011
AP
RJ
UL
YO
CT
N 2
012
AP
RJ
UL
YO
CT
N 2
013
AP
RJ
UL
YO
CT
JA
N
JA
N
JA
N
JA
N
JA
N
JA
N
JA
N
JA
N
JA
N
JA
N
JA
N
JA
N
Source: COGCC: Colorado Weekly & Monthly Oil and Gas Statistics 12/6/13)
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COLORADO NATURAL GAS PRODUCTION 1995 2012
6.00
ay
)
1995-2012BILLION CUBIC FEET OF GAS PER DAY 12-06-13
3 44 3 674.13
4.33 4.554.654.69
4 00
5.00
( b
cf/
da
1 931 982.182.292.602.83 3.00 3.15
3.44 3.67
3.00
4.00
PR
OD
1.521.601.781.931.98
1.00
2.00
AL
GA
S
0.00
AN
NU
A
Source: COGCC: Colorado Weekly & Monthly Oil and Gas Statistics 12/6/13)
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COLORADO OIL PRODUCTION 1995-2012THOUSAND BARRELS PER DAY 12 06 13
135.3140
160
00
THOUSAND BARRELS PER DAY 12-06-13
107.2
35 3
100
120
140
ON
(100
)
78.470.2 66.8
61.452 9 54 1 55.156.2 58.9 61.763.5
66.4 69.179.1 81.6
89.6
80
100
DU
CT
IOb
l/d
ay)
52.9 54.1 55.1 61.7
40
60
PR
OD bb
0
20
OIL
Source: COGCC: Colorado Weekly & Monthly Oil and Gas Statistics 12/6/13)
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Oil and gas production and emissions are expected to increase • EIA predicts US production to increase by
84% between 2013 and 2040
• WPX plans to drill additional exploratory wells in the Piceance, increasing its capital expenditure in the Basin to half a billion dollars
• BLM White River Field Office EIS: contemplates 1,800 new well pads
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Significant development occurs outside the NAA
• 75% of new well starts in 2012 occurred outside the nonattainment area
• Large parts of the Niobrara where much of the new development is focused, occur outside the NAA
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RECENT COLORADO OIL AND GAS
WE PERMITSWELL PERMITS 12-06-13
Source: COGCC: Colorado Weekly & Monthly Oil and Gas Statistics 12/6/13)
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Division modeling predicts VOCs from Oil and Gas increase while other sources decrease
2011 2018
Oil and Gas 567.2 (54%) 869.8 (68%)
On-Road Vehicles 167.7 (16%) 122.9 (10%)
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O&G activities contribute to ozone pollution
DGS source apportionment modeling: VOCs from oil and gas facilities contribute
• 1.19 ppb to monitor at Greeley,
• 0.50 ppb to monitor at Fort Collins West, and
• 0.53 ppb to monitor at Fort Collins.
DGS sensitivity modeling:
• Reducing VOCs from oil and gas sources leads to widespread ozone decreases throughout the Front Range
• 20% reduction in oil and gas VOC emissions decreases ozone up to 1.67 ppb.
Meteorological modeling: VOC emissions from sources on the Western Slope and Southwest part of Colorado travel east and north and contribute to the Front Range nonattainment problem.
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O&G activities contribute to ozone pollution cont. • O&G activities are responsible for majority of
anthropogenic VOCs at monitors across the state
– 92% in Weld County
– 84% in Yuma County
– 85% in Montezuma County
– 97% in Rio Blanco County
– 91% in Garfield County
– 81% in Moffat County
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Statewide reductions in VOCs and CH4 are necessary and appropriate • Achieving “the maximum practical degree of air
purity in every portion” of the state, maintaining and attaining the federal health-based ambient air quality standards, and preventing “significant deterioration” of pristine air, are fundamental tenets of Colorado clean air policy. C.R.S. § 25-7-109(1)(a).
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Majority (55%) of wells and facilities are located outside the nonattainment area
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NUMBER OF ACTIVE COLORADO OIL & GAS
WELLS BY COUNTY
20,884
20000
22000
87.0% of Colorado's 51,693 active wells are located in these 6 counties
(12-06-13)
16000
18000
20000
LS
10,55810000
12000
14000
CT
IVE
WE
LL
3 885
7,001
6000
8000
10000
MB
ER
OF
AC
3,885 3,3393,079 2,947
2000
4000NU
0WELD GARFIELD YUMA LA PLATA LAS ANIMAS RIO BLANCO 36 OTHER
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Ozone pollution is an increasing problem outside the nonattainment area
• Rangely monitor violates the 8-hr NAAQS this year. Neither unique nor poorly understood.
• CDPHE issued 9 ozone advisories last winter for Moffat and Rio Blanco counties indicating air quality was unhealthy for children and adults active outdoors as well as asthmatics and older adults
• Clean Air Scientific Advisory Committee recommends an ozone standard between 0.060 and 0.070 ppm
• Oil and gas VOCs emitted in Western and Southwest Colorado transport east and north and contribute to the Denver Front Range nonattainment area.
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8-9 monitors in Western and Southwest Colorado will fall into nonattainment if EPA lowers the 8-hr ozone standard to 65 ppb
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Immediate near term CH4 reductions are necessary to combat climate change
• Climate change is “unequivocal” and it is “virtually certain” that human influence has warmed the climate (IPCC Report)
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Immediate near term CH4 reductions are necessary to combat climate change
• Per January 16, 2014, AQCC meeting: Colorado is already experiencing adverse impacts from climate change, including:
– increased droughts,
– reduced snowpack,
– wildfires, and
– other extreme weather events.
• These impacts threaten important ski and other recreation economies, crops, and way of life.
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AQCC has clear authority to regulate hydrocarbons
• Section 109 of the APPCA provides the Commission with clear authority to regulate hydrocarbons
• Indeed, AQCC already regulates hydrocarbons from large oil and gas emission sources pursuant to EPA’s Tailoring Rule
• Arguments that AQCC should delay pending further federal action are meritless
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Significant benefits accompany CH4 reductions
• Will reduce CH4 emissions by over 110,000 tons per year
• Will generate at least $100-300 million a year based on central values for the cost of carbon from the US government
• Division Estimates that rule will result in $16.8 million of captured product otherwise lost to the atmosphere
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Rule is Cost Effective
• Average cost per ton of VOC reduced is less than $500 a ton of VOC reduced, per estimate from the Division (not accounting for reduction in methane emissions)
• Average cost per ton of methane reduced is less than $500 a ton of methane reduced, per estimate from the Division and WZI (not accounting for reduction in VOC emissions)
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Rule is narrowly tailored, provides flexibility, and accounts for operational differences • Tiers for LDAR: only 12% of sites (the largest) are subject to monthly
inspections; smallest sites need only do instrument inspection once
• Low-VOC sources, such as CBM facilities and certain “dry” gas sources, subject to minimal requirements
• Extended implementation dates for existing sources
• Well maintenance “BMP” and STEM requirement allow operator to determine how best to control emissions
• Safety and process exceptions provided in tank, fugitive, pneumatic and well maintenance requirements
• Tailoring requirements to emissions, rather than geographic location, ensures rule achieves maximum emission reductions at reasonable cost
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Well sites with 0-6
tpy of VOCs:
One-time
Well sites with 7-12
tpys of VOCs:
Annual
Well sites with 13-
49 tpys of VOCs:
Quarterly
Well sites with 50
tpys or more of
VOCs: Monthly
Inspections are tiered to size of well site
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LDAR is reasonable and appropriate
• Fugitive emissions are second largest source of VOCs and CH4; NSPS will not address
• DGS group critique of cost is riddled with inconsistencies and flawed assumptions that renders the analysis highly unreliable and meaningless
• Weight of evidence demonstrates frequent monitoring yields greater reductions than skip or step down monitoring at reasonable costs
– Leak discovery increases with inspections; converse is also true.
– Skip monitoring provides incentive for operators to not find leaks; presents enforcement challenges.
– Certain components require frequent tightening to control leaks
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Colorado is a leader
• Commission has demonstrated history of leadership when it comes to protecting clean air. Landmark rules in 2004, strengthened in 2006, 2008 and again today
• In keeping with this tradition, Governor has announced “zero tolerance” policy for methane
• Industry has thrived in Colorado even as new rules were developed and implemented under this proactive approach
• Arguments to delay pending further federal, state or global action are meritless and contradict this tradition and sound policy
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Proposed Rules Make Sense for Colorado
• Widespread support from:
– Industry Leaders
– The Environmental Community and
– Local governments
• State-wide reductions in ozone precursors and methane emissions are necessary to protect Coloradan’s health and environment
• Highly cost effective
• Common sense and practical, with appropriate flexibility and accommodation for smaller, lower emitting facilities
• Highly Effective: Will remove over 93,000 tons of VOCs and more than 110,000 tons of CH4 from the atmosphere
• Ensures Colorado continues tradition as national leader in clean air measures