From the pages of
Sublette Examiner
Volume 8, Number 19 - August 7, 2008
brought to you online by Pinedale Online

DEQ Back In Pinedale To Address Air, Water Quality

by Tiffany Turner

The Wyoming Department of Environmental Equality (DEQ) hosted another public meeting July 30 to update concerned citizens and discuss its current actions to combat the rising air and water pollution in the industry fields of Sublette County.

DEQ Director John Corra was present along with a cortege of staff to address about 100 citizens gathered with questions and comments.

The agency’s presentation consisted of slides and speeches informing the local populous of new regulations and actions and what to expect in the near future. Community members had chances to ask questions during the public forum and to speak with DEQ staff privately after the meeting.

Water quality

“There is not a lot that has changed,” Corra said of the water-quality situation here. “There are a couple of points worth mentioning.”

One point made was the DEQ has asked the Bureau of Land Management to clarify its new rules and regulations in its upcoming Final Record of Decision (ROD) to avoid future confusion.

In addition to the operators’ planned mitigation funds, Corra added, the DEQ has reached an agreement with them to supply additional money for the DEQ’s portion of monitoring costs in the fields. Those funds, nearly $1.5 million, would also be included in the ROD.

To update the public since the last meeting in April, Corra said DEQ has narrowed down the cause of the raised hydrocarbon levels in several infected wells. According to Corra, Shell Rocky Mountain performed tests on their wells and disscovered the pipe putty they use has an almost identical chemical composition to those well findings.

Since gathering this information, Shell has switched to a silicone-based putty and has found no further hydrocarbon readings in the water wells they used.

Pit guidelines

Another subject of dispute during the April meeting was the operation and guidelines of evaporation pits in the Anticline and Jonah.

“We went back home and committed the people who work in that area to look at it,” Corra said. “New guidances are being formed.”

“It is something we need to be doing,” he added.

The regulations are slated to be released by Oct. 1 and will include construction details, monitoring and reporting requirements.

The rules and regulations are not necessarily new, Corra said, but they will step up the communication levels to those operating these evaporation pits as to what is actually expected of them. Many citizens worried about what steps the DEQ can take should proof of a violation occur in or around wells and evaporation pits. Corra informed those present the DEQ depends on the Sublette County Conservation District for testing levels on a monitoring level.

The first step once anything is detected is to determine whether the levels are above or below regulations, according to Mark Charles, DEQ Water Quality Standards program manager. If the detected levels are below regulation, studies will be done to determine the source of the hydrocarbons or other chemicals and hopefully negate the impact. If the levels are above the allowable state, the well is then enrolled in the DEQ Voluntary Remediation Program at the operator’s expense.

If a violating operator chooses to not volunteer, the DEQ will take action at their expense, Charles clarified.

“If they do not do it voluntarily, we have the right to come enforce it,” Charles said. “You either volunteer or we come get you.”

The remediation program helps determine a course of action to solve the violation. The company then investigates at its own cost and returns to the DEQ for permission to move forward with a final solution, which is then implemented and followed until the infected site again meets minimum requirements. Regular monitoring continues long after the problem is deemed under control.

Air Quality

For the bulk of the DEQ meeting, DEQ’s Air Quality Division Manager Dave Finley discussed the strides taken to restrict and record the levels of pollutants in Sublette County air, a large worry after multiple ozone alerts early this year.

“I think some significant steps were taken since April,” Finley said. “We’ve taken some significant steps toward our own ability to enforce our regulations out there. … Since our last meeting, the net (volatile organic compounds) readings have decreased by 400 tons per year.”

According to Finley, strategies under way to reduce NOx and VOC levels include voluntary industry incentives, Air Quality Division (AQD) Best Available Control Technology (BACT) requirements and non-voluntary measures.

“We need to tackle the existing emissions,” Finley said.

According to Finley nearly 50 percent of all NOx emissions are from drilling rigs and 57 percent of all VOC comes from dehydration units, with the next largest coming from tanks and pneumatic pumps.

Voluntary initiatives in the works include:

• Retrofitting production equipment,

• Redesigning systems to reduce or eliminate emission points and

• Reducing emissions from drill rigs.

The AQD issued a “formal call” for operator commitment to the voluntary initiatives on July 21, Finley said, and has received mixed results from the operators, who show a hesitancy to commit to the program without knowledge of the DEQ’s final strategic plan.

“It really does not matter to me if we have individual commitment,” Finley said. “It has to be done – and it will be done.”

“We think it is in the best interest of the industry and definitely the air quality … to do this quickly,” Finley added.

If the voluntary actions go into effect before all regulations are in place, he said, the operators can fix the problems without penalties from the AQD.

EnCana has already sent a response to the DEQ, explaining they will have all rigs functioning on Tier II-emissions controls “by the soonest possible date.” Finley expects this to be some time in 2009. EnCana also plans to modify its gathering systems to decrease VOC by 40 percent. Finley added he expected others to soon follow suit.

“We really do expect other companies to gather together … come to us and put (their voluntary actions) down on paper,” Finley said. “We really need to know how much of that (reduction) is going to take place without us.”

If the operators cannot agree to undertake many changes voluntarily, DEQ will enforce the more stringent new requirements, Finley said.

In addition to the voluntary initiative, the new 2008 BACT requirements will include required controls for producing water tanks, tank loading, pneumatic controls and well blow downs.

“Our requirements get more stringent to reflect the increase in technology,” Finley said.

Another requirement will be regulations and controls on tanker trucks; every time a tanker refills, the air displaced releases emissions into the atmosphere.

Other non-voluntary requirements will include increased permitting rules and regulations, more controls on the levels and machinery in the fields and precise ozone levels, with a margin of safety, for healthy living. The DEQ will increase knowledge of events by creating an ozone model for the Upper Green River Basin, as most current models focus on summer levels in urban environments.

“We don’t really have the tool that places like Los Angeles and Denver have,” Finley said.

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