From the pages of
Pinedale Roundup
Volume 105, Number 9 - February 28, 2008
brought to you online by Pinedale Online

EPA slams BLM draft

by Alecia Warren

The Environmental Protection Agency (EPA) has given its lowest rating of “environmentally unsound” to the Bureau of Land Management’s (BLM) Revised Draft for the Supplemental Environmental Impact Statement (RDSEIS) for the Pinedale Anticline Project Area (PAPA) released in December. The revised draft presents “significant, adverse long-term impacts to air quality and groundwater quality,” that could result in public health hazards, according to the EPA’s written comments to the BLM.

The EPA found its first disappointment in how the BLM had weakened the language in the draft’s air mitigation plan, which the EPA had been “heavily involved” in writing for the original SEIS.

“There aren’t the firm commitments to reduce the visibility to the Bridger-Wilderness area as we saw in the earlier supplement,” said Larry Svoboda, EPA spokesperson. This criticism was backed by the National Forest Service, which predicted in its letter to the BLM that emissions would create visibility impairments to the Bridger, Fitzpatrick, Washakie and Teton Wilderness Areas.

The EPA further censured the revised draft’s ozone emissions model. The model, updated from the original draft, predicts that ozone concentrations on the anticline will reach .075 parts per million, just under the National Ambient Air Quality Standard of .08 parts per million. Emission must exceed .084 parts per million for an eight-hour period to be called a violation.

The BLM acknowledged the model was likely under-predicting the ozone levels, so actual emissions would probably reach or violate the national standard, Svoboda said. On top of that, the EPA will conduct its five-year review of the air quality standard this March, and might lower the standard to under .08 parts per million, which would make the draft’s model a blatant prediction of air-quality violation.

Ozone emission standards are in place to prevent health hazards, Svoboda said. “Ozone is an extreme irritant to both the lungs and eyes and can do so to a fully healthy individual,” he said. “But when someone has any kind of chronic pulmonary disease of any sort, it complicates it even more. It’s particularly dangerous for sick people, young people and old people, and that’s the population we need to protect.” The EPA further criticized the draft’s data revealing 88 of 230 wells have benzene contamination, with two contaminations exceeding the Drinking Water Standard. The number raises frightening concerns about potential future impacts from drilling operations, Svoboda said.

Benzene is also a known carcinogen, and research has revealed a correlation between benzene exposures and certain cancers, Svoboda said.

Perry Walker, an air quality scientist in Daniel, said that even he has criticized the BLM’s air quality modeling methods for years.

The model incorrectly predicts ozone levels, he says, because it factors in emissions, wind and terrain measurements from industry standard models, instead of measurements made directly on the field.

This method overlooks significant details unique to the anticline, for instance that the rigs operate between a 7,000 and 9,000-foot elevation, which affects how chemicals combust into the atmosphere, Walker said. The model also relies on obsolete wind level averages from the late ‘90s and early ‘00s, which Walker said obscures predictions of how the wind carries anticline pollutants into class one and two air sheds.

“I’ve slowly come to realize more and more that this entire modeling prediction of a rosy future with only a handful of days with visibility impairment is garbage,” Walker said. “What I’ve told the EPA, the Department of Environmental Quality and the industry is: until you can demonstrate to me that you have actually collected empirical measurements, put them into the model and gotten output that matches what should happen with those empirical inputs, you have failed to validate that model to me, and failed to prove that model is an effective tool for measurement.”

TRC, the company contracted for the modeling, as well as the EPA and the operators, all have told Walker that taking direct emissions measurements on the field would simply be too expensive.

Svoboda said the EPA will “carefully” evaluate the BLM’s model, but couldn’t predict what would come of it.

The EPA has otherwise arranged meetings with the BLM and the Department of Environmental Quality (DEQ) to evaluate the EPA’s ozone, visibility and groundwater concerns.

Bill Lanning, project manager at the Pinedale BLM Office, declined to comment on what he expected from these meetings, but Svoboda said the EPA is optimistic. “We’ve had good success in working with the Wyoming office of the BLM,” he said. “We understand the importance of the anticline to our future, but we do believe with some more work and a better plan, this development can move forward in a more environmentally protective manner.”

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