Air Quality Bureau
Questions and Answers from April 23, 2008 Public Meeting in Farmington
Is it ok to jog early in the morning?
Ambient ozone levels are usually lower in the early morning and peak in the afternoon, so on days when ozone concentrations are high, it is best to exercise in the morning to avoid breathing air with higher concentration of ozone.
Does the NMED monitor for Volatile Organic Compounds (VOCs)?
Not at this time, but NMED has applied for a grant from EPA to measure VOCs in Bloomfield.
Since we are way below standards on Nitrogen Oxides (NOx), are VOCs the "culprit" on the days when ozone concentrations are elevated?
It is not an "either - or" situation with Nitrogen Oxides and VOCs. BOTH things must be present, interacting with each other to produce Ozone. A lot of work needs to be done before this question can be answered. First, a thorough inventory must be made of ALL of the NOx and VOC emissions in the area, including the numerous sources which are below the threshold where they would require a permit. Then a computerized dispersion modeling analysis needs to be completed to determine which emissions are causing the formation of ozone.
How far can ozone be transported?
Ozone can be transported up to a hundred miles from its source. In order for this to happen prevailing winds would have to move it relatively fast since Ozone breaks down at night. Ozone captured by a temperature inversion or a high pressure system reaches higher levels, but both of these conditions involve very still air which inhibits transport. There are very few ozone monitors in other states near the Four Corners area. Since the AQB doesn't have monitors east of the Bloomfield monitor or west of the Substation monitor, we aren't sure whether ozone concentrations in the Four Corners area are due to transport. However, in order for ozone transport to be a significant factor, there would have to be a potential source of Nitrogen Oxides and VOCs in one of the upwind states.
Is the NMED/AQB going to make some recommendations about what voluntary measures should be considered?
The dispersion modeling analysis will tell us what measures could help to lower ozone concentrations. Of course, it is likely that reductions in NOx and VOC emissions in San Juan County will be beneficial.
What did we do in Sunland Park to bring the area back into attainment?
The ozone nonattainment area in Sunland Park was caused by transport of air pollution from other areas, so there weren't many reductions that had to be made in Sunland Park. However, new and modifying industrial sources of air pollution in Sunland Park that emit VOCs in large amounts must use the Lowest Achievable Emission Rate control technology and offset new emissions by retiring old emissions.
What are "normal" levels of ozone around the state?
We tend to look more at "highs" since they indicate problems that might require our attention. One of the highest 8-hr ozone averages we have measured (0.101 ppm in 1999) was at the Santa Teresa border crossing in Dona Ana County. That clearly seemed to be a case of the transport of air pollution from another area. The fourth highest 8-hr average at that site was 0.078 ppm in 1999. Southern Dona Ana County seems to have the highest readings in the state. In 1999, Rio Rancho, north of Albuquerque, had 0.087 ppm for its first highest 8-hour ozone average and 0.076 ppm for its fourth highest 8-hour average. We don't calculate "lows" or "averages" as a matter of course, but normal 8-hour average lows in New Mexico are in the range of 0.010 to 0.020 ppm and normal 8-hour averages are around 0.034 ppm.
Does the Bureau monitor to the west of Substation for ozone?
No. We cannot locate state ambient air quality monitors significantly further west of our Substation monitor because we have no jurisdiction on tribal lands.
What about lean-burn engines? Do they reduce VOCs as well as NOx? Are the VOCs emitted in the combustion process or are there fugitive emissions emitted as well?
This is a multi-part question. VOCs are produced by any internal combustion engine. The words "lean-burn" are typically used to describe industrial engines and compressors, but some of the same technologies are also applied to newer automobile engines. Industrial engines can burn diesel, gasoline, or natural gas fuel. Leaks in the fuel tank or the line leading to the engine can produce fugitive VOCs. Lean-burn engines are designed with some special features that should reduce both NOx and VOCs. A higher air to fuel ratio ensures that there is sufficient oxygen to fully combust the fuel. Head and ignition design controls how the fuel-air mixture is burned. Lean design engines are designed to run cooler, which reduces the amount of thermal NOx that is produced. {If pushed to the extreme this technology may result in a compromise. As VOC and NOx emissions are reduced to the absolute minimum, emissions of Carbon Monoxide (CO) may increase. CO does not contribute significantly to the formation of ozone, but it is an EPA regulated pollutant.} Automobiles: A more efficient engine (i.e., more miles per gallon) produces fewer emissions for each mile driven. Most new vehicles have fuel injection to ensure that fuel is completely vaporized and thoroughly mixed with air. The computer chip in an electronic ignition precisely controls the combustion process, igniting the fuel/air mixture at just the right time to ensure complete combustion. Newer auto engines use slightly more air relative to the fuel, to make sure that there is sufficient oxygen to combusted all of the fuel. Some states require fuel additives (like alcohol or MTBE) that contain additional oxygen. These fuels are required in Nonattainment areas. Other technologies include catalytic converters and exhaust gas recombustion. All of these technologies should ensure that the exhaust VOCs are minimal. However, despite all of these technologies, poor compression from worn or cracked rings, a clogged catalytic converter and/or PVC valve can greatly increase the emissions from a vehicle.
How costly is phase I vapor recovery at gas stations?
There are different kinds of gasoline pump modifications. The passive rubber cup type deflects wind to reduce vapor emission. Deflectors are relatively inexpensive. Vacuum recovery systems look like an accordian tube around the nozzle. These are more expensive, and as might be expected, they are also more effective.
Is the AQB considering vapor recovery for gasoline?
At this time we haven't determined what sources of air pollution are responsible for the elevated ozone concentrations. If gasoline vapor emissions were identified as a significant contributor to ozone formation, controls could be imposed in two increments. Stage I requires fuel tankers to use vapor recovery when unloading at a gas station. Stage II refers to the rubber sleeve on the gas pump nozzles that traps vapors when a car tank is being filled. Both are intended to reduce VOC emissions.
What would the AQB consider to remedy fugitive leaks?
The EPA definition of "fugitive emissions" is something that could not conceivably go up a smokestack. The fugitive emission category would include leaks, but fugitive emissions are only part of the VOC problem. The Air Quality Bureau regulates large sources by issuing permits that limit how much they can emit. In addition, there are many unregulated emission sources (e.g. irrigation pumps or wellhead compressors) that are individually too small to require permits. The large sources with permits show up on our emissions inventory; smaller sources that fall below the permit threshold do not. It is possible that the cumulative effect of many small, unregulated sources is as large as the big regulated sources. Before the Air Quality Bureau looked at controls for part of the problem we'd want to be sure that our actions would result in significant reductions. Since we don't know about the quantities emitted by smaller sources, the first step is to complete a detailed inventory that shows how unregulated emissions contribute to the overall picture. Examples of things that should be examined for VOC emissions include drilling sites, wellhead compressors, wellhead glycol dehydrators, flash tank emissions, and line pigging.
Do refineries and gas plants have leaks that go unattended? Wouldn't that be losing product?
They may have some "product" leakage but depending upon the amount, the cost to recover can be more than the loss of product. In addition to product loss, unattended leaks would constitute a serious safety risk. Leaks are not necessarily in liquid form: vapor leaks may be more common. As stated during the public meeting, refineries and gas processing plants are permitted. They are inspected frequently, most have systems that continuously monitor operational parameters, and they are, in general, very well run. A plant like this can yield 50 - 90% fewer leaks than an unregulated plant. Unpermitted areas of oil and gas production receive far less scrutiny, for example oil and gas wellhead activity, initial treatment and storage of oil and gas products and the associated waste streams. Storage tanks can be emitting VOCs as a result of high outside temperatures that evaporate the volatile liquids stored during unloading. Many field storage tanks vent directly to the atmosphere and are not controlled. While these sources are individually smaller than refineries, there are lots of them in San Juan County. No conclusions have been made about these operations except that the cumulative VOC emission rates could be significant.
Bernalillo requires oxygenated fuels in the summer-would oxygenated fuels help in Farmington?
Oxygenated fuels would reduce some automobile VOC emissions. However, the AQB hasn't determined if the reductions would be significant in reducing Ozone levels in San Juan County. This is another question that will be answered after further technical analysis. For more information on the Bernalillo County program check: http://www.cabq.gov/aircare/oxyfuels.html
What about an inspection & maintenance program?
An I & M program is not required at this time by the state, the county or any of the municipalities in San Juan County. As in the previous question, an I&M program would reduce some emissions which is not a bad thing to do. But based on the (relatively) low population of San Juan County, I&M might not contribute significantly to ozone reduction. The director of Albuquerque's I&M Program is Glen Denis (505) 764-1110, if anyone would like to ask him additional questions.
Given that so much of the emissions are from the power plants, how can their emissions be reduced? Are the SJGS and APS plants using the best control technologies?
The two plants are not major contributors to the County's total VOC emissions, but they are large sources of NOx. Both plants use low-NOx technology, which is not necessarily state-of-the-art, but is better control technology than used at other power plants in the West. Both plants emit amounts of NOx that meet the state regulatory limit. Obstacles to requiring better control technology include high installation/operation cost and the AQB's lack of authority to impose additional control requirements. Lower emissions at these power plants would likely come from improved combustion technology, rather than add-on devices.
This seems like a difficult problem to solve-if the power plants are using good technology and leaks are being minimized, what can be done? What is the difference between doing it voluntarily or being forced to do it later?
The Air Quality Bureau hopes that further technical analysis will reveal which sources need to be controlled. Under EPA's ozone flex program, areas that are near the ozone standard get more credit for voluntary reductions made before the area becomes "Nonattainment". Nonattainment status has all kinds of negative implications and requires years of controls and monitoring. Nonattainment also means new and modified industrial sources must adhere to a federal permitting program that requires state-of-the-art control technology that can be very costly, and the net result may be reduced economic development in San Juan County.
Since the state keeps a good inventory, has anyone looked at whether the inventory increased between 2000 and 2001? What about the differences in met data in the two years?
The inventory for 2001 is being completed now, but it is expected that there was an increase in emissions from 2000 to 2001. The fact that recorded Ozone levels dropped slightly in 2001 is probably explained by differences in meteorological conditions during the two years. The year 2000 had a few more stagnant, high-pressure events in the summer than 2001 did.
Is there a cycle to this? Do the emissions affect the weather?
There is a correlation between the summer high-pressure pattern and high ozone concentrations. We don't see any evidence that emissions in San Juan County are affecting the weather, but paving and development do tend to raise the average outdoor temperature of an area very slightly.
How about information exchange with the state of Utah?
The AQB has discussed the elevated ozone issue with the state of Utah. They have indicated that their monitors show relatively high 8-hour average concentrations in some areas of southern Utah, also.
Is there any data on incidence of asthma in the 4-corners area?
The AQB is working with the Department of Health to get this data.
What can citizens do to get data on the health effects of breathing ozone?
The EPA has established a web site that shows air quality animations (including Ozone) every day on an hourly basis. We have just developed the process to allow maps to include New Mexico data. You can see what is happening "qualitative" sense (Good, Moderate, Unhealthy for Sensitive Groups, Unhealthy, and Very Unhealthy.) To see the site go to {http://www.airnow.gov/} From the pick list below the map, select "all states," which is the last item on the list. Select "Yesterday's Ozone," then click "See the Map." On some days, Northern Arizona shows an Ozone bloom over the Grand Canyon which may result from vehicle traffic driving to the canyon. Emissions from the Mojave Power plant just over the California border may also play a role.
Do local governments have authority to implement voluntary or mandatory programs? What have local governments done in other areas?
Local governments can implement various programs that may improve air quality; however, the state receives funding to regulate air pollution throughout the state except for Bernalillo County and tribal areas. In Texas, local governments of cities where air quality is degrading have been active in assisting the state in developing plans to clean up the air.
All monitoring stations are in elevated locations, but 90% of the community lives in the valleys. What differences are there between elevated areas and the valleys in measured ozone?
We believe that there is not much difference between the ozone measured in elevated areas and the ozone measured in valleys in the Farmington area. Ozone is a regional pollutant and doesn't vary much locally. The monitors at Substation and Bloomfield have similar readings on a daily basis, despite being located miles apart.
How can Farmington get more monitors?
The need for additional monitors would first have to be evaluated. Since ozone is a regional pollutant and our monitors are reading similar values, even though they are approximately 30 miles apart, the concentrations within the area between these sites are probably similar. This assumption is based on our experience with ozone monitoring at other locations.
Can the AQB monitor near the Navajo nation?
AQB used to have a site called "Reservation" that was located on the Navajo Reservation, approximately 1 mile NNW of the APS Four Corners power plant and 5 miles SW of the PNM San Juan power plant, where it measured SO2 and NO2 concentrations. That site was shut down in 1994 because of vandalism and because tribal authorities took over responsibility for that area. A monitoring site outside of Shiprock, which measured SO2 and PM10, was closed in 1998. When they were in operation, these sites did not show very high values of the pollutants they were measuring.
What are the strategies that will be effective in the Farmington community given the emissions that are in this area?
The AQB hopes to answer this question with further technical analyses. This answer is starting to sound redundant, but it would be wrong to identify a solution when we haven't gathered enough information or fully assessed the problem.
How are the National Ambient Air Quality Standards (NAAQS) set?
The standards are set and reviewed periodically by EPA with the assistance of many highly qualified scientists and physicians on the basis of health-studies completed throughout the country. The standards are designed to protect the health of the most susceptible portion of the US population: children, the elderly and those with a compromised immune system.
How does the San Juan Basin topography contribute to the high ozone levels?
Topography is more significant in relation to local concentrations from a nearby source of air pollution. For example, smoke from a chimney located below a bluff may not be dispersed well because the bluff deflects the wind. This terrain effect may lead to increased local concentrations of NOx or VOC; however, both would have to be in the same place at the same time to form ozone. Topography is significant in San Juan County because the relatively high elevation of the county reduces the partial pressure of atmospheric gases and increases automobile emissions. Elevation and thin air also allow more ultraviolet light from the sun to reach the ground. Ultraviolet light leads to ozone formation.
What health information is out there about air pollution and asthma attacks/emergency room admissions? Can we correlate the monitor data with the emergency room admissions?
The AQB will work with the Department of Health to see if this is possible.
Leaks and flares in the field-can they contribute to the ozone concentrations? What can industry do to fix leaks?
A properly operated flare is not likely to contribute to ozone formation. Flares burn hydrocarbons and VOCs, producing carbon dioxide and water vapor in the process. Pipeline leaks are possible contributors of hydrocarbons (primarily methane). VOC leakage could only occur from the limited pipeline network that carries liquid condensates. These include heavier hydrocarbon such as ethane, propane, and butane, toxic volatiles like Benzene Toluene, Ethylbenzene, or Xylene (referred to by the industry as BTEX), and aldehydes. Pipeline leaks are the responsibility of the Department of Transportation (DOT) which regulates pipeline safety. It would be surprising if either the industry or DOT would tolerate leaks of the magnitude that would be necessary to create the ongoing ozone problem.
Who gets information about leaks and fugitive emissions?
Leaks and spills from oil pipelines must be reported to the Oil Conservation Division of the Department of Energy, Minerals, and Natural Resources. The database containing these spills is available on that department's Website at http://www.emnrd.state.nm.us/ocd/.
What are the non-permitted sources? What are the non-permitted industrial sources?
Any source that produces less than 10 tons per year of any individual pollutant or less than 25 tons per year of all pollutants combined, does not require an Air Quality permit. Permitting sources doesn't necessarily mean that emissions are reduced, controlled or minimized. It only means that the source has a permit with federally enforceable conditions requiring it to comply with all applicable state and federal regulations. Some sources need no controls to meet these requirements. Sources of air pollution that typically don't require air quality permits include automobiles, home fireplaces and lawn mowers. Industrial sources that typically don't require air quality permits include small boilers, heaters and some wellhead compressor engines.
What about an industry workgroup to work on this?
The New Mexico Oil and Gas Association (NMOGA) has established a workgroup to look into this issue.
Is the number of oil and gas facilities a problem? Why do we continue to expand and permit these sources?
The San Juan Basin is one of the largest gas reserves in the world and the demand for natural gas in the US is very high. The exploitation of coal seam gas in the mid 1980's resulted in an explosion of gas field production and processing operations in a relatively small area around Farmington. The coal seam gas is quite clean except for CO2 and water. It contains very little hydrogen sulfide and doesn't require expensive removal processes. The CO2 (approximately 12%) does need to be removed. While the large number of oil and gas related facilities is part of the problem, there are other contributing factors that must also be considered. Oil and Gas drilling and production is licensed and regulated at the state level, not by a local authority. As long as an individual permit application complies with state and federal regulations, there are no grounds to refuse it. The AQB also determines that the cumulative impacts of all permitted sources in the area meet federal and state standards. State statute requires the AQB to issue a permit if all state and federal requirements are met. There is no provision in state or federal regulations for caution when an area's air quality is below, but near, the state or federal standard.
Will the county/city have to implement controls for automobiles?
It is feasible that the county or city could implement such a program, but it would not be required by the state unless the area is declared nonattainment.
Is industry willing to work on this issue?
Bruce Gantner (Burlington Resources) has informed the AQB that a NMOGA workgroup has been formed to look at this issue. According to Bruce, industry is anxious to look at measures that they can take to help remedy the problem. Contact: www.nmoga.org or Deborah Seligman.
What needs to happen next?
The AQB would like to form a workgroup to discuss the path forward with the city, county, industry and citizens. It is important that any such group include representatives from all interested parties.
Who monitors for mercury?
The Air Quality Bureau would implement monitoring requirements for a power plant if the emission of Mercury into the air were more than 10 tons per year, or, if in combination with other hazardous air pollutants, the total exceeded 25 tons per year. Since neither of the power plants in San Juan County approaches these levels, there are no requirements for Mercury emissions for either plant. Mercury levels in water are the responsibility of the Environment Departments Surface Water Quality Bureau. Their advisory notice on fish in New Mexico rivers is linked from the following web page: http://www.nmenv.state/swqb/ssstop.html. The warning is based on water sampling done in 1996 which essentially found no detectible levels of Mercury in the San Juan River. However, recognizing that Mercury accumulates as it goes up through the food chain, they issued a conservative warning against eating large quantities of fish, particularly for children and pregnant women. For more information on the survey and how to interpret the results, you may contact Mr. Scott Hopkins of the Surface Water Bureau at (505) 827-2820. The Surface Water Quality Bureau is currently studying the Total Maximum Daily Load (TMDL) of the San Juan River. Results should be available in 2004, but this study is not planned to include Mercury.
Who buys our power?
Preliminary Answer: The destination of power generated in New Mexico is difficult to trace. Unlike a migratory bird, we can't "band" an electron and see where it goes. Once electrons are placed into the national grid they merge with other electrons and flow in every direction. This past year has also revealed that power ownership changes many times between the point of generation and the point of use. A question that could be more easily answered would be: "What percentage of the power produced in New Mexico is exported?" Production data could be gathered from the relatively small number of New Mexico producers. A close estimate of domestic use could be computed from New Mexico Utility companies. The difference between the two numbers would approximate power exports, although there are also some transmission losses within the state.
How can NM get more recycling programs?
Recycling programs are established at the county level. The NMED Solid Waste Bureau can provide information and contacts for a recycling program but decisions and organization are a local responsibility. The NMED promotes recycling as an important step in reducing pollution. However, there are some important factors that should be considered. A recycling program essentially diverts a waste stream, converting it to a supply stream of raw materials. Since profit margins are low, recycling works most efficiently when the supply and demand are located nearby. The Four Corners area needs businesses or industries that could utilize the recycled material. Businesses are dependant on a continuous supply stream. Trouble will develop quickly if the supply is undependable or smaller than anticipated. A business may have to be sized to the minimum reliable waste stream rather than the average or maximum. Businesses also need customers. Is there an adequate local market for the product made from recycled material or will it have to be shipped? If either the recycled material or the recycled product have to be hauled somewhere else, the shipping cost could make the recycling program uneconomical. A final failure mode would be lack of participation or intermittent participation on the part of the community. The best way to ensure a successful recycling program is to get a lot of people involved and committed, and to carefully study the supply and demand factors. What kind of waste could be recycled? How much of each type will be available on a continuous basis? What business or industry could use it? If it has to be hauled away, what are the closest points of use and how much will the shipping cost?
How long has it been since PNM SJGS has been upgraded?
Nancy Norem of PNM reported that San Juan Generating Station recently spent $80 million to upgrade the pollution controls around 1998. This was for a sulfur control system on the Well-Mann Lord acid gas plant. PNM replaced that plant with a lime scrubbing process that is efficient and less expensive to operate and maintain. PNM uses electrostatic precipitators for particulate control which is arguably the best technology around. To our knowledge, no recent upgrades have been made to the power production units. PNM has to meet more stringent NOX emission rates than APS because it is a newer power plant. Most changes to APS have been control retrofits which are sometimes less reliable than controls designed into initial construction. Since the APS Four Corners power plant is regulated by Navajo EPA and EPA Region 9, we don't know dates or dollar amounts. EPA Region 9 has been developing a regulation for this plant for the last few years. It is not yet finalized.
Can the NMED and Dept. of Health coordinate and communicate the data to the public jointly?
The AQB has contacted the Department of Health and hopes to collaborate with them to have another public meeting in Farmington this summer to discuss the relationship between air quality data and public health data in San Juan County.
Can the Dept. of Health come talk about health issues in San Juan County?
We hope to have a meeting this summer in San Juan County with representatives of the Dept. of Health present.
Can we get the results of the CDC study?
The CDC activity turns out not to have been an official study, but rather a 30-day project assigned to a temporary intern. It did not look into health effects in San Juan County. Since a formal CDC report will not be issued, data on respiratory ailments should be gathered from local hospitals and health clinics and compared and assessed against data from similar regions. We have discussed this possibility with the Health Department. They would like to support this activity and are seeking funding.
How can we get public information from the NMED?
You can see much of the public information about San Juan County on our website at http://www.nmenv.state/aqb/. If this information does not answer your questions, call Mary Uhl, Bureau Chief, (505) 476-4301. We will continue to update the website with information.
How can we communicate better?
The AQB believes that the community working group will open up many communications avenues. We will support and participate in this effort; however, it is YOUR community and all communications need not be passed through us. Concerned groups and individuals in the area should make an effort to learn about the Ozone issue. Share what you learn with others, and discuss ideas among yourselves. Don't be afraid to express your opinion, but learn to listen carefully and learn from others so you can understand all perspectives. The more people who are actively involved, the better chance you will have of finding a good solution.
How high do the concentrations have to be before we do something about this?
While this might have been a frustrated rhetorical question, there is a serious answer. Legally, nothing forces action at either the state or local level until the 3-year average of fourth highest 8-hour average reading for each year exceeds the EPA limit of 0.084 ppm. This may not happen immediately. Another way to look at the issue though, is that if the area is declared nonattainment for Ozone it will take a minimum of 10 years to get back into attainment. This fact strongly suggests that preventive action would be the wisest course.
What is the address of the local office?
The New Mexico Environment Department Field Office is located at 3400 Messina Drive, Farmington, New Mexico 87402. You can call (505) 566-9746. Air Quality questions should be addressed to Mark Jones.
How can you get information about other communities that have done voluntary programs?
Two communities, Austin, TX and Corpus Christi, TX, have developed plans to reduce ozone levels voluntarily under an EPA program called Ozone-Flex. The ozone reduction plan for Corpus Christi is still in draft form and is not available at this time. A word of caution: neither of these plans is likely to be directly applicable to the situation in San Juan County. They will give examples of how a plan is organized, but the measures taken in large urban areas will not address the very different situation in Northwestern New Mexico.
What about natural sources? Could some of the VOCs come from natural sources of gas?
Some VOCs could be migrating from coal, gas, and oil producing formations via improperly finished wells or natural fractures. If anyone has information about the location of such "seeps", we would like to know about it. However, these would have to be very large in order to significantly contribute to the formation of ozone. Trees and plants are also biogenic sources of VOCs. For instance, the "Blue Ridge Mountains" in Appalachia are named after the haze that results from the decay of massive amounts of vegetation on the forest floor. In a dry area like ours, however, limited water produces MUCH less vegetation and decay is very slow, so biogenic emissions from vegetation probably don't significantly contribute to ozone formation in San Juan County.
Does NMED have money/budget to add monitors in the area?
We operate within relatively fixed budgets. The initial cost of a monitor is approximately $40,000. It costs more each year to operate, maintain and calibrate a monitor. There does not seem to be strong indication that another monitor would accomplish anything since the two existing monitors yield similar results, and Ozone is a regional pollutant, rather than a localized effect. We are also constrained by geopolitical boundaries. We can't monitor in another state or on tribal land. The Substation monitor is about as far West as we can go.
Can Health Dept. and ED put out a quarterly report/newsletter on ozone and health effects and progress being made on the problem?
This seems like a good idea. The AQB will ask the Health Department if they would like to collaborate on such a project. Also there is background information on health and what you can do on the website mentioned above: http://www.airnow.gov.
Will ED meet with Bloomfield and Aztec city councils?
The Environment Department has met with the mayors of Bloomfield and Aztec, has spoken to the Farmington City Council, and has communicated with the County Manager, and several of the County commissioners.
Can NMED facilitate the creation of the task force proposed by Ralph Gruebel (Director of the Environmental Protection Division)?
Yes-AQB can coordinate participation of other state agencies. Industry can bring regulatory and technical expertise. The AQB can also participate by providing scientific expertise.
What needs to be done?
The Air Quality Bureau needs to refine the inventory data of vehicles, oil and gas facilities, and other sources of air pollution. We need to complete a modeling analysis based on the inventory and other factors that have been mentioned. Coordination with the Health Dept. has been strongly encouraged by many at the meeting and we will follow up on that.
How can the community start to clean up the area?
See EPA website www.epa.gov/airnow. It has a section called "What can you do?" It talks about getting information, addressing air pollution in your home, making healthy choices, and more. You can also organize to pressure local and state officials to identify sources, quantify emissions, and implement regulations to require reductions.
What is the trend in the pollutant data over the years?
We have started collecting ozone data in San Juan County relatively recently, in 1997 at the Substation site and in 2000 at the Bloomfield site. The 10 highest hourly ozone concentrations have ranged between 0.096 ppm and 0.070 ppm, not necessarily showing a definitive upward trend. The year with the highest concentrations was 2000.
Where can one find information about renewable energy?
Nancy Norem reported that PNM has looked into this, in conjunction with Energy, Minerals, and Natural Resources. A joint venture with a second company will produce wind power at a site in Eastern New Mexico, which will be purchased by PNM.
Was there any correlation with the recent high levels and the forest and range fires of the last few summers?
There is a correlation between the days with elevated Ozone levels and stationary high-pressure systems. There don't appear to have been any large forest or range fires in the Four Corners area that occurred on the dates that elevated ozone was measured. The heat generated by a forest fire can volatilize (evaporate) many organic compounds from vegetation, but this typically occurs just as the material bursts into flame and the VOCs are burned up.
Why do the power plants, refineries and compressor units only have to report a flare or emission problem instead of stopping the problem?
Permits are issued for normal or steady state operations. It has long been recognized that large start-up, shutdown, or a major change in operating conditions will not produce the same emissions. This is similar to starting your car on a cold winter morning, or accelerating rapidly from a slow speed. Our regulations, reflecting EPA's, permit the steady-state operations and require the facility to notify us when they have an off-normal situation. Under no circumstances, however, can the federal standards be exceeded without an area being declared Nonattainment. Sources of air pollution can be issued a notice of violation (and fines) if the AQB determines that a problem results in an exceedance of federal ambient air quality standards.
What are the two power plants emitting annually? And how much are they emitting? (i.e. mercury)
Mercury is a hazardous air pollutant (HAP). A major source, according to EPA, is one that releases more than 10 tons per year of any individual HAP, or 25 tons per year in total HAP emissions. Power plants as a category are recognized as the largest source of Mercury emissions; however, Mercury releases alone from any individual plant are unlikely to trigger EPA's definition of a "major source." As a point of comparison, the largest electrical utility in the state of Wisconsin produces only 0.63 tons of mercury per year. Concentrations in the fatty tissue of fish can be higher than in bodies of water, because mercury tends to accumulate and get more concentrated as it goes up the food chain. The EPA and a number of states have issued general warnings about eating fish; however, at this point there is no data indicating high Mercury levels in the San Juan River. The Environment Department Surface Water Quality Bureau is conducting a broad spectrum study of the San Juan River in 2002 and 2003. Results should be available in 2004, but this study is not planned to include Mercury. The EPA has two very good websites with a lot of information on Mercury. They are: http://www.epa.gov/mercury/ http://www.epa.gov/ttn/atw/combust/utiltox/utoxpg.html. The EPA has announced to Congress, its intention to promulgate a new category of regulation, known as maximum achievable control technology (MACT standards) for "major source" in any listed source category. While power plants do not currently meet the definition of major Mercury sources, EPA may reduce the threshold at which a facility would be defined as a major source. It is too early to tell the extent to which MACT standards will influence mercury release levels.
If the community and industry work together and reduce VOCs, what assurances do we have that the power plants won't buy dirtier plants caps with President Bush's plans for "cleaner air"?
The details and specific requirements of President Bush's Clear Skies Initiative have yet to be determined, but at this point it doesn't appear that there will be a nationwide trading program for VOCs. There is a proposal for a western trading program for NOx, though. The Clear Skies Initiative requires congressional approval, so there is opportunity to contact your congressional representatives regarding the initiative.
Is there a correlation between the 4-corners population growth and the surge in VOCs?
Probably not, although we will examine this carefully in our inventory. San Juan County's population grew from 91,605 in 1990 to 113,801 in 2000: an increase of 24%. It is more likely however, that the increase in VOCs is due to the exploitation of large natural gas reserves in the San Juan Basin, because the gas is in demand outside of the basin. The same principle is at work with Nitrogen Oxides. The power plants are located near the coal, while the power demand is elsewhere.