Air Quality Bureau
Questions and Answers from November 6, 2002 Open House/Public Meeting in Farmington
Questions in response to the Task Force presentation
How were the task force meetings publicized? Who can attend?
The first task force meeting was publicized through email, press releases, and interested people being contacted directly by the task force facilitator. Anyone who is interested may attend.
Can people get information from past task force meetings?
Information from past task force meetings is posted on the following website: http://www.nmenv.state.nm.us/ozonetf/index.html
Questions in response to the New Mexico Department of Health (DOH) presentation
Are you planning on using asthma data for compilation of your report?
Yes, the New Mexico Department of Health plans to use available asthma data (such as hospital admissions, emergency room visits, and Behavioral Risk Factor Surveillance System data) when preparing a report about asthma and ozone in San Juan County.
Will your report include data from all hospital visits or just those that are respiratory- related?
The DOH report will include only visits for select chronic respiratory illnesses (such as asthma, emphysema, and chronic bronchitis). However, DOH is considering using the total number of hospital visits for purposes of determining the percentage of visits that are due to these chronic respiratory illnesses.
Can schools be involved in your study? The schools all maintain student absence data - nurses report absences. Superintendents should be contacted to arrange for reports to be made available to the Department of Health.
Schools could be involved in the DOH study if the data are adequate for determining asthma-related absences. DOH will first contact superintendents to determine if the data are adequate. It is DOH's understanding that there are monthly meetings of the superintendents in the Farmington area. DOH representatives will attend at least one of these meetings if it is an appropriate way for us to learn more about available school absentee data.
You mentioned that you would look at data from San Juan Regional Hospital; will you also look at data from Shiprock and/or Durango? Many people have a choice of hospitals.
Yes, DOH will use data that are available from the Northern Navajo Medical Center in Shiprock and the hospital in Durango, as well as the data from San Juan Regional Medical Center in Farmington.
How many other areas of the state are collecting similar data (asthma, hospital admissions) and can we compare our data to data from those areas? Is this type of data being collected in Carlsbad, Silver City, and other parts of the state?
The DOH is conducting asthma surveillance throughout New Mexico and the results for San Juan County can be compared to other regions of the State.
Many asthma and other admissions are made to 24-hour clinics; are you planning to include data from these facilities? What about other doctors and clinics not directly related to the regional hospital?
The DOH recognizes the importance of 24-hour clinics in asthma care and will look into the accessibility of these data for its analysis and report. It is not feasible for DOH to survey the patient records in the office of each doctor and clinic, so it is unlikely that these will be included in the study. However, some of these data will be included as they are available to DOH through the Children's Chronic Disease Registry.
Questions in response to the New Mexico Environment Department (NMED) Air Quality presentation
A power plant facility near Page, AZ installed scrubbers. Can we find data from near that facility?
We will work with Arizona Department of Environmental Quality to see if there are any monitors nearby.
Why does Grand Canyon have elevated levels; is it transported from another area like California?
We don't know why ozone is elevated in the Grand Canyon area, but one possibility is transport from other areas, such as California. We hope to be able to answer these questions through a proposed analysis of regional ozone in the west.
Why were there no air quality alerts for children playing outdoors during the fire around Durango last summer?
Air quality alerts for Durango would be issued by the Colorado Department of Public Health and Environment.
What effects did the fires have on ozone readings this year?
The effects of wildfires are not known yet. NMED will need to consider the effects of large wildfires when we do the emissions inventory and modeling. Wildfires can produce large amounts of ozone precursors. We also need to keep in mind that the same "heat wave" weather that is good for big wildfires is also optimum for ozone formation.
People have had to change their behavior during bad-air days, why can't pollution-creators change their behavior like the people do?
Many industrial sources of air pollution operate 24 hours a day, 365 days per year. This continuous operation is often necessary for the economic viability of a business. Industrial sources, in many cases, apply air pollution controls to minimize the emissions of air pollutants year-round.
How is the Environment Department dealing with the Bureau of Land Management Environmental Impact Statement? Does the Environment Department have legal authority to override the BLM EIS?
The NM Environment Department is working closely with the BLM to ensure that the EIS addresses whether the proposed development will comply with all state and federal ambient air quality standards and regulations. The EIS is currently being revised and we will review and comment on the revision. As the EIS details possible environmental consequences and is not an air quality permit application, the ED will not "approve" or "deny" the EIS. However, many of the proposed facilities will require air quality permits and state enforcement of those permits. The ED does have authority to deny air quality permit applications and enforce air quality permits.
Is the BLM involved in the San Juan ozone task force?
Yes.
Is it a 1:1 ratio with VOC and NOx to create ozone?
No, the chemistry of ozone formation is quite complicated and varies in different parts of the country.
In the evening in a clean area, what is the typical ppm reading? Are there minimum levels of ozone on earth? If so, what is the least ozone recorded, where is it and how do they do it?
In remote, unpolluted sites, hourly ozone concentrations are usually about 0.020-0.040 ppm, and there is usually not much difference between daytime and nighttime values. In urban areas with high daytime ozone levels, it's not uncommon for ozone values to fall to near zero at night. It is difficult to explain this without getting into a chemistry lesson, but a simplified way to describe it would be to say that the same "family" of combustion products (oxides of nitrogen) that produces ozone in sunlight also consumes ozone in darkness.
Can you speak to the significance of distance from a monitor; how far from the monitors do the elevated levels of ozone stretch?
This is another data gap in our information, there are not many ozone monitors in the region. We do know that monitored ozone is at somewhat lower levels on the Southern Ute land to the north of San Juan County. We also know that levels of ozone are somewhat lower in Sandoval and Bernalillo Counties. However, we really don't know the eastern or western extent of the elevated ozone levels in San Juan County.
Do vehicle emissions include putting gas in the car?
There are emissions associated with putting gas into automobiles.
Do VOC emissions from oil and gas operations include all emissions or only permitted emissions?
Our NMED inventory of VOC emissions includes only permitted sources.
Can you give a list of the contributors to ozone in San Juan County and tell how they contribute?
This is another data gap and one that we hope to answer through our inventory and modeling analysis in the future.
Is ozone transported?
It can be.
Is there a permitting process for wellheads or compressors?
Yes, there is an air quality permitting process if emissions from these facilities exceed 10 tpy or 10 lb/hr of any regulated air pollutant.
What is the best technology to reduce the VOC at a wellhead?
In the first place, it depends upon the type of well: conventional (coproduction of oil and gas from the same borehole) or coal-bed methane (CBM), which is by far the most common in the San Juan County region but not in the rest of the state. With conventional production, it is important to know whether or not the gas is "sour" (contains hydrogen sulfide), in which case it is probably flared already. If a flare is burning, complete combustion will insure that both the hydrogen sulfide and VOCs are destroyed. If the gas is "sweet," it can probably be compressed and sent to a processing plant because conventional gas isn't usually as "wet" as gas produced from coal beds.
Now, limiting ourselves to the Four Corners Region and CBM: It depends upon whether or not the well has a dehydrator. If there is no dehydrator, then it is important to minimize leakage and emissions from "line-pigging." If there is a dehydrator, condenser units are an option. In Wyoming, the only state that imposes controls on wellhead dehydrators, condensers are preferred by industry. Condenser units work by evaporative cooling. Produced water from the well is separated by the dehydrator and evaporates easily into dry air. This in turn chills the gas stream, condensing the volatile material that is captured in a tank. Where well spacing and VOC quantities are high, a separate pipeline to gather VOCs may be justified. If not, VOCs can be trucked to a central gathering point. Tank venting may cause losses if the tanks overheat in the sun and/or are not emptied frequently enough.
Wyoming does not specify condensers, but includes them in its list of pre-approved BACT methods. Per the Wyoming regulation, BACT must remove 90% of VOCs and 95% of HAPs by weight. The Oil and Gas industry likes condensers because they are mechanically simple and don't require lots of electronic controls and instrumentation. One drawback is that the evaporative cooling ceases to work when temperatures fall below freezing. This should be somewhat less of a problem in New Mexico than in Wyoming.
Is the cost too prohibitive to require the oil and gas industry to have monitoring on their sites?
Continuous monitoring of air emissions is expensive, but many oil and gas facilities are required to have periodic monitoring.
Permitting for open burning - how does it work?
The state Open Burning regulation (20.2.60 NMAC) specifies which kinds of open burning are unrestricted, which are allowed without a permit but subject to restrictions set forth in the rule, and which require a permit. This rule does not apply to tribal lands. The Open Burning regulation is available on the New Mexico Records Center web site, and at the Environment Department's Field Offices. Applications for open burning permits can also be obtained from the Field Offices. Federal land managers must follow an approved smoke management plan to minimize the adverse effects of their prescribed burning on air quality. We are considering possible changes to the Open Burning regulation -- watch for news on this.
How can you compare Farmington to Albuquerque when Albuquerque has several times as many people?
The comparison tells us that even though Albuquerque likely has more auto emissions, Farmington somehow has more air pollution that causes ozone.
Does EPA mandate what happens on tribal land?
Yes.
How are we coordinating with tribal lands?
Tribal representatives are members of the Task Force and steering committee.
Who has jurisdiction over permitting and location of BLM's proposed gas wells?
The state's Oil Conservation Division permits locations. If emissions from a source are greater than 10 tons per year or 10 pounds per hour of a single pollutant, permitting by the Air Quality Bureau is required.
Can the Environment Department step in when the area goes nonattainment? What would be the effects of nonattainment? What has Albuquerque done to avoid nonattainment?
NMED must step in when an area goes nonattainment and implement a federal permitting program that requires offsets and the highest level of control technology for air pollution sources. Additionally, there must be an analysis and potentially control of air pollution from other sources of ozone precursors, like cars and trucks. Albuquerque hasn't necessarily made specific measures to avoid ozone nonattainment; however, some of the measures that were implemented to abate CO in Bernalillo county may also help to reduce ozone.
Do we have monitors on the power plant stacks?
Power plant emissions are monitored continuously at each stack, and reported to NMED and EPA quarterly.
To what degree are city governments involved in this process?
City governments are represented on the task force.
Recommendations and Next Steps
Those attending the meeting were asked what the state or AQB should do next in the ozone process; the responses were as follows:
- Schedule task force meetings to allow more public participation, such as after work hours. Keep task force meetings open to the public.
- Need more newspaper coverage to scare people into paying attention
- It would be good to know more about how the industry is participating and helping to solve the problem.
- Complaints made to the Environment Department about emissions should be reported in the newspaper.