Problems with Flares

Flares are often used to control volatile organic compound (VOC) emissions from natural gas processing plants and other oil and gas facilities in the Denver area. The flares, which are nothing more than a giant flame, burn off the VOCs, which would otherwise react with sunlight to create ozone pollution.

Unfortunately, flares don't always work. The Colorado Air Pollution Control Division assumes flares automatically control VOC emissions below permitted limits. For example, the state often assumes flares will reduce VOC emissions by 95% or more. These assumptions are totally baseless.

Flares are susceptible to crosswinds and, if poorly operated and maintained, won't burn off VOCs like they're supposed to. An inefficient flare spews black smoke, whereas an effective flare has no visible emissions. The state never takes into consideration crosswinds or poor operation and maintenance, meaning that many flares often spew black smoke.

A study done in the Houston area, which has also suffered from ozone pollution, reported that actual VOC emissions from flares are way underestimated due to these factors. The study states:

"The Houston area’s very high ozone levels are heavily impacted by emissions from refinery and petrochemical plant flares. A significant factor contributing to this situation is Texas regulations for permitting and monitoring of flares that are based on inappropriate assumptions for combustion efficiency and are not adequately enforced."

Rocky Mountain Clean Air Action has questioned the state's flare efficiency assumptions in comments on permits for gas processing plants in the Denver area. The state always asserts their assumptions are valid. The problem is they have no monitoring data from any of these plants showing that flares always achieve the required VOC reductions.

Colorado's baseless flare efficiency assumptions likely means that VOC emissions are way underestimated, just like in the Houston area. The result is that VOCs from flares are yet another source of overlooked ozone pollution in the Denver metro area.

Highest Ozone Reading So Far and Elusive VOC Emissions

On June 19, the air monitor at Rocky Flats measured an 8-hour ozone reading of 94 parts per billion. This is the highest ozone level meausred in the Denver metro area so far this year. It's also 14 parts per billion higher than the level considered "safe" for people, which is 80 parts per billion. Here's the read out:

Pollutant	Conc.	Station	Hour	Date
O3	94	RFN	18	2006-06-19

An article today in the Rocky Mountain News also sheds more light on fugitive volatile organic compound, or VOC, emissions, which are released from leaky valves, tank hatches, and pipes at oil and gas facilities. A new technology that uses infrared imaging shows that many of these facilities are spewing out massive amounts of undetected VOCs. Of course, anyone with half a sense of smell who happens to be near one of these facilities could tell you this is the case. If it was water leaking from the pipes at some of these facilities, they'd be filling reservoirs. There's a link to a video showing a condensate tank bellowing out VOCs on the News' website, but I've been having trouble getting it to play. Let me know if you can't get it working, either.

Nice and Rainy

Today's a nice, somewhat rainy day in Denver and ozone levels are low. It's a welcome respite from the heat that we've been having, and a welcome reminder of how good rain feels. The rain even smells like it blew in from the mountains. Although I got a little wet riding my bike to work today, it was one of the most pleasant commutes I've had in the last week or so. A slight cold wind, wet weather, and clean air (at least, relatively clean); Denver can be a really beautiful place.

Ozone Violations

Yesterday there was another 8-hour ozone standard violation in Golden at the National Renewable Energy Laboratory monitor. The maximum 8-hour average was 81 parts per billion (the standard is 80). This is the second violation at the NREL this year, the last one was June 4 and also read 81.

These violations also come at the heels of two violations, both 81 parts per billion, that occurred at the Rocky Flats ozone monitor on May 25. You can query air data for from the state online.

Brown Cloud

Live Images of Downtown Denver's Sky

For those wondering what conditions are like in the Denver metro area, the Colorado Air Pollution Control Division has hourly live pictures of the downtown sky. While you can really see the brown cloud a little further out of the downtown area, these images are still striking. The images are also archived, so you can see what conditions were like at other times and on other days.

Deferral of Ozone Nonattainment Designation

For over two years now, the Environmental Protection Agency has deferred designating the Denver metro area as nonattainment for violating the 8-hour ozone ambient air quality standard. This deferral has so far been unquestioned and regarded as an acceptable decision. The reality is that nothing in the Clean Air Act allows the EPA to defer designating an area as nonattainment if it violates an ambient air quality standard.

But let me put this another way. All it will take this fall when the EPA decides whether to defer Denver's ozone nonattainment designation once again is one simple sentence to the EPA: This is illegal. This is all that needs to happen for the Early Action Compact to be thrown out and the Denver metro area given the nonattainment protection it needs. Another thing to keep in mind is that any citizen has the power to do this.

I'm amazed that more people don't realize just how thin of ice the state, industry, and local governments are skating on. I'm also amazed that, in light of this, the state, industry, and local governments aren't clamoring to do more to control ozone pollution for the health of Denver citizens.

Resistance to Clean Air?

The Colorado Department of Public Health and Environment held a meeting today to discuss their proposal to reduce ozone emissions from oil and gas drilling in the Denver metro area. The industry reps and attorneys at the meeting chided CDPHE's proposal.

In a chat today, Rocky Mountain News environmental reporter stated, "the initial reaction from oil and gas operators suggests they believe ramped up emission controls are unreasonable." Unreasonable? The industry points to other sources of emissions, like cars. I don’t know about others, but my finger pointing ended about the 5^th grade, when I learned to take responsibility for my actions and listen to others.

But let’s take a look at what’s at stake here:

*A 1999 study found that for every 38 part per billion increase in 8-hour ozone readings, there was a 21.8% increase in emergency room visits among the elderly (see, Defino, R.J. 1999. Emergency room visits for respiratory illnesses among the elderly in Montreal: association with low level ozone exposure. Environmental Research 76:67-77).

*A 2001 study reports that hospital admissions for asthma complications increased when the 8-hour ozone average increased by 9% and admissions for other respiratory disorders increased when the 8-hour ozone average increased by 2.3% (see, Petroeschevsky, A. 2001. Associations between outdoor air pollution and hospital admissions in Brisbane, Australia. Archives of Environmental Health 56:37-52).

*And finally, a 2005 study on the effects of ozone on infants reported that for every 19 part per billion increase in 8-hour ozone averages, the incidence of difficulty breathing among infants increased by 28%. Among infants of asthmatic mothers, the incidence of difficulty breathing increased by 55% for every 19 part per billion increase. This same study concluded, "At levels of ozone exposure near or below current U.S. EPA standards, infants are at increased risk of respiratory symptoms, particularly infants whose mothers have physician-diagnosed asthma." (see, Triche, E.W., J.F. Gent, T.R. Holford, K. Belanger, M.B. Bracken, W.S. Beckett, L. Naeher, J. McSharry, and B.P. Leaderer. 2005. Low-level ozone exposure and respiratory symptoms in infants. Environmental Health Perspectives 14:911-916)

Based on the 2005 study, every 19 parts per billion decrease in 8-hour ozone readings would decrease the incidence of difficulty breathing among infants with asthmatic mothers by 55%. The state's proposed oil and gas ozone controls predict average decreases of over 2 parts per billion, leading to a nearly 7% reduction in the incidence of difficulty breathing among infants with asthmatic mothers and a nearly 3%decrease among all infants. I’m sorry, but this is not unreasonable; and while these decreases may seem small, this is the least we should be doing for our children.

The oil and gas industry has some nerve fighting clean air controls for Denver citizens.

Booming Oil and Gas Drilling

Today's Rocky Mountain News pretty much sums up the problems we're facing in terms of booming oil and gas development and ozone pollution. Combined with several days in a row of above-average temperatures, it seems pretty likely Denver will once again violate ozone air quality standards. The oil and gas industry's refusal to agree to new and better pollution controls only underscores the need for more strict regulatory action to protect our health.

A nonattainment designation likely would have prevented all this from happening in the first place by imposing strict ozone control requiremnets. Fortunately, it's never too late to act for clean air and a nonattainment designation is better late than never.

Denver Ozone

Rocky Mountain Clean Air Action is happy to introduce the Denver Ozone blog. Have any thoughts about ozone air pollution in Denver (i.e., the brown cloud of smog), any thoughts about what's being done to control ozone, any thoughts on air pollution in general? Pass them on, along with your ideas and observations. Thanks--Jeremy and Obsidian.