Abstract Many areas in the United States are not in attainment of the National Ambient Air Quality Standard for ozone, These areas include some with petroleum production operations, such as Kern County, California. In addition, major OCS development and production sources in the Western Gulf of Mexico are located offshore of the Houston and Beaumont/Port Arthur nonattainment areas. EPA requires that states implement a planning (SIP) process to develop strategies to achieve the federal ozone standard. These plans have the potential to result in significant control requirements for the production facilities. Potential impacts from different source types can be assessed through use of photochemical modeling of ozone precursor emissions (hydrocarbon and nitrogen oxides) from all anthropogenic (man made) sources. This modeling information can be used to:identify whether specific types of sources contribute to the ozone nonattainment problem, and
develop a set of control measures to reduce ambient ozone levels.
This paper will examine two photochemical modeling case studies which assessed the impact of petroleum productions sources in the Bakersfield and Houston nonattainment areas, The San Joaquin Valley SIP modeling showed that additional controls of NOx emissions from heaters, boilers and internal combustion engines located on the west side of the Valley were not necessary to meet the federal ozone standard by 1999. In the case of the assessment of OCS impacts on Houston, modeling showed that at times and locations where the federal ozone standard was exceeded, OCS contributions were minimal, This finding not only removes the probability of controls, but also greatly limits any probability of transfer of jurisdiction for OCS air quality from Minerals Management Service to EPA.
Recommendations on how to develop and implement a modeling assessment program will be presented to aid those who may be involved in similar planning processes in the future.
Introduction This paper will present two case studies in which decisions about the need for controls of air emissions from petroleum productions sources were based on air quality modeling. Unlike simple permit modeling, the assessments were made for multiple sources and used sophisticated photochemical models The paper will describe how air quality monitoring and modeling programs were implemented in a cooperative fashion with the appropriate regulatory agencies. This resulted in all parties having a vested interest in the success of the program. As important, it allowed all parties to accept the results of the assessment. In both cases, no new or additional controls were required, and the avoided costs to the petroleum industry were estimated at $ 50,000,000 and $ 100,000,000 respectively.
Background In 1990, the U. S. Congress passed the federal Clean Air Act Amendments (CAAA). Major changes were made with respect to requirements to attain the ozone National Ambient Air Quality Standards (NAAQS). This standard is set at 12 parts per hundred million (pphm), averaged over one hour, It is not be exceeded more than once annually, averaged over three years. Title I of the Act mandated that those states which contained areas not yet in attainment with the ozone NAAQS submit a State Implementation Plan (SIP) by November 1994. The SIP was required to demonstrate that the areas in question would attain the standard by the applicable deadline.
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