OCTOBER ACTION
STRICTER LIMITS ON
OIL AND GAS METHANE
Summary: The oil and gas industry is the US's largest source of methane, which has a global warming potential (heat trapping ability) 87 times that of carbon dioxide. EPA's proposed rules leave out major sources of pollution, let drillers skip inspections, retain loopholes for polluters to avoid regulation, and don't monitor at the fence line or in the atmosphere, where emissions do the most harm to public health.
We applaud EPA action to limit methane and VOC emissions from their largest industrial source, the oil and gas industry. Climate change is already impacting America's health and over 15 million Americans live within 1 mile of an oil or gas well where exposure to VOCs and ozone may increase their risk of cancer, birth defects, brain damage, childhood asthma, cardiovascular disease, and premature death (McKenzie, 2014; 2012).
An opportunity we can't afford to squander. The short atmospheric life of methane means that rapid emissions reduction can slow global warming by as much as 0.5 degrees C before 2050 (Shindell, 2012). . The proposed regulations would decrease oil and gas methane emissions only 5% below current levels in 2025, when it is possible to achieve reductions of 40% which quickly pay for themselves in fuel savings (Harvey, 2012).
Proposed rules have 3 major weaknesses: failure to include all significant sources of emissions, inadequate inspections, and failure to monitor emissions leaving the site.
Suggested improvements:
Include all sources Even the best rules won't be effective unless they apply to all major pollution sources. Methane is not a local pollutant, its effect is regional and global. Facilities which are functionally connected, as well as those within a quarter mile, should be aggregated, regulated as major sources, and required to use the best available technology to limit release of harmful emissions.
Nearly two million existing active oil and gas wells are not covered by these rules and will produce 90% of the sector's methane emissions in 2018. We support the inclusion of existing sources in ozone non attainment areas but believe all wells should be regulated and all communities protected equally.
Venting during liquid unloading from gas wells is the third largest source of emissions from natural gas production, yet this was excluded from regulation. Plunger lifts can decrease emissions per unloading event 50- 99% (Allen, 2015). High efficiency flaring at the small subset of wells which unload very frequently would further reduce emissions by 93% (Heath, 2014; EDF, 2015). These measures should be mandatory.
Adequate inspection schedule The proposed inspection schedule of every 6 to 12 months is inadequate. Colorado, Wyoming, Pennsylvania, and Ohio all require quarterly inspections, which have been found to be cost effective for industry(ICF, 2014). Doubling and quadrupling the interval would double the amount of fugitive emissions. Inspections should be quarterly at minimum.
The bulk of emissions come from a very small subset of leaks (Heath, 2014) so reporting a low percentage of leaking components should not allow operators to skip inspections. This encourages non compliance. The EPA handbook on LDAR Best Practices states: “Experience has shown that poor monitoring rather than good performance has allowed facilities to take advantage of the less frequent monitoring provisions.” (EPA, 2007;EPA 1999).
Measure pollutants entering our communities and atmosphere
Research in several states has documented dangerous ambient levels of benzene, toluene, and formaldehyde in communities adjacent to oil and gas wells (Helmig, 2014; Macey, 2014). Fence line measurement of VOCs is necessary to verify compliance and safeguard public health.
Once all active oil and gas operations are regulated, regional inspection frequency should determined by top down methane measurements, creating a direct relationship between emissions and inspection frequency and providing a true incentive for compliance. Technologies for top down measurement by satellite and overflight sampling are well developed ( Miller, 2013; Karion, 2013; Caulton, 2014; Schneising, 2014) and federal participation is appropriate under the Land Based Natural Gas Extraction and Production National Enforcement Initiative due to the significant health and environmental threats involved. (EPA, 2014).
The proposed rules are a welcome start but without correcting the deficiencies noted above, they leave the public at unacceptable risk of harm from air pollution and climate related illnesses.
Full list of REFERENCES below beneath Quick Clicks
An opportunity we can't afford to squander. The short atmospheric life of methane means that rapid emissions reduction can slow global warming by as much as 0.5 degrees C before 2050 (Shindell, 2012). . The proposed regulations would decrease oil and gas methane emissions only 5% below current levels in 2025, when it is possible to achieve reductions of 40% which quickly pay for themselves in fuel savings (Harvey, 2012).
Proposed rules have 3 major weaknesses: failure to include all significant sources of emissions, inadequate inspections, and failure to monitor emissions leaving the site.
Suggested improvements:
Include all sources Even the best rules won't be effective unless they apply to all major pollution sources. Methane is not a local pollutant, its effect is regional and global. Facilities which are functionally connected, as well as those within a quarter mile, should be aggregated, regulated as major sources, and required to use the best available technology to limit release of harmful emissions.
Nearly two million existing active oil and gas wells are not covered by these rules and will produce 90% of the sector's methane emissions in 2018. We support the inclusion of existing sources in ozone non attainment areas but believe all wells should be regulated and all communities protected equally.
Venting during liquid unloading from gas wells is the third largest source of emissions from natural gas production, yet this was excluded from regulation. Plunger lifts can decrease emissions per unloading event 50- 99% (Allen, 2015). High efficiency flaring at the small subset of wells which unload very frequently would further reduce emissions by 93% (Heath, 2014; EDF, 2015). These measures should be mandatory.
Adequate inspection schedule The proposed inspection schedule of every 6 to 12 months is inadequate. Colorado, Wyoming, Pennsylvania, and Ohio all require quarterly inspections, which have been found to be cost effective for industry(ICF, 2014). Doubling and quadrupling the interval would double the amount of fugitive emissions. Inspections should be quarterly at minimum.
The bulk of emissions come from a very small subset of leaks (Heath, 2014) so reporting a low percentage of leaking components should not allow operators to skip inspections. This encourages non compliance. The EPA handbook on LDAR Best Practices states: “Experience has shown that poor monitoring rather than good performance has allowed facilities to take advantage of the less frequent monitoring provisions.” (EPA, 2007;EPA 1999).
Measure pollutants entering our communities and atmosphere
Research in several states has documented dangerous ambient levels of benzene, toluene, and formaldehyde in communities adjacent to oil and gas wells (Helmig, 2014; Macey, 2014). Fence line measurement of VOCs is necessary to verify compliance and safeguard public health.
Once all active oil and gas operations are regulated, regional inspection frequency should determined by top down methane measurements, creating a direct relationship between emissions and inspection frequency and providing a true incentive for compliance. Technologies for top down measurement by satellite and overflight sampling are well developed ( Miller, 2013; Karion, 2013; Caulton, 2014; Schneising, 2014) and federal participation is appropriate under the Land Based Natural Gas Extraction and Production National Enforcement Initiative due to the significant health and environmental threats involved. (EPA, 2014).
The proposed rules are a welcome start but without correcting the deficiencies noted above, they leave the public at unacceptable risk of harm from air pollution and climate related illnesses.
Full list of REFERENCES below beneath Quick Clicks
BE COUNTED with these QUICK CLICKS
Trans Pacific Partnership
Negotiations are done. All that remains is an up or down vote in Congress. The final document is still secret but as far as we know, state and national climate laws are not exempt from corporate lawsuits for loss of profit.
Trans Pacific Partnership
Negotiations are done. All that remains is an up or down vote in Congress. The final document is still secret but as far as we know, state and national climate laws are not exempt from corporate lawsuits for loss of profit.
REFERENCES
Allen, D. Methane Emissions from Process Equipment at Natural Gas Production Sites in the United States: Liquid Unloadings Environ. Sci. Technol., 2015, 49 (1), pp 641–648 DOI: 10.1021/es504016r
Caulton, D. R., et al. (2014),Toward a better understanding and quantification of methane emissions from shale gas development, Proc. Natl. Acad. Sci. U. S. A., 111(17),6237–6242, doi:10.1073/pnas.1316546111.
EDF, The Cost Effectiveness of Mitigating Liquids Unloading Emissions Using Flares. Document submitted to California Air Resources Board, April 2015 http://www.arb.ca.gov/cc/oil-gas/meetings/EDF_attachment_5-22-15.pdf
EPA, Clean Air Act Stationary Source Compliance Monitoring Strategy (CAA CMS). 2014 http://www2.epa.gov/sites/production/files/2013-09/documents/cmspolicy.pdf
EPA Office of Enforcement and Compliance Assurance, Leak Detection and Repair A Best Practices Guide, 2007 http://www2.epa.gov/sites/production/files/2014-02/documents/ldarguide.pdf
EPA Natural Gas STAR Program, http://www3.epa.gov/gasstar/accomplishments/index.html#three
EPA Enforcement Alert – Proper Monitoring Essential to Reducing ‘Fugitive Emissions’ Under Leak Detection and Repair Programs, EPA 300-N-99-014. US EPA Office of Enforcement and Compliance Assurance. Vol. 2, No. 9, Oct 1999.http://www2.epa.gov/sites/production/files/documents/emissions.pdf
Harvey, S. Leaking Profits: The U.S. Oil and Gas Industry Can Reduce Pollution, Conserve Resources, and Make Money by Preventing Methane Waste. NRDC Report March 2012, http://www.nrdc.org/energy/leaking-profits.asp
Heath, G. “U.S. Natural Gas System Methane Emissions: State of Knowledge from LCAs, Inventories, and Atmospheric Measurements.” Presentation at Colorado State University on April 7, 2014.
Helmig Highly Elevated Atmospheric Levels of Volatile Organic Compounds in the Uintah Basin, Utah Environ. Sci. Technol., 2014, 48 (9), pp 4707–4715 DOI: 10.1021/es405046r
ICF March 2014 Economic Analysis of Methane Emission Reduction Opportunities in the U.S. Onshore Oil and Natural Gas Industries, https://www.edf.org/energy/icf-methane-cost-curve-report
Karion, A. et al. (2013), Methane emissions estimate from airborne measurements over a western United States natural gas field, Geophys. Res. Lett., 40(16), 4393–4397, doi:10.1002/grl.50811.
Macey, G. Air concentrations of volatile compounds near oil and gas production: a community-based exploratory studyEnvironmental Health 2014, 13:82 doi:10.1186/1476-069X-13-82
McKenzie, L Birth Outcomes and Maternal Residential Proximity to Natural Gas Development in Rural ColoradoEnviron Health Perspect; DOI:10.1289/ehp.1306722 2014
McKenzie, L. Human health risk assessment of air emissions from development of unconventional natural gas resources, Science of the Total Environment 424 (2012) 79–87, 2012. http://www.ncbi.nlm.nih.gov/pubmed/22444058
Miller, S. M., et al. (2013),Anthropogenic emissions of methane in the United States, Proc. Natl. Acad. Sci. U. S. A., 110(50),20,018–20,022, doi:10.1073/pnas.1314392110.
Schneising, O. (2014), Remote sensing of fugitive methane emissions from oil and gas production in North American tight geologic formations. Earth's Future, 2: 548–558. doi:10.1002/2014EF000265
Shindell, D Simultaneously Mitigating Near-Term Climate Change and Improving Human Health and Food Security, 13 January 2012:Vol. 335 no. 6065 pp. 183-189 DOI: 10.1126/science.1210026
World Resources Institute, Bradbury J. CLEARING THE AIR: REDUCING UPSTREAM GREENHOUSE GAS EMISSIONS FROM U.S. NATURAL GAS SYSTEMS Working paper, World Resources Institute April 2013 http://www.wri.org/sites/default/files/clearing_the_air_full_version.pdf
Allen, D. Methane Emissions from Process Equipment at Natural Gas Production Sites in the United States: Liquid Unloadings Environ. Sci. Technol., 2015, 49 (1), pp 641–648 DOI: 10.1021/es504016r
Caulton, D. R., et al. (2014),Toward a better understanding and quantification of methane emissions from shale gas development, Proc. Natl. Acad. Sci. U. S. A., 111(17),6237–6242, doi:10.1073/pnas.1316546111.
EDF, The Cost Effectiveness of Mitigating Liquids Unloading Emissions Using Flares. Document submitted to California Air Resources Board, April 2015 http://www.arb.ca.gov/cc/oil-gas/meetings/EDF_attachment_5-22-15.pdf
EPA, Clean Air Act Stationary Source Compliance Monitoring Strategy (CAA CMS). 2014 http://www2.epa.gov/sites/production/files/2013-09/documents/cmspolicy.pdf
EPA Office of Enforcement and Compliance Assurance, Leak Detection and Repair A Best Practices Guide, 2007 http://www2.epa.gov/sites/production/files/2014-02/documents/ldarguide.pdf
EPA Natural Gas STAR Program, http://www3.epa.gov/gasstar/accomplishments/index.html#three
EPA Enforcement Alert – Proper Monitoring Essential to Reducing ‘Fugitive Emissions’ Under Leak Detection and Repair Programs, EPA 300-N-99-014. US EPA Office of Enforcement and Compliance Assurance. Vol. 2, No. 9, Oct 1999.http://www2.epa.gov/sites/production/files/documents/emissions.pdf
Harvey, S. Leaking Profits: The U.S. Oil and Gas Industry Can Reduce Pollution, Conserve Resources, and Make Money by Preventing Methane Waste. NRDC Report March 2012, http://www.nrdc.org/energy/leaking-profits.asp
Heath, G. “U.S. Natural Gas System Methane Emissions: State of Knowledge from LCAs, Inventories, and Atmospheric Measurements.” Presentation at Colorado State University on April 7, 2014.
Helmig Highly Elevated Atmospheric Levels of Volatile Organic Compounds in the Uintah Basin, Utah Environ. Sci. Technol., 2014, 48 (9), pp 4707–4715 DOI: 10.1021/es405046r
ICF March 2014 Economic Analysis of Methane Emission Reduction Opportunities in the U.S. Onshore Oil and Natural Gas Industries, https://www.edf.org/energy/icf-methane-cost-curve-report
Karion, A. et al. (2013), Methane emissions estimate from airborne measurements over a western United States natural gas field, Geophys. Res. Lett., 40(16), 4393–4397, doi:10.1002/grl.50811.
Macey, G. Air concentrations of volatile compounds near oil and gas production: a community-based exploratory studyEnvironmental Health 2014, 13:82 doi:10.1186/1476-069X-13-82
McKenzie, L Birth Outcomes and Maternal Residential Proximity to Natural Gas Development in Rural ColoradoEnviron Health Perspect; DOI:10.1289/ehp.1306722 2014
McKenzie, L. Human health risk assessment of air emissions from development of unconventional natural gas resources, Science of the Total Environment 424 (2012) 79–87, 2012. http://www.ncbi.nlm.nih.gov/pubmed/22444058
Miller, S. M., et al. (2013),Anthropogenic emissions of methane in the United States, Proc. Natl. Acad. Sci. U. S. A., 110(50),20,018–20,022, doi:10.1073/pnas.1314392110.
Schneising, O. (2014), Remote sensing of fugitive methane emissions from oil and gas production in North American tight geologic formations. Earth's Future, 2: 548–558. doi:10.1002/2014EF000265
Shindell, D Simultaneously Mitigating Near-Term Climate Change and Improving Human Health and Food Security, 13 January 2012:Vol. 335 no. 6065 pp. 183-189 DOI: 10.1126/science.1210026
World Resources Institute, Bradbury J. CLEARING THE AIR: REDUCING UPSTREAM GREENHOUSE GAS EMISSIONS FROM U.S. NATURAL GAS SYSTEMS Working paper, World Resources Institute April 2013 http://www.wri.org/sites/default/files/clearing_the_air_full_version.pdf
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