Bringing Fugitives To Justice In Wyoming

Source: Scott Dalton for The New York Times

When it comes to healthy air, what you can’t see can hurt you.

Leaks of volatile organic compounds (VOC) and methane, the primary components in natural gas, may be invisible – but that doesn’t mean they are harmless.  These leaks – called “fugitive” emissions – can create serious air quality problems when VOC’s are involved. Meanwhile, methane leaks mean less product available for sale and a wasted resource.

But, while you can’t always see leaks with the naked eye, you can use modern technology to help you detect and fix them.  Cameras that use infrared technology to “see” leaking hydrocarbons and inexpensive hand held sensors that measure leaks are commonly used to help operators find and fix leaking equipment.  Leak Detection and Repair (LDAR) programs that require operators to check for leaks frequently using these modern technologies, and expeditiously repair them, can produce huge air quality benefits.  Such programs are currently required in permits for a number of operators in Wyoming’s Jonah Pinedale Anticline Development Area.

Wyoming regulators are working on a proposal to expand this requirement by mandating LDAR programs across the Upper Green River Basin, where ozone pollution fails to meet federal health-based standards.  The Wyoming program, which was presented to the state’s Air Quality Advisory Board last week, is an excellent start. This program, with one important modification, will help the state improve the air quality and health of local residents and start to catch more “fugitives” – which are the second biggest source of VOC emissions in the UGRB and projected to be the largest source of VOC emissions in Southwestern Wyoming by 2015.

Admittedly, this may seem like an arcane, acronym-laden issue – but the concept is simple: ensuring operators use the best, modern technology available to find and fix leaks in their equipment.  These leaks both pollute the air we breathe and waste their product. In fact, strong LDAR programs may be the best, most cost-effective way to get these leaks fixed and pollution reduced.  And that is why other states should pay attention to what Wyoming is doing.

While there is more that could be done, Wyoming’s willingness to step up and build consensus around reasonable efforts to cut down on harmful air pollution from oil and gas operations exhibits true leadership on an important issue.  The state’s proposal will require operators to inspect all new and modified facilities with more than four tons per year of fugitive VOC emissions in the nonattainment area on at least a quarterly basis.  Once located, these leaks will have to be fixed.

These proposed LDAR requirements improve on existing state standards in a few key ways:

  • The four ton per year threshold is twice as protective as the currently imposed standard of eight.
  • The proposal doubles the frequency of inspections for facilities that do not have storage vessels (where inspections are currently required on a semiannual basis they will be quarterly in this proposal).
  • The LDAR requirement applies across the Upper Green River Basin Nonattainment Area, not just in the smaller Jonah Pinedale Anticline Development Area, as is currently the practice.  A statewide rule would be better, but a strong program in the nonattainment area is certainly a big step in the right direction.

We give high praise to Wyoming for these aspects of its proposal.  However, all of these improvements could be severely undermined if the state allows operators to identify leaks using nothing more than the human eye, ear or nose — the so called Audio Visual Olfactory (AVO) method.  The fact is, the human senses are simply not as finely-tuned and cannot catch as many leaks as today’s off-the-shelf technologies.

If we only rely on what we can see, hear or smell, huge leaks could slip through the cracks and huge quantities of harmful VOC’s and methane will pollute the air unchecked.  Today’s technology can do this job of detecting harmful substances better, so why not use it?  Allowing AVO is a loophole that can and should be fixed as this proposal moves forward.

It is good news then that Wyoming air regulators indicated at the public meeting last week that they “won’t exclusively accept AVO,” and that it would only be allowed in conjunction with other, more reliable detection methods.  We will continue to work with state regulators on this issue ensure that this important clarification is captured in the final guidance document.

Cost-effective LDAR technologies, utilizing reliable, technologically-precise detection methods, will help reduce emissions, clean up unhealthy air, and – given that methane is also what the natural gas industry sells – help gas producers’ bottom lines as well.

Kudos to the Cowboy State for leading on an issue that, once clarified, will again show that clean air and the oil and gas industry can coexist.


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