Energy Exchange

Are Natural Gas Vehicles Good For Climate Change?

By Drew Nelson / Published: February 1, 2012

Source: Pike Research

Last week, in a speech in Las Vegas, President Obama called for getting more natural gas vehicles (NGVs) on the road in the United States. NGV proponents applauded the speech and immediately reiterated the conventional wisdom that because natural gas burns cleaner than gasoline or diesel, NGVs lead to reduced greenhouse gas emissions. However, recent science shows that the conventional wisdom may not be right.

While it is clear that the actual combustion of natural gas is cleaner than the combustion of gasoline or diesel, there are other emissions associated with the production, delivery and use of those fuels. Natural gas is essentially methane, a potent greenhouse gas. Over 2o years, a pound of methane is 72 times more potent than a pound of carbon dioxide. As natural gas is produced and piped across the country, there are plenty of opportunities for it to leak into the atmosphere. EPA estimates that leak rate to be somewhere between 2-3%, but the exact amount is the subject of much debate.

What we do know is that whatever the percentage of methane that is lost to the atmosphere, it erodes the climate benefits of combusting natural gas. In other words, the higher the leak rates the less the benefits. If leakage is high enough, NGVs can actually be worse for climate for some period of time. A newly published study concluded that over 20 years, NGVs were worse for the climate than gasoline or diesel vehicles unless current leak rates are reduced. With current leak rates, even after 100 years NGVs are no better for the climate than gasoline or diesel vehicles.

Because methane is more potent over shorter time frames, if we remove more methane now, we can reap quick benefits for the climate system. However, if we emit more methane now, it will have a greater negative impact on the climate system. This may be precisely the outcome we get if we aren’t careful in how we proceed with NGVs. Before large-scale policies encouraging NGVs are written into law, we should better understand the leak rate of methane from the natural gas supply and take actions to ensure it is low enough that putting more NGV on the road does not harm the climate. Understanding and reducing leak rates is critical to accepting NGVs as a legitimate GHG strategy. EDF is working to do this, but until we have better data and see an industry committed to reducing leaks, we will reserve judgment on whether the President’s call for accelerating NGVs is justified.

Posted in Natural Gas / Comments are closed

Improving New York’s Proposed Hydraulic Fracturing Regulations

By Mark Brownstein / Published: January 31, 2012

Around the country, states are taking a serious look at their regulations to manage shale gas development. New York has the potential to be a leader among these states. Environmental Defense Fund (EDF) believes that strong regulations and aggressive enforcement is critical to protecting public health and the environment from high-volume hydraulic fracturing and other hydrocarbon extraction activities in New York State. To that end, we have submitted detailed comments on the New York State Department of Environmental Conservation (NYSDEC)’s proposed rules and permitting conditions for hydraulic fracturing. The NYSDEC can put New York at the forefront of safe and clean shale gas development by implementing our suggestions in several critical areas:

1) Chemical Disclosure: Full public disclosure is rapidly becoming the industry norm across the country, but the proposed NYSDEC disclosure rules for chemicals used in the hydraulic fracturing process only covers chemicals with Material Safety Data Sheets (MSDS), thus failing to capture perhaps half or more of the chemicals used. This is especially problematic because MSDS only explore hazards in occupational settings and do not consider implications for public health or the environment. Further, the proposed rule only requires disclosure of additive products proposed to be used in hydraulic fracturing, as opposed to the chemicals actually used during the hydraulic fracturing process. EDF feels strongly that operators should disclose all hydraulic fracturing chemicals used on a well-by-well basis, posted on a searchable, publically accessible website.

2) Well Construction: Properly constructed, tested and maintained wells are critical to protecting New York’s precious groundwater and surface water aquifers from contamination by drilling fluid, wastewater and natural gas seepage. The proposed well construction regulations and permitting conditions need improvement to meet industry best practice standards. Furthermore, some of the proposed rules represent potential safety hazards for well pad workers. A model regulatory framework EDF, and others, are developing could be used to greatly improve NYDEC’s proposed well construction regulations.

3) GHG Emissions/Methane Leakage: EDF is a leading advocate of strict standards on limiting methane emissions from natural gas production. Methane is a pernicious greenhouse gas, many more times more powerful than carbon dioxide. To reduce the peak warming and improve air quality, it is critical to minimize the amount of methane vented or flared at the production site or leaked during storage and transmission. We strongly urge the NYSDEC to impose specific Green Completion and other emission-reducing requirements on operators, and to formulate hard emissions targets that provide incentives for operators to reduce methane leakage even further.

4) Wastewater: Hydraulic fracturing produces huge volumes of potentially toxic and radioactive wastewater. New York recognizes this problem but does not seriously address the lack of capacity for processing or safely storing hydraulic fracturing waste materials within the state. Current technology does not allow for safe, cost-effective purification of hydraulic fracturing wastewater at treatment centers for re-introduction into the water system, and should be banned. Insofar as it appears that the final disposition of the bulk of the wastewater produced in New York will be trucked out of state to deep injection wells, the proposed regulations and permitting conditions must grapple with this expensive and perhaps unsustainable practice. Finally, since wastewater recycling will likely be the dominant treatment option undertaken by shale gas operators in New York, this practice needs to be more thoughtfully and transparently regulated.

5) Phase-in: Even with the best rules on the books, it will take time to hire and train the necessary staff to implement and enforce the rules properly. New York is essentially building a regulatory program from scratch. EDF believes the NYSDEC should learn how to walk before it can run. Our suggestion is that New York phase in the regulatory program region by region. In this way, the state can be sure that the pace of drilling activity will not outpace its ability to adequately administer the regulations. So, too, this phase-in approach will allow the state to acquire valuable experience in step-wise fashion. The key is not doing it quickly, but doing it correctly.

These and other adjustments to the proposed rules and permitting conditions are necessary to protect public health and the environment in New York. Shale gas extraction can be made safe through strong regulations and aggressive enforcement to protect communities. EDF is committed to working with the NYSDEC on these issues to produce the most responsible hydraulic fracturing regulatory framework in the nation.

EDF’s full comments on New York’s hydraulic fracturing regulations are available here.

State Of The Union Address: A Mixed Bag On Natural Gas

By Mark Brownstein / Published: January 25, 2012

In President Obama’s State of the Union address last night, he laid out his plans for the expanded role that natural gas will play in the future. The President stated:

“We have a supply of natural gas that can last America nearly one hundred years, and my Administration will take every possible action to safely develop this energy. Experts believe this will support more than 600,000 jobs by the end of the decade. And I’m requiring all companies that drill for gas on public lands to disclose the chemicals they use.”

I am pleased to see a commitment to the full disclosure of hydraulic fracturing chemicals, but this is only the first step in getting the rules right for natural gas. As we discussed back in November, EDF President Fred Krupp sat on the Shale Gas Subcommittee of the Secretary of Energy Advisory Board (Subcommittee), which provided strong recommendations for strengthening environmental management in the shale gas industry and developing this abundant energy source in ways that safeguard public health and the environment.

I would have liked to have seen the President speak directly to implementing the Subcommittee’s recommendations, beginning with the Department of the Interior (DOI). Simply committing to the disclosure of hydraulic fracturing chemicals isn’t enough. The recommendations included strict requirements for everything from well construction and the reduction or elimination of methane venting to groundwater protection to methane leakage and emissions flares, among others. These recommendations are ready to be implemented, and DOI has an opportunity to demonstrate best practice in its leasing and oversight of unconventional natural gas development on federal lands.

The jury is out on whether states will embrace the Subcommittee’s recommendations and it will take a concerted effort on the part of organizations like EDF and concerned citizens to demand swift action to improve the quality and effectiveness of state regulations. Implementation of the Subcommittee’s recommendations at the state level is a good place to start and some states are beginning to take a lead role. For example, on the issue of disclosure, Colorado recently set the bar for requiring the full disclosure of all chemicals used in hydraulic fracturing by making this information available on a searchable database. On the other hand, states like New York have proposed weaker requirements, asking companies to disclose only half of the proposed additive products instead of the chemicals actually used in the hydraulic fracturing treatment. For these reasons, it is crucial that the DOI disclosure requirements set a leading example that will influence states to do better. The DOI should start with Colorado, but can do even better.

Last night, the President demonstrated his commitment to domestic energy production through natural gas development and said that “America will develop this resource without putting the health and safety of our citizens at risk.” The federal government and the states have a shared responsibility to ensure that our air, land and water are safe wherever hydraulically fractured wells are drilled.

Also posted in Washington, DC / Comments are closed

Colorado Sets The Bar On Hydraulic Fracturing Chemical Disclosure

By Matt Watson / Published: December 13, 2011

Big news out of Denver this morning.

Source: WLF

After weeks of intense wrangling between industry and environmental representatives, the Colorado Oil and Gas Conservation Commission (COGCC) adopted a hydraulic fracturing fluid chemical disclosure rule that, in many ways, serves as a model for the nation.

It’s been a learning process these last couple of years – as EDF has worked to get disclosure policies adopted in the states. With their own disclosure rules, Wyoming, Arkansas, Texas and Montana have all made important contributions to the debate. And in Colorado, we’re finally seeing things start to coalesce.

Colorado’s Rule 205A settles key questions about what kinds of information the public expects to see and how the information should be presented, including:

Requirements for Searchable Database

Picking up on a recommendation from the shale gas subcommittee of the U.S. Secretary of Energy Advisory Board (a panel on which EDF President Fred Krupp served), the Colorado rule requires chemical information to be made available on a website that allows people to search and sort data by company, chemical ingredient, geographic area and other criteria.

This is a big step that will allow land owners, neighbors, regulators and policymakers to focus and refine their questions and research about hydraulic fracturing.

We’re also fans of the fact that the rule requires operators to post their disclosures on Frac Focus, which must be made searchable by January 1, 2013. If Frac Focus doesn’t have these upgrades in place by then (or isn’t clearly on a path to do so), the rule requires the COGCC to build its own searchable database.

The creators of Frac Focus – the Ground Water Protection Council (GWPC) and the Interstate Oil and Gas Compact Commission (IOGCC) – are already talking about searchability, and the Colorado rule provides a clear signal that the states want to see it happen and happen soon.

(The Texas disclosure rule, which was also adopted today, uses Frac Focus as the disclosure platform, but doesn’t require searchability. In adopting the rule, the Texas Railroad Commission agreed that Frac Focus should be made searchable and said it would work with GWPC and IOGCC to make those upgrades).

Full Disclosure of Chemical Ingredients

Colorado also set a national standard by requiring disclosure of the identities and concentrations of all chemical ingredients, not just those that have been determined to be “hazardous” according to Occupational Safety and Health Administration (OSHA) regulations. Other states have taken the step of requiring disclosure of the identities of all chemicals, but Colorado is the first to require disclosure of both chemical identities and concentrations for all chemicals.

As readers of our blog posts on fracturing fluid disclosure know, just because a chemical hasn’t been identified as “hazardous” under OSHA Hazard Communication rules, it doesn’t necessarily mean the chemical isn’t dangerous. OSHA regulations require that chemicals be identified as hazardous when studies show they could be dangerous in a workplace setting. These regulations don’t look at the question of whether a chemical might be dangerous if exposure occurs through an environmental pathway. Moreover, a chemical might be dangerous in both a workplace setting and through environmental exposure – but if the studies haven’t been done yet, OSHA regulations don’t require you to list it as hazardous.

According to industry, at least half of the chemicals used in hydraulic fracturing fluids don’t fall under these OSHA Hazard Communication rules. And toxicological data on many, if not most, of these chemicals is very thin. So requiring full disclosure of hydraulic fracturing chemicals is a critical first step toward building up our understanding of the risks they may present.

The Colorado disclosure rule isn’t perfect, but it’s darn good. And with the provisions for searchability and full chemical disclosure, it has set a national standard on two key issues.

Posted in Natural Gas / Read 1 Response

Making Do Under TSCA: EPA To Require Reporting Of Health Data By Makers Of Chemicals Used In Hydraulic Fracturing

By EDF Blogs / Published: December 9, 2011

This commentary was originally posted by Richard Denison, Ph.D., Senior Scientist, on the EDF Chemicals & Nanomaterials Blog.

Last August, Earthjustice, Environmental Defense Fund (EDF) and over one hundred other groups recently filed a petition under the Toxic Substances Control Act (TSCA) calling on the Environmental Protection Agency (EPA) to require manufacturers and processors of chemicals used in oil and gas exploration and production (E&P chemicals) – including those used in hydraulic fracturing fluids – both to conduct testing and submit to EPA health and environmental data they already have on hand. The aim of the petition was to ensure EPA obtains better information on the identity, production, use and health/environmental effects of these chemicals in order to evaluate their health and environmental risks. Late last month, EPA announced its decision.

EPA Decision on the Petition

In November, EPA partially granted the petition. It granted the petitioners’ request that EPA develop rules requiring makers of chemicals used in hydraulic fracturing fluids to submit existing information to EPA identifying the chemicals, their intended uses, quantities produced and health or environmental exposure to or effects of the chemicals.

While this is a positive step forward, EPA denied two other aspects of our petition. EPA rejected the request to issue a rule requiring testing of these chemicals to fill data gaps because the agency lacks sufficient information to make the potential risk or high-exposure findings it is required to make under TSCA to justify a test rule. (The high evidentiary burden EPA must meet to require testing is of course a serious limitation of TSCA and a major reason why TSCA reform is so badly needed.) It also limited the scope of the reporting rules only to chemicals used in hydraulic fracturing, and did not include other E&P chemicals, such as those used in drilling muds, or fluids.

An Important Clarification

It is important to note that the actions called for under the TSCA petition are different from the disclosure efforts EDF and others have been pushing for on a state-by-state basis, in three respects. First, the reporting rules will apply to manufacturers and processors of the chemicals themselves, whereas the disclosure initiatives focus on oil and gas drillers to publically disclose chemicals they add to hydraulic fracturing fluid. Second, the EPA rules are intended to provide EPA with information sufficient to understand the potential risks of the subject chemicals at an aggregate, national level, whereas the disclosure initiatives are aimed at a local, even well-by-well scale. Third, the EPA rules encompass information beyond just the identity of the subject chemicals to include other information about their production, use and potential health/environmental effects. While much of the information reported to EPA under the rules can and should be made public, increasing disclosure per se is not the primary focus of our petition nor of the rules.

Next Steps

EPA’s decision is in sum welcome as an advancement of efforts to identify and reduce environmental and public health impacts from oil and gas exploration and production. EPA plans to solicit input on the design and scope of reporting requirements as well as the process by which information is “aggregated and disclosed to maximize transparency and public understanding.” Through these processes, EDF, Earthjustice and other petitioners can argue for EPA to make enhancements “to ensure that the health and environmental risks posed by E&P chemicals are fully understood,” as we stated in the TSCA petition.

Also posted in Washington, DC / Comments are closed

EPA’s Pavillion, WY Groundwater Contamination Study A Wake-Up Call

By Mark Brownstein / Published: December 8, 2011

Today’s release of a draft US Environmental Protection Agency study on groundwater contamination around natural gas wells in Pavillion, Wyoming, should be a wake-up call to anyone who thinks public anxiety about shale gas development is overblown and unjustified.

Based on the draft report, it seems pretty clear that hydraulic fracturing fluids, and other contaminants associated with natural gas production, found their way into Pavilion’s groundwater. And it is not hard to see why. The report reads like a primer on what NOT to do when developing unconventional gas. It’s all here: poor cement quality, cement not injected to the proper depth to isolate the well from the groundwater, fracturing activity taking place in close proximity to the water table (in itself a questionable practice, but in this case, particularly egregious given the lack of cap rock between the zone of fracture and the groundwater), soil contamination around waste water pits indicating spills at the surface that migrated to groundwater and lack of clarity about what went down the well because of incomplete disclosure of the chemicals used in the fracturing process.

This draft report is Exhibit A on why stronger regulation and enforcement is necessary if the general public is EVER going to believe that shale gas development is a safe source of natural gas. Indeed, the draft report says it best:

“Finally, this investigation supports recommendations made by the U.S. Department of Energy Panel (DOE 2011a, b) on the need for collection of baseline data, greater transparency on chemical composition of hydraulic fracturing fluids, and greater emphasis on well construction and integrity requirements and testing. As stated by the panel, implementation of these recommendations would decrease the likelihood of impact to ground water and increase public confidence in the technology.”

Having played a leading role in developing the DOE recommendations, we couldn’t agree more. As this draft report makes clear, the time for action to improve regulation and enforcement is now.

Posted in Natural Gas / Read 1 Response