Energy Exchange

A Red Flag On Disclosure Of Hydraulic Fracturing Chemicals

By Scott Anderson / Published: December 12, 2012

It’s not often that a new regulatory idea becomes so popular that one or more states per month climb on the bandwagon. But that is precisely what has happened with the push to disclose which chemicals are pumped into the ground to stimulate oil and natural gas production during the process known as hydraulic fracturing, or “fracking.”

A year ago, only three states (Arkansas, Montana and Wyoming) required oil and gas producers to tell the public what chemicals they were using. Two other states (Colorado and Texas) were actively developing such rules. Today, just twelve months later, statutes or regulations mandating “frack” chemical disclosure are on the books in no fewer than 18 states, and proposals are pending or under consideration in several others.

FracFocus, an online registry that compiles information on hydraulic fracturing chemicals both for states where disclosure is voluntary and required, has been up and running for just 20 months, but already it houses approximately 800,000 records that include ingredients data. As of December 5, 2012, this data represented 33,606 wells. The amount of information on the site continues to grow rapidly.

It is impressive that so much information has been made available in such a short time. Still, people have begun to wonder whether the disclosure rules are accomplishing what was intended. The question is important because rules that aren’t working need to be changed. A good regulatory system is based on a process of continual improvement, not a naive idea that the rulebook can be written in a way that will never need changing.

Unfortunately, judging from early press reports, there are quite a few bugs in the system. To be fair, the reporting requirements are quite new and still being implemented — and analysis of the data has barely begun. But problems are emerging. The issue receiving the most media attention is the sheer number of trade secret claims. Read More »

Also posted in General, Texas / Read 5 Responses

More To Come On Methane…

By Steven Hamburg / Published: December 6, 2012

Concerns around the impacts of methane emissions have reemerged in headlines, with the release of a methane leakage study about Boston. Published in the journal of Environmental Pollution a couple weeks ago, researchers from Boston University and Duke University measured atmospheric methane concentrations leaking from natural gas pipelines in Boston many of which are over a hundred years old. Another report issued last week by researchers at the Massachusetts Institute of Technology (published in Environmental Research Letters) looked at the impact of shale gas production on greenhouse gas emissions.

When talking about harmful greenhouse gases, carbon dioxide (CO2) usually gets most of the attention. Yet methane, the main ingredient in natural gas, is a short-lived greenhouse gas many times more potent than CO2 – or around 72 times more potent over a 20-year time frame. Stakes are high for the scientific community to fully understand the implications of methane leakage rates. These reports help elevate the issue that methane leakage matters to the climate and air quality, but this is only part of the story.

Methane is potentially leaking from the entire natural gas supply chain — from wells, pipelines and storage facilities — and no one knows precisely how much is leaking and where the leaks are stemming from. Some reports estimate the total methane leakage rate occurring during natural gas production, transmission and distribution to range anywhere from 1 to 7.9 percent. At the same time, the data that the Environmental Protection Agency (EPA) and everyone else rely on were collected 20 or more years ago.

A challenge for understanding the distribution of methane concentration data in Boston is that no one knows how to interpret the data yet. Maps of methane concentrations in the urban environment can be spurious. They may look scary, but are they? This and many other tough scientific questions still need to be answered, we are very early in the process of understanding how much methane is leaking and from where. The scientific community at large, including EDF and the authors of the Boston study, are committed to collecting the data necessary to addressing these concerns and to understanding the true climate impact of methane emissions.

EDF is working with leading academic researchers and industry leaders to conduct scientifically rigorous measurements of quantitative emissions across the natural gas supply chain from well to the end user. We are developing the methodologies where necessary to move past a ‘he said, she said’ conversation to one focused on data characterizing leak rates. The critical next step for us in using the increasingly robust data gathered from new innovative technologies is to precipitate a clear enough understanding of where the leaks are in the supply chain to catalyze a constructive conversation about what new policies and industry practices will be required to minimize methane leakage.

The first EDF fugitive methane report, focused on field measurements made at natural gas production sites, will be completed early next year under the leadership of the University of Texas Austin. EDF and our partners are using a diverse array of measurement techniques to characterize leak rates. We are also working to make basin-wide measurements within areas of natural gas production. Over the course of 2013 and early 2014, studies of emissions at other key components in the supply chain, including the local distribution system, will be completed and the data and conclusions released to the public.

EDF is actively campaigning to ensure that fugitive methane emissions from the natural gas industry are less than 1 percent of production in order to ensure that the climate benefits of natural gas are maximized. We see development of innovative, cost effective and accurate methane detection technologies and procedures as a necessary part of minimizing leak rates. Our view is that minimizing methane leakage is an important enough issue that we need to take the time to establish a scientific understanding of the underlying issues and by doing so defining effective well-targeted actions.

Also posted in Climate, Methane / Read 1 Response

Loose Use Of Facts Undermines Credibility Of White’s OpEd

By Jim Marston / Published: November 7, 2012

This commentary was originally posted on the EDF Texas Clean Air Matters Blog.

An erroneous and misleading opinion piece by Kathleen Hartnett White with the Texas Public Policy Foundation, ran in Sunday’s The Austin American-Statesman. In the article, White misrepresents several important details from a 4-year old EDF report that was prepared by Dr. Al Armendariz, a former Regional Administrator of the Environmental Protection Agency. The report catalogued emissions from oil and gas production in the Barnett Shale area. Her purported facts about the study findings are just plain wrong.

First, she claims that the report concluded that ozone precursor emissions from Barnett Shale production are twice as large as all mobile source emissions in the area. In fact, the report concluded that peak Barnett Shale emissions, while significant, were roughly comparable to emissions from cars and trucks (see press release accompanying the report).

White then claims that Dr. Armendariz’s study considered methane to be an ozone precursor, contrary to what is clearly stated in the report at p. 8. While it is true that methane does form ozone, albeit slowly, the report states “[m]ethane and ethane are specifically excluded from the definition of VOC” (volatile organic compounds). Thus, the report excluded methane from the comparison to mobile emissions of ozone precursors.

It is unclear if the author even read Dr. Armendariz’s work, which was not computer modeling, as she claims. Rather, it was an emissions “inventory,” a catalog of the air pollutant emissions from oil/gas sources in the Barnett Shale area, constructed using established engineering practices and industry-backed data sources. The core pieces of information for the inventory were oil/gas production data that are available for every county in Texas from databases at the Texas Railroad Commission. Dr. Armendariz’s resulting emissions estimates were in reasonable agreement with estimates issued by the Texas Commission on Environmental Quality later in 2009 (10-20% difference).

You can’t make a strong case when you get facts wrong. And, it is irresponsible for White to make her case by manipulating science, while cynically blaming government bodies of committing the same sin.

It’s time we all get the facts right and use science to expose truths, not veil our own agenda. For our part, EDF is working with leading academic researchers and industry leaders to conduct scientifically rigorous measurements of emissions from natural gas production. Leaks that occur during production (as well as distribution and use) stand to significantly undermine the potential of natural gas as a lower carbon energy source.

Also posted in Methane, Texas / Comments are closed

EDF Pushes Colorado For Full Adoption, Stronger Enforcement Of EPA Oil And Gas Rules

By Dan Grossman / Published: October 18, 2012

Ten of the nation’s 100 largest natural gas fields are located in Colorado. Three of the nation’s largest 100 oil fields are located here. Overall, Colorado is host to over 45,000 oil and gas wells.

And yet, the agency here in Colorado responsible for inspecting oil and gas wells for compliance with air quality regulations employs a mere eight inspectors. Yes, eight.

If we’re going to do it right in Colorado – developing energy resources in ways that protects communities, public health and the environment – the state is going to have to give agencies the resources they need to oversee industry operations. No one should be forced to sacrifice clean air and a healthy community, and regulators can’t do their job with one hand tied behind their back.

Oil and gas operations emit a variety of air pollutants, including pollutants that contribute to ground-level ozone or “smog,” toxic air pollutants, including known human carcinogens, and methane, a potent climate-disrupting pollutant.

In April, the Environmental Protection Agency adopted ground-breaking rules to reduce harmful pollution from oil and natural gas production. The New Source Performance Standards (NSPS) contain critical safeguards for human health and the environment that will help improve air quality in Colorado.

EDF applauded EPA’s adoption of the NSPS standards as an important first step to minimize the environmental impact of oil and gas production. And now our attention is turning to the states that are deciding whether to adopt and implement the new federal standards as their own or to cede enforcement to the EPA.

Despite Colorado’s past leadership in adopting clean air measures for the oil and gas sector, the state is now foregoing an opportunity to reduce harmful emissions from oil and gas operations through full adoption of the NSPS. The primary reason for the decision not to fully adopt the federal standards is the lack of state inspection and enforcement resources.

Today, the Air Quality Control Commission (AQCC) indefinitely delayed adoption of the new EPA clean air standards as they apply to certain aspects of gas well operations while additional information is gathered. Moreover, the Commission voted to adopt standards that apply to other facets of production (e.g., compressing stations) “only to the extent that they already trigger the combination of existing reporting and permitting requirements in Colorado.”

This “partial adoption” approach approved by the AQCC will (1) unduly delay the clean air benefits that the NSPS rules can bring to Colorado and (2) create a confusing and inefficient dual-agency enforcement regime that likely will fail to bring regulatory certainty.

The Colorado Air Pollution Control Division staff has indicated that the partial adoption approach is necessary given the sparse resources available for permitting, inspections and enforcement. This concern is valid. Even with new inspectors being brought on board, the Air Quality Control Division will only have eight employees to cover over 45,000 wells, for an astonishing inspector-to-well ratio of 1 to 5,625. However, punting to the EPA for enforcement is not likely to improve the resource issue given that Region 8 employs fewer than five full-time oil and gas air inspectors for the entire six-state region.

Today, EDF and our allies implored the AQCC to fully adopt the NSPS standards for oil and gas operations and called on the Hickenlooper administration and the legislature to give state agencies the resources they need so they can provide effective oversight of the industry.

Oil and gas activity continues to grow at a breakneck pace in Colorado, and it is imperative that we take quick action to make sure it’s being done right. Doing it right means not only putting strong standards in place, but also making sure our oversight agencies have the resources they need to ensure communities and our environment are protected.

To read the testimony we and our colleagues filed on this issue, click HERE.

Posted in Natural Gas / Tagged AQCC | Read 1 Response

Natural Gas: A Question Of Sustainability

By Elena Craft, PhD / Published: October 11, 2012

This commentary was originally posted on the EDF Texas Clean Air Matters Blog.

Today there are around 45,000 shale gas wells operating in the United States – triple the number in 2005 – and as a result, people are rightfully concerned about the extent of the shale boom’s potential damage to the environment.

The issue became the focal point of discussion this month in “Can Natural Gas Be Sustainable?,” a five-person panel presentation at the second annual SXSW Eco conference in Austin. As part of the panel, we discussed how stronger standards and employing best practices could minimize impacts of increased natural gas production in the wake of growing public concern about the health and environmental impacts of drilling.

Attendees of SXSW Eco represented a broad swath of perspectives, ranging from those who were against any natural gas development to those who wanted to see much more natural gas development. One attendee even criticized the title of the panel, presenting the position that developing any non-renewable resource is inherently not sustainable.

As for the sustainability question, one thing is clear: the natural gas industry has a lot of opportunity for improvement, and there is mounting public pressure to address environmental concerns. Nearly 61 percent of Americans have negative views about the oil and gas industry – higher than any other industry (David Blackmon, from FTI Consulting, actually joked that this was an improvement!)

As part of the discussion, I spoke about the many environmental and health impacts associated with natural gas development. Construction and drilling equipment can degrade local air quality with smog-forming pollutants and air toxics (Example: activities at the Barnett Shale in Texas). I also spoke about the implications of faulty well construction as one of the major causes of natural gas leakage, and emphasized that while natural gas is touted as a low-carbon fuel source, leaks from the production, distribution, and use of natural gas could undermine the greenhouse gas advantage combusted natural gas has over coal.

EDF is working hard to address the key problem areas associated with natural gas development: exposure to toxic chemicals and waste products; faulty well construction and design; climate impacts from methane leakage; local and regional air pollution; and land use and community impacts. Our team is engaging with community, government and industry stakeholders to help identify ways to minimize both human health and environmental risk, including:

Comprehensive disclosure of hydraulic fracturing chemicals
Modernization of rules for well construction and operation
Systems-based management of wastes and water
State and national standards for improving air quality and reducing climate impacts
Minimization of land use and community impacts from natural gas development

Fellow SXSW Panelists

Other speakers presented varying perspectives on natural gas issues. Chris Helman, Associate Editor of Forbes magazine, moderated the panel and emphasized the public interest on the topic, as well as the contribution of natural gas to the country’s energy portfolio.

George Peridas, a scientist from NRDC, prefaced his comments by saying, “We have a lot of work to do before we can call natural gas clean.” Peridas gave examples of numerous exemptions given the natural gas industry under the Safe Drinking Water Act, the Clean Water Act and the Clean Air Act. As well, those tasked with enforcing the state natural gas regulations that currently exist lack the ability to go out, fully inspect and enforce those standards. The result, he said, was that “industry is a self-policing entity right now.”

Much of his policy work focuses on climate change and correspondingly, Peridas said that natural gas could help with climate change and air quality when compared to coal. “The key is that gas needs to displace dirtier fuels,” he said. “A bridge is not the right frame of mind, and we cannot afford to treat gas as an abundant resource. We need to address its impacts now.”

Some of the solutions Peridas proposed included: designation of “off-limits” areas that provide fresh water resources or wildlife/conservation value; stopping those leaks that waste methane and contribute to greenhouse gas emissions; development of a comprehensive guide for how to drill safely (e.g., proper cement jobs at well sites); repealing the outrageous exemptions at the federal level that industry currently enjoys; focusing on measures and policies that promote solutions (e.g., solar energy); and ensuring that communities have a say in whether drilling proceeds in their areas.

Sister Elizabeth Riebschlaeger, a nun with Congregation Of The Sisters Of Charity Of The Incarnate Word, and community advocate for the Eagle Ford Shale, agreed strongly with co-panelist George Peridas and his push for more local regulations. She told the story of citizens in small, rural Texas towns being strongly impacted by the Eagle Ford shale, and even used the phrase “merciless exploitation” to describe her own such experience.

Sister Elizabeth asked the rhetorical question: “Are we counting our natural gas clean energy chickens before they hatch?” She then emphasized that society must consider all of the activities required to produce natural gas, including activities she has observed in the Eagle Ford Shale: trucks and heavy equipment; travel trailers for workers; transporting of sand and chemicals, fracking equipment, and toxic waste (produced during operations); construction of huge batteries and tanks; rigs operating 24 hours a day; loud compressor stations; damage to land requiring clean up; and more.

David Blackmon, managing director at FTI Consulting, represented industry’s point of view, which touts the “reality that over half of our electricity generating capacity is natural gas.” The demand for natural gas includes backing up intermittent supply from solar and wind power. He said that natural gas was one of the only power sources that could be “cycled up” in a matter of minutes and that coal made this process more expensive.

Blackmon said that the key to making natural gas sustainable was ensuring public trust; trust that it is being appropriately regulated at federal, state and local levels. “I absolutely agree that there are not enough inspectors in the Texas Railroad Commission to regulate it,” he said. “The good news is that most companies in the industry recognize the need for public trust and are working towards that.”

Also posted in Methane / Tagged fracking, Methane Leakage, Natural Gas | Read 2 Responses

New Study To Provide Important, Direct Measurement Data On Methane Emissions From Natural Gas Production

By Steven Hamburg / Published: October 10, 2012

While natural gas burns cleaner than other fossil fuels when combusted, methane leakage from the production, transportation, and use of natural gas has the potential to undermine some or all of those benefits, depending on the leakage rate. Methane is the main ingredient in natural gas and a greenhouse gas (GHG) pollutant many times more potent than carbon dioxide (CO2), the principal contributor to man-made climate change.

In other words, leaks during the production, distribution, and use of natural gas could undermine, and possibly even overwhelm, the greenhouse gas advantage combusted natural gas has over coal and spell major trouble for the climate.

Up to this point, direct measurement data on methane leakage rates has been limited and subject to wide interpretation and debate. Some studies have estimated the leak rate to be as high as 7.9%, while others have estimated the leak rate to be as low as 1% for some aspects of the drilling process. Methane leakage matters, and has clear implications on whether natural gas can be seen as a lower carbon energy source. To help overcome some of the debate, EDF is working with leading academic researchers and industry leaders from across the natural gas sector to take direct measurements of leak rates to help better define the natural gas leak rate across the natural gas supply chain in the United States.

In partnership with the EDF and nine leading natural gas producers, today the University of Texas Austin (UT) announced the first part of this study, focused on emissions from natural gas production. The study will help provide a clearer picture of methane leakage rates occurring at natural gas drilling sites around the country. It is particularly relevant because drilling and completion processes have evolved rapidly in recent years – thanks to breakthroughs in horizontal drilling and hydraulic fracturing – and the knowledge about the methane leaked during this shift has not.

The main objective of this study on production emissions is to obtain scientifically rigorous data from multiple gas producing basins. The study will focus on quantifying emissions from well completions, gas well liquid unloading and well workovers, in addition to other more routine well-site fugitive emissions, the areas of the production process with the greatest leak rate uncertainties

The study is unique in that it brings multiple, key stakeholders to the table to make measurements of emissions at the well pad that will be shared when completed. If natural gas is to become an accepted part of an energy independence strategy, while supporting a clean energy future, it is critical to work together to quantify, and where ever possible lower, the existing methane leakage rate. Such an approach could yield enormous added environmental and health benefits from existing and future natural gas infrastructure.

A research team led by UT, including engineering and environmental testing firms URS and Aerodyne Research, is conducting the extensive field study. Project partners include EDF, Anadarko Petroleum Corporation, BG Group plc, Chevron Inc., Encana Oil & Gas (USA) Inc., Pioneer Natural Resources Company, Shell, Southwestern Energy, Talisman Energy, USA, and XTO Energy, an ExxonMobil subsidiary.

For more information on ways to get sustained benefits from natural gas, EDF published a paper earlier this year titled, “Greater focus needed on methane leakage from natural gas infrastructure.” Find more at edf.org/methaneleakage.

Also posted in Methane / Read 3 Responses