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Curbing Methane Pollution from the Oil and Gas Sector: EPA "White Papers" Show It's Cost-Effective and Critical in Climate Change Fight

David Doniger

Posted June 18, 2014 in Curbing Pollution, Solving Global Warming, U.S. Law and Policy

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This post written by Meleah Geertsma.

NRDC and our partners submitted comments to EPA this week on the agency’s white papers investigating methane pollution from the oil and gas sector. EPA issued the white papers this April as the first step in the agency’s process for deciding how to cut the huge amounts of methane pollution coming from the oil and gas sector, a process announced in March by President Obama in his Climate Action Plan: Strategy to Reduce Methane. The oil and gas sector is the second largest industrial source of climate-changing pollution in the U.S., after power plants.  Reducing the sector’s heavy climate footprint is a critical component of meeting President Obama’s goal of reducing the nation’s overall climate-changing pollution 17 percent below 2005 levels by 2020. 

Our comments provide compelling reasons why strong methane-curbing standards are needed to protect the climate, authorized (indeed, required) by law, and technically feasible at reasonable cost (and in some cases profitable).  At the outset, our comments highlight the strong reasons for directly regulating oil and gas sector methane emissions under the Clean Air Act:

  • The Supreme Court has confirmed that Section 111 of the Clean Air Act authorizes EPA to set standards curbing emissions of climate-changing pollutants from new and existing industrial sources.
  • As mentioned, the oil and gas sector is the nation’s second largest industrial contributor climate-changing pollution, according to EPA’s current greenhouse gas inventory.  EPA’s inventory, however, understates the climate impact of the oil and gas sector for two reasons:  The inventory underestimates both the amount of methane emitted, and the heat-trapping potency of each ton that escapes. 
  • Directly regulating methane itself is necessary to effectively curb the overall emissions of this compound from the oil and gas sector.  Neither voluntary measures nor surrogate approaches (i.e., regulating ozone smog precursors or hazardous air pollutants) can achieve the same degree of emission control across the entire oil and gas sector.   

Our comments walk through the white papers, demonstrating that the data reviewed in the papers support the two points we’ve been making for years: (1) oil and gas methane emissions are huge, and (2) those emissions can be sharply reduced at reasonable cost – and often at a profit. Assessing the data presented in the white papers, and other data EPA should include going forward, we show the following:

  • Methane emissions from natural gas compressors can be cut by amounts equivalent to more than 15 million tons of carbon dioxide (CO2e) per year, primarily by controlling emissions from existing compressors.  Controls on pneumatic devices present about the same reduction opportunity.
  • Leaks from components located throughout the system, from production to distribution, make an enormous contribution to total sector emissions.  Exceedingly low cost methods of detecting and controlling those leaks are available. Such leak detection and repair procedures are already required in Canada and some U.S. states.   
  • Oil wells often contain substantial amounts of methane (i.e., natural gas). Methane emissions need to be controlled during drilling and production from these oil wells. Control measures that are already required for natural gas wells (including “green completion” requirements and limits on flaring) need to apply to these “gassy” oil wells too. 
  • There are significant opportunities to reduce methane from liquids unloading (a process for clearing fluids from working gas wells), in particular from widespread use of “smart” automation.

Our comments conclude that the EPA white papers and other available data sources demonstrate that the cost of control measures is eminently reasonable.  In many cases the costs of these controls is negative – in other words, companies will save money by reducing their methane pollution because they retain more product that can then be reused or sold.

In sum, the EPA white papers leave no doubt that the path forward is clear:  it’s time for direct regulation of methane from new and existing sources throughout the oil and gas sector.  Now it’s on EPA to get the job done.

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Comments

Michael BerndtsonJun 19 2014 09:54 PM

How will EPA prepare ever encompassing regulations on fugitive methane emissions? Especially in this political environment. Besides, of course, making recommendations and good old fashion guilt tripping. I guess my question is, what regulations cover activities that traditionally haven't been all that regulated and aren't traditional industrial point sources? This may include oil and gas production and utility's underground gas storage. Here's some general sources off the top of my head.

1) wellhead flaring and venting
2) wellfield collection and processing
3) surface flux and abandoned well emissions pushed up from fracked horizontal well fields
4) midstream transmission (including compressor stations and pipelines)
5) Natural gas treatment: for utility sales or LNG
6) distribution after citygate sales
7) underground natural gas storage by utilities

This list spreads out over a bunch of industry sectors, falling under a myriad of regulations. And Obama only has about two years left.

Will EDF's work on fugitive emissions cover this?

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