Friday, November 11, 2022

EPA Unveils Proposed Methane Pollution Reduction Standards Covering Oil & Gas Facilities, Including Conventional Oil & Gas Wells

On November 11, at COP27 in Sharm el Sheikh, Egypt, the U.S. Environmental Protection Agency announced it is strengthening its
proposed standards to cut methane and other harmful air pollution. 

If finalized, these critical, commonsense standards will protect workers and communities, maintain and create high-quality, union-friendly jobs, and promote U.S. innovation and manufacturing of critical new technologies, all while delivering significant economic benefits through increased recovery of wasted gas.

The updates, which supplement proposed standards EPA released in November 2021, reflect input and feedback from a broad range of stakeholders and nearly half a million public comments. 

The updates would provide more comprehensive requirements to reduce climate and health-harming air pollution, including from hundreds of thousands of existing oil and gas sources nationwide. 

It would promote the use of innovative methane detection technologies and other cutting-edge solutions, many of which are being developed and deployed by small businesses providing good-paying jobs across the United States.

The new proposal also includes a ground-breaking “Super-Emitter Response Program” that would require operators to respond to credible third-party reports of high-volume methane leaks. 

The agency estimates that in 2030, the proposal would reduce methane from covered sources by 87 percent below 2005 levels.

“The United States is once again a global leader in confronting the climate crisis, and we must lead by example when it comes to tackling methane pollution – one of the biggest drivers of climate change. We’re listening to public feedback and strengthening our proposed oil and gas industry standards, which will enable innovative new technology to flourish while protecting people and the planet,” said EPA Administrator Michael S. Regan. “Our stronger standards will work hand in hand with the historic level of resources from the Inflation Reduction Act to protect our most vulnerable communities and to put us on a path to achieve President Biden’s ambitious climate goals.”

Oil and natural gas operations are the nation’s largest industrial source of methane. 

Methane is a potent greenhouse gas that traps about 80 times as much heat as carbon dioxide, on average, over the first 20 years after it reaches the atmosphere and is responsible for approximately one third of the warming from greenhouse gases occurring today. 

Sharp cuts in methane emissions are among the most critical actions the U.S. can take in the short term to slow the rate of climate change. 

Oil and natural gas operations are also significant sources of other health-harming air pollutants, including smog-forming volatile organic compounds (VOCs) and toxic air pollutants such as benzene.

The Clean Air Act standards in the supplemental proposal will complement President Biden’s Inflation Reduction Act, which provides resources for financial and technical assistance and a waste emissions charge for applicable oil and gas facilities that exceed statutorily specified waste emissions thresholds. 

The federal Inflation Reduction [Climate, Energy] Act incentivizes early implementation of innovative methane reduction technologies and supports methane mitigation and monitoring activities, allowing the United States to achieve greater methane emissions reductions more quickly.

Taking into account both the supplemental proposal and other measures in the November 2021 proposal, EPA projects that the proposed standards would reduce an estimated 36 million tons of methane emissions from 2023 to 2035, the equivalent of 810 million metric tons of carbon dioxide. 

That’s nearly the same as all greenhouse gases emitted from coal-fired electricity generation in the U.S. in 2020. 

EPA’s estimates also show the updated proposal would reduce VOC emissions by 9.7 million tons from 2023 to 2035, and air toxics emissions, including chemicals such as benzene and toluene, by 390,000 tons. 

These projections reflect new analysis of the costs and benefits of the proposed standards, which incorporates an improved modeling approach as well as updated estimates of the number of facilities covered by the supplemental proposal and the amount of methane and VOCs they emit.

The supplemental proposal reflects public input on the November proposal and new information and analyses, which helped the EPA determine comprehensive and cost-effective approaches to reduce pollution from oil and natural gas facilities. 

Key features of the supplemental proposal would:

-- Ensure that all well sites are routinely monitored for leaks at less cost, and until they are closed properly;

-- Provide industry flexibility to use innovative and cost-effective methane detection technologies, and a streamlined process for approving new detection methods as they become available;

-- Leverage data from remote sensing technology to quickly identify and fix large methane leaks;

-- Require that flares are properly operated to reduce emissions, and revise requirements for associated gas flaring;

-- Establish emission standards for dry seal compressors, which are currently unregulated;

-- Set a zero-emissions standard for pneumatic controllers and pneumatic pumps at affected facilities in all segments of the industry.

-- Increase recovery of natural gas that otherwise would go to waste – enough gas from 2023 to 2035 to heat an estimated 3.5 million homes for the winter.

Proposal includes super-emitter response program

The supplemental proposal would also establish a super-emitter response program that would leverage data from regulatory agencies or approved third parties with expertise in remote methane detection technology to quickly identify these large-scale emissions for prompt control. 

Studies show that large leaks from a small number of sources are responsible for as much as half of the methane emissions from the oil and natural gas industry, along with significant amounts of smog-forming VOCs. 

While many requirements of EPA’s combined proposals would reduce common sources of super emitters, EPA is proposing the response program to address super emitters’ significant pollution and impact on communities where they are located. 

To ensure that the super-emitter response program operates transparently, notices sent to oil and natural gas owners and operators, along with their response and any corrective actions, would be available on a website for easy access.

In addition to making EPA’s proposal more comprehensive, the supplemental proposal includes requirements for states to develop plans to limit methane emissions from hundreds of thousands of existing sources nationwide. 

EPA is proposing to require states to submit those plans within 18 months after the final rule is issued, and to establish compliance deadlines for existing sources that are no later than three years after the submission deadline. 

The supplemental proposal includes requirements for considering the communities most affected by and vulnerable to oil and gas emissions, along with a demonstration of meaningful community engagement as states develop their plans.

EPA estimates that the supplemental proposal will yield total net climate benefits valued at $34 to 36 billion from 2023 to 2035 (the equivalent of about $3.1 to $3.2 billion per year), after taking into account the costs of compliance and savings from recovered natural gas. 

The climate benefits are estimated using the social cost of greenhouse gases, a metric that represents the monetary value of avoided climate damages associated with a decrease in emissions of a greenhouse gas. 

While EPA’s estimates are based on the interim social cost of greenhouse gases recommended by an interagency working group in February 2021, EPA also is including a separate analysis that is based on updated social cost of greenhouse gases estimates that address recommendations of the National Academies of Science, Engineering, and Medicine. 

The additional analysis and accompanying EPA draft technical report will be available in the rulemaking docket for public comment. EPA is also seeking peer review of the report.

Public Comment

EPA will take comment on the supplemental proposal until February 13, 2023. The agency will host virtual trainings to provide communities, Tribes and small businesses information about the supplemental proposal and about participating in the public comment process. 

Those trainings will be November 17 and 30, 2022 and registration information is available on EPA’s website. 

EPA will hold a virtual public hearing January 10 and 11, 2023. Registration for the public hearing will open after the supplemental proposal is published in the Federal Register. 

EPA intends to issue a final rule in 2023.

Click Here for more information on the proposed methane rulemaking.

PA Finalizing Regulation

Pennsylvania is finalizing a two-part regulation setting volatile organic compound and methane emission standards from oil and gas facilities in response to previous EPA regulations covering both conventional and unconventional shale gas oil and gas facilities.

In Pennsylvania, conventional oil and gas facilities account for 80 percent of methane emissions from the oil and gas industry because they have done little or nothing to control them. 

The unconventional shale gas industry accounts for 20 percent because they have implemented some controls.  Read more here.

The final unconventional regulations were approved by the Independent Regulatory Review Commission on July 21.  Read more here.

The IRRC is scheduled to meet on November 17 on the final regulations covering conventional oil and gas facilities.  There were no comments submitted on this regulation to the IRRC.  Read more here.

Pennsylvania is faced with the loss of over $700 million in federal highway funds if these regulations are not finalized by December 16.

Reaction To New EPA Proposal

John Walliser, Senior Vice President at the PA Environmental Council, released this statement on EPA's draft methane rule--

The U.S. Environmental Protection Agency (EPA) has released a new regulatory proposal to substantially reduce oil and gas methane pollution. The new draft builds on, and considerably strengthens, the agency’s initial proposal released last November. 

Most importantly, the proposal includes new standards for low-producing (but still potentially highly polluting) wells, which are a significant source of emissions in Pennsylvania.

“Capturing methane emissions from oil and gas operations is a cornerstone to responsible energy security and development. We are gratified to see the EPA issue a proposed rule that seeks to further address activities that risk releasing this potent greenhouse gas to the atmosphere. 

“The draft rule takes meaningful strides toward regular inspections at small wells with leak-prone equipment, which are responsible for half of all methane emissions nationwide. Also critically important are provisions to retrofit oil and gas well sites with zero-emission equipment and new proposals to require inspections at abandoned wells until they are closed.” 

The U.S. oil and gas industry emits 16 million metric tons of methane annually, which has the same near-term climate impact as 350 coal-fired power plants. 

The latest peer-reviewed research finds that these wells – sometimes referred to as “marginal” wells – drive over 50% of all well site methane pollution nationwide, despite producing just 6% of the country’s oil and gas. 

The EPA proposal requires regular monitoring at all sites with failure-prone equipment, which are responsible for an estimated 63% of production site methane emissions.

These steps are critical for states like Pennsylvania which have a wide range of older to newer well sites and an undetermined level of emissions.

Taking into account both the supplemental proposal and other measures in the November 2021 proposal, EPA projects that the proposed standards would reduce an estimated 36 million tons of methane emissions from 2023 to 2035, the equivalent of 810 million metric tons of carbon dioxide. 

That’s nearly the same as all greenhouse gases emitted from coal-fired electricity generation in the U.S. in 2020.  

EPA’s estimates also show the updated proposal would reduce VOC emissions by 9.7 million tons from 2023 to 2035, and air toxics emissions, including chemicals such as benzene and toluene, by 390,000 tons.

A public comment period will be opening soon. EPA has already scheduled briefings to support public engagement. PEC will be submitting comments, which will be posted on our website once complete.

The York County-based Evangelical Environmental Network's President & CEO Rev. Mitch Hescox issued this statement on EPA's announcement--

What a momentous day for the health of God’s children – praise God! 

Today, the Environmental Protection Agency (EPA) released an updated rule to cut methane and other harmful pollutants from oil and gas operations across the U.S. 

The proposed standard would reduce 36 million tons of leaked methane, 9.7 million tons of Volatile Organic Compounds (VOC’s, smog-producing compounds), and 390,000 tons of hazardous air pollutants (HAP’s) such as cancer-causing benzene. 

These reductions will have a profound impact in defending our kids’ health and lives and will also significantly contribute to addressing the climate crisis.

We thank Administrator Regan and the EPA team for their long hours and persistent work in getting this new proposal out for public comment.

Together, with the more than 133,000 pro-life Christians who submitted comments to the EPA regarding the original proposed rule, we at the Evangelical Environmental Network recognize the life-threatening danger methane pollution poses to our children – both born and unborn – and the urgent need for strong protective action.

Every child is precious in the sight of God and deserves to be defended from the threat of poisons emitted from oil and gas production, distribution, and transportation. 

These include known cancer-causing toxics like benzene, VOCs that increase ozone levels, and methane. 

Methane is an over 80 times more potent greenhouse gas than CO2 in the first twenty years and a major contributor to global warming and climate-fueled extreme weather. 

Rising temperatures not only pose the threat of heat illness and death during heat waves, but also directly contribute to worsening ozone levels. 

The medical and scientific literature is clear – living within 0.5 miles of a methane extraction or production site harms our children, and newer research suggests that even those living further afield within a 5-mile radius may also be at risk.

New geospatial analysis released by Earthworks and FracTracker shows that more than 17.3 million people – including 3.9 million children under 18 – live within the half-mile health threat radius of active oil and gas production operations. 

Within my home state of Pennsylvania at least 310,896 kids face this hazard. 

This makes addressing fugitive and leaking methane from both existing and new oil/gas facilities a moral responsibility.

As pro-life evangelicals, we have a special concern for the unborn. We want children to be born healthy and unhindered by the ravages of pollution even before they take their first breath. 

The medical community has long known that unborn children are especially vulnerable to environmental impacts. 

Of these impacts, fossil fuels are the most serious threat to children’s health worldwide. 

The once-held belief that a pregnant mother gives chemical protection to her developing child is untrue. 

Studies have shown that smog, VOCs, soot, and air toxics have a disproportionate impact upon life in the womb. 

Research by Dr. Shaina L. Stacy and others at the University of Pittsburgh found close proximity to unconventional gas wells in Butler County, PA is associated with babies born with lower birthweight. 

Additionally, Dr. Lisa M. McKenzie with the Colorado School of Public Health published peer reviewed research that links birth defects to methane production. 

Research by Casey J.A., et al (2019) further describes that living within a half-mile radius of natural gas development leads to increased brain, spine, or spinal cord birth defects.

We are especially thankful that the new proposed standards are based on actual methane emissions instead of oil and gas production. 

Recent studies clearly prove that smaller leak-prone wells have disproportionately high emission rates of methane and associated gases.

 Under the new emission-based rule, these methane super-emitters will no longer slip through the cracks.

While the complete details are under our review, we are especially pleased that the proposal:

-- Ends the use of intentionally polluting equipment, including pneumatic controllers and pumps within 3 years of the rule’s finalization

-- Puts strict guidelines on flaring

-- Requires regular OGI (Optical Gas Inspections) on all wells except the simplest sites that still require AVO (Audio, Visual, Olfactory) inspections

-- Provides plans for approving the latest technology use in monitoring

-- Allows communities to be involved in monitoring Super Emitter Sites

-- Requires states to develop State Implementation Plans with 18 months of the final rule being published

For our children’s right for an abundant and healthy life, we applaud EPA efforts for this stronger rule.

PA Moms Clean Air Force applauds EPA action to reduce oil and gas methane emissions--

Today, President Biden and the Environmental Protection Agency (EPA) released an updated rule to cut methane and other harmful pollutants from new and existing oil and gas operations. 

The EPA proposal includes stronger standards that would reduce methane emissions from covered sources by 87 percent below 2005 levels. 

Members of Moms Clean Air Force have been demanding oil and gas methane protections for a decade. This proposal is an important step towards addressing the climate crisis and protecting the health and safety of communities across the country.  

The updated proposal improves on many of the standards in the original draft rule released by EPA in 2021, and addresses concerns of the hundreds of thousands of people who submitted public comments urging EPA to strengthen their methane protections, and the thousands of people from across the country who sent petitions to President Biden urging his administration to move swiftly to publish these updated methane rules. 

Some improvements include:

-- Strengthening leak detection and repair (LDAR) requirements, including requiring inspections at small wells with leak-prone equipment which are responsible for half of all methane emissions nationwide;

-- Maintaining zero-emitting pneumatic equipment requirements

-- Taking steps towards addressing high emission incidents with a new monitoring response program

-- Requiring that abandoned wells are subject to inspections until closure 

"A strong EPA oil and gas methane rule would help to protect frontline communities like mine from methane and other harmful air pollution," said Vanessa Lynch the Pennsylvania State Coordinator for Moms Clean Air Force and mother living near Pittsburgh . "We know families who live near oil and gas operations are more likely to experience adverse birth outcomes, cancers, asthma attacks and respiratory problems. Many of these outcomes would be significantly reduced with protections that include low-producing oil and gas wells, which are are responsible for approximately half of the methane emitted from all well sites in the United States while accounting for only 6% of the nation’s oil and gas production. The methane footprint of these small wells is enormous and can’t be ignored."

There is more to be done and Moms Clean Air Force looks forward to working with the EPA to make sure these updated methane rules protect children’s health from all sources of oil and gas methane pollution including small wells, routine flaring, and polluting equipment.

The Environmental Defense Fund issued this statement on the EPA proposal--

“The Biden administration is continuing to advance the ball on these crucial standards,” said Jon Goldstein, Senior Director of Regulatory and Legislative Affairs at Environmental Defense Fund. “Cutting methane pollution from the oil and gas industry is one of the most immediate and cost-effective ways to slow the rate of global warming while improving air quality and protecting public health. EPA’s proposal reinforces the United States’ firm commitment to climate action as the world convenes in Egypt to renew efforts to stem global warming. Minimizing wasteful methane emissions can also help meet energy needs during the geopolitical crisis, even as we continue to decarbonize the world’s energy systems."

“EPA’s proposal strengthens a number of critical pollution safeguards, including by ensuring regular inspections at high-polluting, lower-producing wells, unlocking advanced monitoring technologies, and addressing pollution from abandoned wells,” said Peter Zalzal, Associate Vice President for Clean Air Strategies. “The proposal relies on modern, proven technologies and best practices, including zero-emitting solutions, that, once strengthened and finalized, will deliver enormous climate and public health benefits for millions of people across the country. We look forward to further reviewing the proposal and working with EPA and all stakeholders to make the final rule as protective as possible.”

Routine Flaring

EPA’s proposal takes steps forward to reduce routine flaring, though further strengthening is needed to eliminate this wasteful and polluting practice.  EPA has also sought comment on questions related to the impacts of the Inflation Reduction Act, which can help to further accelerate methane pollution reductions.

The U.S. oil and gas industry emits 16 million metric tons of methane annually, which has the same near-term climate impact as 350 coal-fired power plants. 

According to analysis from the Environmental Defense Fund, reducing waste of natural gas from leaks and flaring could provide over half of the 50 billion cubic meters per year of natural gas that the Biden administration has pledged to our European allies to address the energy crisis brought on by the Russian war on Ukraine.

Conventional Oil & Gas Wells

Today’s proposal addresses emissions from high polluting, lower-producing wells – over three-quarters of which are owned by large companies that operate over 100 wells each and averaged gross revenues of nearly $335 million in 2019.

The latest peer-reviewed research finds that these wells– sometimes called “marginal” – wells drive over 50% of all wellsite methane pollution nationwide, despite producing just 6% of the country’s oil and gas.

The proposal requires regular monitoring at all sites with failure-prone equipment –  this is critical for reducing equipment leaks, which are responsible for 63% of production site methane emissions.

The proposed standards also maintain strong requirements to transition toward zero-emitting pneumatics, which are the industry’s second largest source of methane emissions.

Click Here for the full EDF Statement.

(Photo: Conventional natural gas well leaking methane in Allegheny County, Earthworks.)

Related Articles This Week:

-- NEW FEATURE: Pennsylvania Oil & Gas Weekly Compliance Dashboard - Nov. 5 To 11  [PaEN]

-- PA Oil & Gas Industrial Facilities: Permit Notices/Opportunities To Comment  [PaEN]  

-- What Can We Expect From Gov. Shapiro, Lt. Gov. Davis On Environmental, Energy Issues?  [PaEN]

-- Guest Essay: Stop Giving Handouts To Natural Gas Industry, Make Them Clean Up Their Own Messes And Protect Public Health - By Mitchell Hescox, Evangelical Environmental Network; Jacquelyn Omotalade, Environmental Health Project; Melissa Ostroff, MPH, Earthworks  [PaEN]

-- Guest Essay: Our Leaders Need To Stop Negotiating With The Fossil-Fuel Industry Behind Closed Doors And Protect Public Health And Our Children - By Lois Bower-Bjornson, Clean Air Council and Washington County Resident  [PaEN]

-- FracTracker Alliance, Clean Air Council, Other Groups Hosting Nov. 14 Webinar On Protected Zones: Setbacks From Oil & Gas Facilities In California, Colorado, PA  [PaEN]

-- Federal Energy Regulatory Commission Accepting Comments On Draft EIS For Ohio Valley Connector Natural Gas Pipeline In Greene County Until Nov. 21  [PaEN]

-- Reuters: Williams Urges FERC To Approve Regional Energy Access Natural Gas Pipeline Expansion Affecting 6 Counties In PA  [PaEN]

-- TribLive Letter: EPA Must Protect Our Kids From Oil & Gas Methane Pollution

-- Bob Donnan Blog/WTAE: Washington County Family Files Landmark Lawsuit Over Hazardous Chemicals And Chevron/EQT Shale Gas Drilling 

-- WTAE: Lawsuit By Washington County Homeowner Says Fracking Caused PFAS ‘Forever Chemicals’ To Contaminate His Drinking Water  

-- Pittsburgh Business Times: Washington County Family Sues Chevron, EQT Over Shale Gas Well Pads Near House

-- Observer-Reporter: Range Resources Part Of DEP Investigation Into High Methane Levels In 2 Homes In South Strabane Twp., Washington County  

-- E&E News - Heather Richards: Biden Orphan Well Plan Faces Trouble In PA: ‘All For Naught’ If DEP Can’t Stop New Oil & Gas Well Abandonments

-- Capital & Main - Audrey Carleton: In Fracking’s ‘Ground Zero’ - Dimock, Susquehanna County - PA Residents Feel Left Behind - Part I

-- Public Source: DEP Promises To Monitor Shell Ethane Plant, Look Into All Citizen Complaints 

-- NextPittsburgh: Franklin, Venango County, Poised To Become The Next Great ‘Outdoor Town’  [Except for the dumping and negative environmental impacts of the conventional oil & gas industry]

Related Articles - Health & Environmental Impacts:

-- DEP Issued NOVs To Conventional Oil & Gas Companies For Abandoning 55 Wells Without Plugging Them During September Alone, A Dramatic Increase In New Well Abandonments  [PaEN]

-- Creating New Brownfields: Oil & Gas Well Drillers Notified DEP They Are Cleaning Up Soil & Water Contaminated With Chemicals Harmful To Human Health, Aquatic Life At 272 Locations In PA [PaEN]

-- Gov. Wolf, Senate, House Republicans Again Fail To Hold Conventional Oil & Gas Drillers Accountable For Protecting The Environment, Taxpayers On Hook For Billions [PaEN]

-- Conventional Oil & Gas Drillers Reported Spreading 977,671 Gallons Of Untreated Drilling Wastewater On PA Roads In 2021  [PaEN]

-- Penn State Study: Potential Pollution Caused By Road Dumping Conventional Oil & Gas Wastewater Makes It Unsuitable For A Dust Suppressant, Washes Right Off The Road Into The Ditch  [PaEN]

-- DEP Lists 84 Townships As ‘Waste Facilities’ Where Conventional Oil & Gas Wastewater Has Been Disposed Of By Road Spreading; Municipalities Need To Do Their Due Diligence [PaEN]

-- On-Site Conventional Oil & Gas Drilling Waste Disposal Plans Making Hundreds Of Drilling Sites Waste Dumps [PaEN]

-- Conventional Oil & Gas Drillers Dispose Of Drill Cuttings By ‘Dusting’ - Blowing Them On The Ground, And In The Air Around Drill Sites  [PaEN]

-- Senate Hearing: Body Of Evidence Is 'Large, Growing,’ ‘Consistent’ And 'Compelling' That Shale Gas Development Is Having A Negative Impact On Public Health; PA Must Act [PaEN]

-- NO SPECIAL PROTECTION: The Exceptional Value Loyalsock Creek In Lycoming County Is Dammed And Damned - Video Dispatch From The Loyalsock - By Barb Jarmoska, Keep It Wild PA [PaEN]

-- Rare Eastern Hellbender Habitat In Loyalsock Creek, Lycoming County Harmed By Sediment Plumes From Pipeline Crossings, Shale Gas Drilling Water Withdrawal Construction Projects  [PaEN]

-- DEP: PA Fracking Operations Sent Nearly 236,000 Cubic Feet Of Radioactive TENORM Waste To Low-Level Radioactive Waste Facilities For Disposal In 2021 - 811,070 since 2016  [PaEN]

-- Study: Industry Data Shows Hazardous Air Pollutants Are ‘Ubiquitous’ In The Natural Gas Transmission System; More Justification For Robust Leak Prevention Programs  [PaEN]

-- Environmental Health Project: Setback Distances And The Regulations We Need To Protect Public Health From Oil & Gas Facilities [PaEN]

-- Conventional Oil & Natural Gas Drilling: An Industrial Machine Moving Across The PA Countryside Leaving Behind Big Liabilities & Spreading Pollution Everywhere It Goes [PaEN]

-- House Committee Fails To Address $70 Million In Penalties On Natural Gas Pipelines Or Real Concerns Of People Living Near Gas Production & Distribution Facilities [PaEN]

-- DEP: Shell, Pipeline Contractor Assessed $670,000 Penalty For Falcon Ethane Pipeline Construction Violations In Allegheny, Beaver, Washington Counties [PaEN]

-- DEP Collects $147,250 Penalty From Rice Drilling B LLC For Erosion & Sedimentation Violations In Greene County; DEP Found Rice Had Hundreds Of Other Violations, Including Abandoning Wells Without Plugging Them  [PaEN]

-- Republican Chair Of House Environmental Committee Believes Opponents Of Natural Gas Infrastructure Projects ‘Just Need To Be Ignored And Politically Ran Over’ [PaEN]

[Posted: November 11, 2022]  PA Environment Digest

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