CATF Testimony to EPA on New Source Performance Standards
Clean Air Task Force experts gave the following testimony at the November 30th EPA listening session on new performance standards to regulate methane emissions from the U.S. oil and gas sector.
Darin Schroeder, Staff Attorney
I am Darin Schroeder, and I’m an attorney with Clean Air Task Force. First, I would just like to recognize all of you at EPA who worked so diligently, for so long, on this proposal. We at CATF think that reducing methane emissions from this sector is an incredibly important step that the country must take to solve its greenhouse gas emissions problem, and I just want to take this moment to thank you all for your work on this.
What EPA has proposed demonstrates some of the ambition that is necessary to truly take action against climate change. Not only does EPA strengthen almost all of its new source standards from 2016, but it also proposes equally strong standards for existing sources for the sector. Existing sources are responsible for the overwhelming majority of emissions from the sector, so addressing those emissions is important—and strongly addressing them is even more important if we hope to meet the global methane pledge of reducing methane emissions by 30% by 2030. To that same end, EPA’s proposal to require almost all pneumatic controllers to be non-emitting is also critical as it would have the impact of essentially removing 1 million metric tons of methane per year.
Unfortunately, we are in a place in the climate change problem where some ambition is not enough, and there are places where EPA must strengthen the requirements before finalization. While the proposal would strengthen leak detection and repair requirements for some sources and does impose some requirements on all facilities, what EPA proposes will not actually solve the leaks problem that we know exists. That is because under EPA’s proposal, facilities with a “potential to emit” of 3 tons per year of methane would only have to perform a one inspection and then will never be required to do look for leaks at that facility again. This is a problem.
Why? Because EPA’s methodology of calculating a facility’s “potential” to emit does not accurately capture that potential. It is well documented, and we’ll provide even more documentation in our written comments, that pieces of equipment like storage vessels and flares frequently fail. When those failures do occur, large emissions events – well over the 3 tpy threshold – can quickly arise. If those failures were to occur after the lone inspection, there is no telling how long that facility would emit before the operator would fix it – if they ever fix it – and those facilities would very quickly be emitting well beyond their “potential” as calculated by this proposal, clearly demonstrating the problem with how that potential is calculated. CATF thinks that the record clearly supports frequent inspections at all sites—monthly or quarterly. At a minimum, no facilities with equipment that is known to fail and/or be the source of large emissions events – sources like flares, storage vessels, and gas-driven pneumatic equipment – should be given a one-time-only inspection pass.
EPA also stops short on the flaring of associated gas, only prohibiting its venting. For new oil wells, it is clear that they cannot simply rely on burning associated gas as the best system of emissions reductions. New oil wells should be better planned to allow that gas to be taken away via pipeline, rather than prioritizing a rush to drill. Moreover, pipelines are not the only method that can reduce emissions from associated gas. There are a number of practices that allow an operator to avoid venting or flaring of associated gas, including: capture and introduction to a gas flow line or collection system to allow it to be sold, with or without additional compression to overcome pipeline pressure restrictions; reinjection for storage or EOR; onsite combustion to produce electricity for onsite or offsite use; compression of the gas into CNG that is then trucked to a gas processing plant; stripping natural gas liquids; and shut-in of the well until takeaway capacity exists. Existing sources are also able to utilize any of these options over time. By designating the affected facility as an oil well and regulating how the associated gas is disposed of, EPA has taken an important first step in its proposal. But it should now finish that and finalize a standard that effectively prohibits the routine flaring of associated gas (with narrow exceptions, such as safety or emergency events).
Thank you for your time, and I’d be happy to follow-up to answer any questions you have.
James Turitto, Campaign Manager
My name is James Turitto. I am a campaign manager with the Clean Air Task Force. I welcome the EPA’s proposed rules as a step in the right direction. At COP26, the US took the leadership role in reducing methane emissions globally by pushing forward the Global Methane Pledge, but actions speak louder than words. The Intergovernmental Panel on Climate Change Sixth Assessment report concluded that methane is responsible for almost fifty percent of the global warming we see today. In order to reduce methane emissions this decade, we need strict regulations coupled with enhanced enforcement.
For the past year, I have been documenting methane emissions in the oil and gas industry around Europe, and I want to talk to you about what I have learned in the field carrying around an optical gas camera. I have visited more than 300 sites along the oil and gas supply chain across 12 countries.
Here is what I have learned:
First, methane pollution is everywhere, regulations must include all sites along the supply chain. I have found emissions at more than 60 percent of the sites I have visited. In total, I have documented more than 450 sources of methane emissions. Some of the sites I have visited were constructed in the last 10 years, others were built many decades ago. The age of the site does not matter.
Furthermore, I have found big leaks in unexpected places and from surprising sources. I have seen large-scale venting events from LNG terminals, I have seen massive leaks from underground sewage systems at gas processing plants, and I have also found and helped repair a major gas leak along a gathering pipeline in an oil field.
You need to look everywhere. If you do not see something, you aren’t looking hard enough.
Second, methane emissions are intermittent, and you need to keep looking. What you see one day may not be there the next day. At the same time, just because you don’t see something, doesn’t mean it isn’t there. Emissions can be intermittent because equipment might not be operating at the time you look or the weather conditions might not suitable for proper detection.
I have been to sites where large methane plumes were venting from compressor stations only to return the next day and find little to no emissions because the equipment was not operating.
Likewise, I have been to sites where I found one of two sources of emissions, only to return a few weeks later and find many more sources of emissions.
Leak detection and repair programs must require frequent inspections to significantly reduce emissions. A strong LDAR program would include monthly inspections.
Third, and finally, we need every tool in the toolkit. Technology is evolving quickly. Thanks to the satellites and other new developing technologies, we are going to have much more information about major sources of methane pollution in the next five years. While right now we are only able to see the largest sources of emissions using satellites, in a few years we will be able to see many more. But it’s important to remember that satellites will only be able to identify about fifty percent of the point sources responsible for methane emissions in the oil and gas industry. The other sources of emissions that will make up the rest of the inventory will be so small that they will require on the ground inspections and surveillance. All of these tools must be used together and complement each other.
Finally, there must be a system for public reporting and oversight to aid in enforcement. During my work I have had a one recurring conversation other ‘methane hunters’: Once you find a problem, what do you do? The next steps are not so clear: (1) You can try to contact the company, hope they will respond and subsequently fix the problem. (2) You can go public and expose the company, and maybe they will feel compelled to act. (3) Or you can report to a regulator, but there are no guidelines on what to report and how they will respond.
We have tried all these approaches. Sadly, the only time leaks get fixed is when the company is willing to act. This cannot be how we operate. The EPA must empower community members – researchers, activists, and journalists — with the ability to report emissions and violations.
We must act now, and we must act quickly. We have precious little time to make a real impact on the climate.
The Global Methane Pledge, which was signed by more than 100 countries at the recent climate conference in Glasgow, has shown the world the US can once again be a leader on climate. To date, the U.S. has failed to control its own methane emissions in the oil and gas sector. How can we expect other countries to reduce their emissions if the leading nation behind the Pledge cannot do it? We need stronger regulations and enhanced enforcement to meet the lofty goals of the Global Methane Pledge.