HEALTH PROFESSIONAL COMMENT LETTER TO EPA: Please strengthen oil and gas methane and VOC rules

Summary:  EPA's proposed rules to limit emissions of methane and volatile organic compounds from oil and gas production aren't strong enough. Instead of a possible 40% reduction, they'd only cut emissions 5%. They leave out major sources of pollution, let drillers skip inspections, leave loopholes for polluters to avoid regulation, and don't include monitoring at the fence line or in the atmosphere, where emissions do the most harm. Let's ask them to do better. Full text of comment letter is below.

As health professionals and students we applaud EPA's action to limit emissions from the country's largest anthropogenic methane source, the oil and gas industry. The health impacts of climate change are already being felt in our hospitals and clinics. Over 15 million Americans live within 1 mile of an oil or gas well and are at increased risk of cancer, birth defects, brain damage, childhood asthma, cardiovascular disease, and premature death from exposure to VOCs and ozone (McKenzie, 2014; 2012).

Because methane is short lived and has a 20 year global warming potential 87 times that of carbon dioxide, rapid emissions reduction can slow global warming by as much as 0.5 degrees C before 2050 (Shindell, 2012). This, and the chance to protect our communities from toxic air pollution are opportunities we can't afford to squander, which is why we are so disappointed that the proposed regulations would decrease methane emissions only 5% by 2025, when it is possible to achieve reductions of 40% with interventions that quickly pay for themselves by saving fuel (Harvey, 2012). The following are our suggestions for improvement.

Include all major sources  Even the best rules won't be effective unless they apply to all major pollution sources. Methane is not a local pollutant, its effect is regional and global. Facilities which are functionally connected, as well as those within a quarter mile or each other, should be aggregated, regulated as major sources, and required to use the best available technology to limit release of harmful emissions. 

Nearly two million existing active oil and gas wells are not covered by these rules and will produce 90% of the sector's methane emissions in 2018. We support EPA's inclusion of existing sources in ozone non attainment areas but hope you will not wait to protect other communities until their air is too polluted to breathe and will issue regulations for existing sources without delay. 

Venting during liquid unloading from gas wells is the third largest source of emissions from natural gas production, yet this was excluded from regulation.  Plunger lifts can decrease emissions 50-99% per unloading event (Allen, 2015). High efficiency flaring at the small subset of wells with very high frequency unloading would further reduce emissions by 93% (Heath, 2014; EDF, 2015). These measures should be mandatory. 

Adequate inspection schedule  The proposed inspection schedule is inadequate. Colorado, Wyoming, Pennsylvania, and Ohio all require quarterly inspections, which have been found to be cost effective for industry(ICF, 2014). Inspecting every 6 to 12 months would double the amount of fugitive emissions. Inspections should be quarterly at minimum.

The bulk of emissions come from a very small subset of leaks (Heath, 2014) so the percentage of leaking components does not predict methane losses and should not determine whether operators can skip inspections. Rewarding fewer leaks with fewer inspections creates incentive for non-compliance. The EPA handbook on LDAR Best Practices states: “Experience has shown that poor monitoring rather than good performance has allowed facilities to take advantage of the less frequent monitoring provisions.” (EPA, 2007) and cites an NEIC investigation which found numbers of leaking components at refineries up to ten times higher than company reports (EPA 1999).

Monitor pollutants that leave the plant  Once all active oil and gas operations are regulated, regional inspection frequency should determined by top down measurements. This would create a direct relationship between emissions and inspection frequency and provide a true incentive to eliminate leaks. Technologies for top down measurement by satellite and overflight sampling are well developed ( Miller, 2013; Karion, 2013; Caulton, 2014; Schneising, 2014) and federal participation is appropriate under the Land Based Natural Gas Extraction and Production National Enforcement Initiative which provides for increased federal involvement due to the significant health and environmental threats involved. (EPA, 2014).

Since the proposed rule, in combination with the previous VOC standard, will cover all oil and gas VOC emissions, it should require ambient VOC monitoring at the fenceline to protect the health of communities. Peer reviewed research from several states has documented ambient levels of benzene, toluene, and formaldehyde in communities adjacent to oil and gas wells, far in excess of those deemed safe by the Agency for Toxic Substances and Disease Registry and the Integrated Risk Information System (Helmig, 2014; Macey, 2014). Measurement of VOCs escaping from oil and gas facilities is necessary to verify compliance and safeguard public health.  

As nurses, doctors, researchers, public health professionals, and students we want to protect the public from the serious health harms that result from inadequate control of oil and gas emissions. The proposed rules are a welcome start but without the inclusion of existing and connected facilities, liquid unloading, more frequent inspections, and top down and fenceline monitoring they fall short of the mark and leave the public at unacceptable risk of harm from air pollution and climate related illnesses.

Name Professional Title / Affiliation* City, State email

Name Professional Title/Affiliation* City, State email

REFERENCES

Allen, D. Methane Emissions from Process Equipment at Natural Gas Production Sites in the United States: Liquid Unloadings Environ. Sci. Technol., 2015, 49 (1), pp 641–648 DOI: 10.1021/es504016r

Caulton, D. R., et al. (2014),Toward a better understanding and quantification of methane emissions from shale gas development, Proc. Natl. Acad. Sci. U. S. A., 111(17),6237–6242, doi:10.1073/pnas.1316546111.

EDF, The Cost Effectiveness of Mitigating Liquids Unloading Emissions Using Flares. Document submitted to California Air Resources Board, April 2015 http://www.arb.ca.gov/cc/oil-gas/meetings/EDF_attachment_5-22-15.pdf

EPA, Clean Air Act Stationary Source Compliance Monitoring Strategy (CAA CMS). 2014 http://www2.epa.gov/sites/production/files/2013-09/documents/cmspolicy.pdf

EPA Office of Enforcement and Compliance Assurance, Leak Detection and Repair A Best Practices Guide, 2007 http://www2.epa.gov/sites/production/files/2014-02/documents/ldarguide.pdf

EPA Natural Gas STAR Program, http://www3.epa.gov/gasstar/accomplishments/index.html#three

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Harvey, S. Leaking Profits: The U.S. Oil and Gas Industry Can Reduce Pollution, Conserve Resources, and Make Money by Preventing Methane Waste. NRDC Report March 2012, http://www.nrdc.org/energy/leaking-profits.asp

Heath, G. “U.S. Natural Gas System Methane Emissions: State of Knowledge from LCAs, Inventories, and Atmospheric Measurements.” Presentation at Colorado State University on April 7, 2014.

Helmig Highly Elevated Atmospheric Levels of Volatile Organic Compounds in the Uintah Basin, Utah Environ. Sci. Technol., 2014, 48 (9), pp 4707–4715 DOI: 10.1021/es405046r

ICF March 2014 Economic Analysis of Methane Emission Reduction Opportunities in the U.S. Onshore Oil and Natural Gas Industries, https://www.edf.org/energy/icf-methane-cost-curve-report

Karion, A. et al. (2013), Methane emissions estimate from airborne measurements over a western United States natural gas field, Geophys. Res. Lett., 40(16), 4393–4397, doi:10.1002/grl.50811.

Macey, G. Air concentrations of volatile compounds near oil and gas production: a community-based exploratory studyEnvironmental Health 2014, 13:82  doi:10.1186/1476-069X-13-82

McKenzie, L Birth Outcomes and Maternal Residential Proximity to Natural Gas Development in Rural ColoradoEnviron Health Perspect; DOI:10.1289/ehp.1306722 2014

McKenzie, L. Human health risk assessment of air emissions from development of unconventional natural gas resources, Science of the Total Environment 424 (2012) 79–87, 2012. http://www.ncbi.nlm.nih.gov/pubmed/22444058

Miller, S. M., et al. (2013),Anthropogenic emissions of methane in the United States, Proc. Natl. Acad. Sci. U. S. A., 110(50),20,018–20,022, doi:10.1073/pnas.1314392110.

Schneising, O. (2014), Remote sensing of fugitive methane emissions from oil and gas production in North American tight geologic formations. Earth's Future, 2: 548–558. doi:10.1002/2014EF000265

Shindell, D Simultaneously Mitigating Near-Term Climate Change and Improving Human Health and Food Security,  13 January 2012:Vol. 335 no. 6065 pp. 183-189 DOI: 10.1126/science.1210026

World Resources Institute, Bradbury J. CLEARING THE AIR: REDUCING UPSTREAM GREENHOUSE GAS EMISSIONS FROM U.S. NATURAL GAS SYSTEMS Working paper, World Resources Institute April 2013 http://www.wri.org/sites/default/files/clearing_the_air_full_version.pdf