Results you can rely on 

# Why Methane Matters

Gary T. Hunt Vice President and Principal Scientist TRC Corporation Lowell, MA 01854 

### Oil & Gas Environmental Compliance Conference Washington, PA May 13

- 14, 2014Results you can rely on 

# Topics of Discussion

• Atmospheric Science

• Sources of Methane

• Regulatory Climate

– Natural Gas Production (Unconventional or Shale)

• White House Strategy to Reduce Emissions

• European Perspective

• Colorado Air Regulations

• Debate and Controversy

• Significant Field Studies

• Closing Thoughts

• References

• Questions

2Results you can rely on 

# Why Methane Matters!!

•

3Results you can rely on 

## Why Methane Matters? Atmospheric Science [1,5,10]

4 

### 20

– 25 Times 

### > GWP of CO 2 

### over next 100

-

year term

72 Times 

### > GWP of CO 2 

### in first 20 years

Atmospheric lifetime of 10

- 12 years

Oxidizes to CO 2 

### and water via reaction with OH

- Radical Concentrations have risen 250% over the period 1750

– 2011 (700 ppb and 1874 / 1758 ppb) 

### Background now 1.9 ppm (v/v) (200 Times 

### < CO 2 

### )

OH

- Radical Levels Decreasing

CH 4 

### Levels highest in past 420,000 yearsResults you can rely on 

## Global Warming Potentials and Atmospheric Lifetimes (Years) [4]

Gas Atmospheric Lifetime GWP a

CO 2 50

- 200 1
CH 4 12 ± 3 21
N 2 O 120 310
HFC

- 23 264 11,700
HFC

- 32 5.6 650
HFC

- 125 32.6 2,800
CF 4 50,000 6,500
C 2 F 6 10,000 9,200

SF 6 3,200 23,900

5 Source: (IPCC 1996) a100

- year time horizon The GWP of CH 4 incudes the direct effects and those indirect effects due to the production of tropospheric ozone and stratospheric water vapor. The indirect effect due to the production of CO 2 is not included.Results you can rely on 

## Sources of Methane Emissions in the United States, 2011 [3]

6 *37% of NG Emissions associated with production or 8.9% of TotalResults you can rely on 

## CH 4 

## Emissions U.S. Regulatory Climate

7 CH 4 specifically not regulated historically

Not typically classified as a volatile organic (VOC)

VOC typically defined as Non

- Methane Hydrocarbons (NMHC)

CH 4 not addressed in final rule NSPS Subpart 0000 (April 2012)

Excluded from NSPS and NESHAPS Shale Gas Production Wells (77 CFR, 49, 490, August 2012)

States Debate

– “Sue and Settle” Controversy

White House Methane Reduction Strategy (March 2014)

Colorado Air Rules (Feb 2014) 40 CFR Part 98 Subpart W

– (March 10, 2014)Results you can rely on 

# Civil Strife

– State Rivalry!!!

EPA Regulation of CH 4 

### Emissions from Oil/Gas Operations Under NSPS

PRO* CON**
New York*** Alabama Ohio
Connecticut Arizona Oklahoma
Delaware Indiana South Dakota Maryland Kansas Texas Rhode Island Montana West Virginia
Vermont Nebraska Wyoming
Massachusetts North Dakota

8 *NE States informed EPA of their intent to sue EPA 12/11/2012. Notice of Intent to Sue. **Signed May 2, 2013 letter cautioning EPA regarding “friendly” negotiations between Agency and NE States (“Sue and Settle”). ***Moratorium currently in placeResults you can rely on 

## Colorado Air Regulations [16] (Adopted 2/23/14)

• First rule to classify methane and ethane as regulated pollutants

• Rules passed with little consideration of industry comments (Colorado O&G Association)

• Regulate hydrocarbon emissions from storage tanks, well production facilities, and compressor stations

• Compliance deadlines as early as May 2014

• NSPS 0000 enforcement now at state level

• “Ripple” effect concerns

– influencing other state programs

9Results you can rely on 

## Colorado Rule

– Some Key Features

• De minimis thresholds for all non

- criteria reportable pollutants set at 250 lbs/year and Air Pollution Emission Notice (APEN) now required.

• Auto igniters required on all emissions control combustion devices both existing and new.

• LDAR programs for well production facilities and compressor stations.

• Storage Tank Emissions Management (STEM).

• Creates Approved Instrument Monitoring Methods (AIMM) and inspection schedules.

• AIMM includes IR camera, EPA Method 21 and AVO (Audio, Visual and Olfactory)

10Results you can rely on 11 

### White House Strategy to Reduce Methane Emissions (March 2014) Relevance to NG Production [14]

Some Features

• Executive Orders

– no congressional legislation !!!

• Interior department standards to reduce venting and flaring of methane from O&G production on public lands.

• Improved methane measurements

– atmospheric concentrations, emissions measurement and inventories.Results you can rely on 

### White House Strategy to Reduce Methane Emissions (March 2014) Relevance to NG Production [14]

• Working with states

– DOE/EPA provide technical assistance to support policy to reduce emissions.

• Enhanced partnerships and stakeholders engagement

– e.g., DOE roundtable discussions (industry, states, academia, non government organizations and labor).

• EPA bolster voluntary NG Star Program

– identify cost

- effective technologies and practices that reduce or avoid CH 4 

### emissions.

12Results you can rely on 

### White House Strategy to Reduce Methane Emissions (March 2014) Relevance to NG Production [14]

• DOE will support development of new technologies

.

• Identify policy recommendations for emissions reduction from energy infrastructur e

- (gas production, transmission, storage and distribution of supply chain).

• Prioritize pipeline safety

- (PHMSA)

- state program survey

– replace old cast iron pipes with new technology.

13Results you can rely on 

## European Perspective (October 2013) Shale Gas Production [9]

Europe considering a Methane Emissions Ceiling under EU Law. Revised National Emissions Ceilings Directive ( NECD )

Shale Gas Companies in Europe will have to monitor and account for methane emissions at drill sites or face regulations, (Joseph Delbeke , EU Climate Head)

**“Companies are going to put it on the table or a regulation is going to come..... we**  **must know what the methane emissions are going to be.”**  ( J.Delbeke )

14Results you can rely on 

## U.S. Industry and Shale Gas Advocates Perspective

EPA NSPS Rules have been proven effective “EPA got it right” Additional NSPS to address CH 4 not warranted. Current NSPS and NESHAPS are resulting in CH 4 emissions reduction (control/capture) [6] 30% of US NG currently attributable to fracturing of shale formations; 50% by 2040 [7] Use of NG versus coal/oil provides net GHG benefit (CO 2 Reduction)

15Results you can rely on 

## Shale Gas vs Coal GHG Impacts Comparison and Controversy

16 

## GHG advantage disappears if 1% of CH 4 

## is lost during NG production [7]

GHG advantage lost at 3

- 4% fugitive emissions [8]

Shale Gas footprint 20

- 200% (2 times) > than coal over 20

- year term [11]

Footprints comparable over 100

- year term [11]Results you can rely on 

## Fugitive CH 4 

## Emissions Comparison of Estimates (Expressed as % of CH 4 

## Produced over Well Lifetime)

Study/Source Type Results In % 

### Comments Reference

EPA 2011 GHG Inventory 0.47 Relies on engineering calculations. USEPA Feb. 2013 [3]

UT/ EDF 2013 0.42 Field measurements small population of sources. PNAS 2013 Allen, et al [6]

Cornell/ Howarth 1.7

- 6.0 Conventional Gas Wells only (0.01% well completion) Howarth

, et al 2011 [11]

Cornell/ Howarth 3.6

- 7.9 Shale Gas Wells only (1.9% well completion) Conservative (Author) Howarth , et al 2011 [11]

NOAA Utah 6.2

- 11.7 Based on hourly gas production rate from a single well on one day. Aircraft measurements with positive bias likely from non

- well sources. NOAA [13]

17Results you can rely on 

## UTEXAS/EDF Study CH 4 

## Emissions Shale Gas Production [6]

18 

## Some Features/Findings

 Direct field measurements at production sites.

 Well completion emissions far below prior EPA estimates.

 NSPS/NESHAPS regulated sources showed most dramatic reductions.

 EPA NSPS and “Green Completion” control technology credited.

 Emissions beyond well site > EPA estimates (unregulated sources).Results you can rely on 

## National Emission Estimates for the Natural Gas Production Sector [6]

Category 2011 EPA GHG Inventory Net Emissions,

*

Gg of Methane/ yr Emission estimates from UT PNAS Report Gg of Methane/ yr

Completion flowbacks from wells with hydraulic fracturing 654 18 (5

- 27)

Chemical pumps 34 68 (35

- 100)

Pneumatic controllers 355 580 (518

– 826)

Equipment Leaks 172

- 211 291 (186

- 396)

Subtotal, Natural Emissions

(All Above Categories) 1215

- 1254 957 ± 2 00

19 Total methane, Gg Methane emissions, *% [percent of gross gas production] 2,545 0.47% [0.59%] 2,300 0.42% [0.53%]Results you can rely on 

## UTEXAS/EDF Study [6] The Critics Point of View “Frackademia”

 Sample population too small (only 150 Shale Production Sites) [12]

 Not representative on industry

- wide basis (489 wells vs 446,745 in EPA 2011 GHG Inventory) [2,3]

 Extrapolation of data industry wide not valid [12]

 Sites selected by petroleum industry sponsors (9 drilling companies) [7,12]

 90% funds provided by petroleum c ompanies [12]

 “Best Case” emissions s cenario ( Howarth /Cornell)

 Study authors career ties to oil industry.

20Results you can rely on 

### CH 4 

### Emissions From Shale Gas Development Marcellus Region of SW Penn

- April 2014 PNAS [15]

• Purdue and Cornell researchers

• “Top Down” approach

– aircraft measures gas levels in air above well

• Wells found with high emissions were in “drilling” stage (<1% of total # in region)

• Drilling (pre

- production) not well represented in current inventories

• Regional CH 4 flux (2.0

– 14 g/skm 2 ) statistically equivalent to EPA “bottom up” inventory (2.3

- 4.6 g/skm 2 )

• Seven (7) well pads (drilling stage) 34 g/s emission rate represents 4

- 30% of regional flux

• EPA “bottom up” estimates for drilling releases range from 0.04

– 0.30 g/s (100

- 1,000 times lower)

21Results you can rely on 

### • Develop cost

- effective CH 4 

### sensing technology.

• Improve US greenhouse gas inventory methodology

– (calculations, emission factors, higher quality data reporting).

• Expand national methane ambient monitoring network (NOAA).

• Improve local/regional emissions modeling

– DOE sponsored measurement programs in Marcellus region of Penn (Penn State and Carnegie Mellon).

22 

### White House Strategy to Reduce Methane Emissions Methane Measurement Action Plan [14]Results you can rely on 

### Emissions Estimates in Pennsylvania Marcellus Region

– Using Atmospheric Inversion



## Some Features

 DOE sponsorship

 Jointly conducted by Penn State and NOAA

 Quantify fugitive CH 4 

### emissions from Marcellus shale gas production region (2014

- 2016)

 Multiple measurement platforms (aircraft, fixed towers and ground vehicles)

 Use of carbon isotopic signatures and tracer gas to differentiate CH 4 

### sources

23Results you can rely on 

### Emissions Estimates in Pennsylvania Marcellus Region

– Using Atmospheric Inversion

• Use of IR based laser diode (Cavity Ring Down Spectroscopy).

• “Top down” approach based upon ambient measurements in combination with meso

- scale atmospheric inversion modeling.

• Source specific data collected to develop CH 4 

### emissions map “bottom

- up”.

• Develop refined emission factors (EF) for use in new inventories and for comparison to existing EF and inventories.

24Results you can rely on 25 

## The Methane Matter!!! Some Closing Thoughts

Debate and controversy continue

The regulatory climate has “heated up”
Much needed field measurements now available or in progress; and more planned
Fugitive CH 4 = lost $

Consider voluntary self audits of gas production sites

Actual industry

- wide emissions somewhere between 0.42 and 7.9%

Further CH 4 regulations imminent, both federal and in certain states (Colorado Copy Cats !!!!) Watch out for White House Executive Orders inviting EPA actionsResults you can rely on 

## Thank You For Your Attention !

26 Contact Information:

**Gary Hunt, Vice President and Principal Scientist TRC Corporation**  **650 Suffolk Street Lowell, MA 01854** 

**978.656.3551 (w) ghunt@trcsolutions.com** Results you can rely on 

# References

1) Leveraging Natural Gas to Reduce GHG Emissions, Center for Climate and Energy Solutions, June 2013.
2) USEPA, Draft U.S. Greenhouse Gas Inventory Report, 2013; http://www.epa.gov/climatechange/ghgemissions/usinventoryreport.html
3) Draft Inventory of U.S. Greenhouse Gas Emissions and Sinks: USEPA, 1990

– 2011, February 11, 2013. 4) IPCC (1996) Climate Change 1995: The Science of Climate Change Intergovernmental Panel on Climate Change. J.T. Houghton, et al. Cambridge University Press, Cambridge, U.K.
5) Methane Hydrates and Contemporary Climate Change, Nature Education Knowledge, 3(10):29, Carolyn Ruppel, 2011.
6) Measurements of Methane Emissions at Natural Gas Production Sites in the U.S., D.T. Allen, et al. Proceedings of the National Academy of Science (PNAS), USA, 2013, DOI: 10.1073/PNAS 1304880110.

27Results you can rely on 

# References (cont’d)

7) “Chasing Methane” Chemical and Engineering News, September 30, 2013, Volume 91, Number 39, page 24. 8) New York Times, September 16, 2013, “Gas Leaks in Fracking Disputed in Study.”
9) Euractiv ( www.Euractiv.com ), October 8, 2013.
10) Recent Greenhouse Gas Concentrations, DOI: 10.3334/CDIA/ATG.032, February 2013, T.J. Blasing, U.S.DOE and Oakridge National Laboratory.
11) “Methane and the Greenhouse Gas Footprint of Natural Gas from Shale Formations”, R.W. Howarth et al., Climatic Change DOI: 10.1007/S10584

- 011

- 0661

- 5, 2011. 12) “Frackademia”: The People and Money Behind The EDF Methane Emissions Study, September 17, 2013. www.commondreams.org 13) NOAA’s One Day of Data Falls to Quiet Critics, August 7, 2013. http://theenergycollective.com/

28Results you can rely on 

# References (cont’d)

14) White House “Climate Action Plan

– Strategy to Reduce Methane Emissions” March 2014. 15) “Toward a Better Understanding and Quantification of Methane Emissions from Shale Gas Development” Carlton, Shepson et al. (Purdue, Cornell, NOAA, U Colorado and Penn State) Proceedings of the National Academy of Science April 14, 2014.
16) Revisions to Regulations 3, 6 and 7 (February 23, 2014) Colorado Air Quality Control Commission.

29