This is part two in a two-part series by Amber Reimondo, Outdoor Council Environmental Quality Advocate, on fugitive methane emissions during oil and gas production and how we can fix the problem. Click here for part one.

I’m on a tour in western Wyoming’s Jonah Field and I ask my host, Paul Ulrich, Jonah Energy’s Government and Regulatory Affairs director, why his company has chosen to go beyond even what Wyoming’s existing air quality regulations require. Jonah’s fugitive methane leak detection and repair program can be a model for others. “Leak detection is a priority for [Jonah Energy],” he said, “because we keep our employees safer, reduce emissions and capture more gas to sales through our program.”

A Proven Cost-Benefit Evaluation

There are good reasons why Jonah Energy sees leak detection and repair (formally known as fugitive emissions monitoring or FEM) as a winning investment.

It’s a win for the company’s employees who are safer on the worksite if leaking odorless, colorless methane gas—an explosion hazard—is discovered and capped.

It’s a win for air quality. Methane is an incredibly potent greenhouse gas. Additionally, volatile organic compounds, which can be a component of fugitive emissions, react with nitrogen oxides (NO_x) and sunlight to create dangerous ground-level ozone. Ozone problems have plagued the rural Upper Green River Basin and its residents for years and are only now, after enforcement of stricter regional regulations (and combined with a downturn in drilling activity) beginning to show signs of improvement.

Detecting and fixing leaks is also a win for the company’s bottom line. Even in today’s slumped natural gas market, Jonah Energy’s FEM program continues to pay for itself with the sales from the gas the company saves.

The State of Wyoming and county government (and ultimately residents) also benefit from the taxes and royalties earned when the gas is sold instead of lost to the atmosphere. This is especially important given the crunched state of Wyoming’s budget today.

Leaks happen, even to the best equipment

Paul and I talk a little more about the cost savings. The net benefit from recovered gas sales is reliable. Paul explains that leaks are just “part of the nature of equipment” so they can occur no matter how new the fitting and regardless of whether the gasket was fully functional when someone last checked it. Without regular inspections and maintenance, undetected leaks can lead to an enormous waste of an important and finite resource.

While leaks are inevitable, Jonah Energy’s inspection records illustrate that through regular and frequent instrument-based inspections, it is possible to decrease the number and severity of leaks overall. Frequent inspections allow the company to identify even the smallest leak right away and to identify trends in designs or brands that consistently malfunction as well as those that more consistently function as designed. Jonah Energy’s monthly inspections allow the company to remain on top of small maintenance problems before they become big ones, and as a result, just like a well-maintained vehicle, the likelihood of experiencing an unexpected, major equipment failure decreases.

Since starting the program in 2010, Jonah Energy has seen a trend that shows leaks are becoming less prevalent and less severe thanks to its regular, frequent inspections and maintenance—even as total well numbers have increased. (According to Jonah Energy, the decrease in number of site inspections over time in the chart below is due to consolidation – more wells on one pad – not less wells.)

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Behind the Lens

At the moment, the Jonah field is the nation’s 8^th largest producing natural gas field. It was ranked even higher before the downturn in the market. The resource is drawn from a multitude of layered tight sandstone lenses (imagine stabbing a straw down into a bowl of potato chips and trying to hit as many chips as possible) anywhere from ten to thirteen thousand feet beneath the surface. It’s this geology that initially made directional drilling a challenge for developers. Even though technology has advanced and more wells can be consolidated and drilled from a single well pad, the sheer density of production sites in the Jonah Field is not an image you’ll soon forget once you see it.

After the BLM approved the Jonah Infill Project in 2006, up to 40 wells per acre can now be drilled over the relatively small 30,500-acre project area. This presents both a challenge and a blessing from a site-by-site inspection standpoint. It’s a challenge because at the moment, Jonah Energy is inspecting 136 individual production and compression facilities every month. But at the same time 30,500 acres is a relatively small gas field – during the tour, we drove the width of the field in about ten minutes and its length in about twenty.

Jonah Energy employs four full-time employees who are equipped with their own infrared camera and charged with monthly inspections of all facilities. These employees have prior experience working on well sites, so they’re often able to repair leaks themselves rather than order in a crew.

Outside his office, Paul introduces us to Caesar Deiaz, one of the team of four inspectors Jonah employs. Caesar is holding something that looks like my parents’ 1995 camcorder. It’s his Flir camera. He flips a switch on the camera and it starts to make a steady electronic sound. Caesar laughs and notes that it’s the camera starting its required ten minutes to cool down, not warm up, before he can use it.

While we wait for the camera to boot up, Caesar sits us down in front of his computer for a look at a portion of a 45-minute video from one of his recent site inspections. At first, the video seems pretty bland. Everything is black and white and the first thirty seconds are mostly a shot of blurred gravel as Caesar walks from the outer edge of a well pad up onto a metal grated walkway that carries him through the facility. The inspectors always record a solid, uncut video at every site to prove that the entire site was inspected and that no leaks were found and omitted from the clip. For several minutes, Caesar’s camera rolls over and pauses at a pipe here, a hatch there, a fitting over here and nothing seems out of the ordinary. But then, we see it. The camera pauses over a hatch and something that appears as black smoke can be seen flowing from a damaged gasket. It’s a gas leak. Caesar zooms in to get a better look at its source and then continues the rest of his inspection before coming back to make the repair. This leak would have been invisible without the use of his Flir camera. I ask Caesar how often he finds leaks like this. “Every day,” he says.

In addition to finding and repairing the leak, Caesar will also “bag” it to get a leak rate using a separate instrument capable of measuring volume. He’ll take that rate back to his colleague at the office who will translate it into an approximate total leaked volume. That volume is important for the company’s records because it helps employees understand how much gas was saved by repairing the leak. They can compare that to the cost of running the program and that’s what allows them to say with confidence that the program more than pays for itself. Along with volume data are those long internal lists of equipment designs that seem to work better or worse than others, which Paul proudly states Jonah Energy happily shares with other operators or regulators who ask because, “it’s in everyone’s interest to know and use this information.”

In addition to Jonah Energy’s inspection program, its data collection and tracking also exceed existing state regulations. The company’s data inform its operations and business decisions, but also provide the rest of us with an important window into the reality of fugitive emissions and what it takes to address them.

Paul notes that Jonah has pursued their monthly FEM and data tracking program because it works for them, and that every company and gas play is different. But he also says that a requirement for these instrument-based inspections on just a quarterly basis – something that is now in place in the Upper Green, but that the Wyoming Outdoor Council and others are urging the Department of Environmental Quality to require statewide—are both “reasonable and feasible.” Jonah’s more robust leak detection program demonstrates what is possible when a company prioritizes Wyoming’s environment and its people, along with its own bottom line.

Thank you to Paul Ulrich, Caesar Deiaz and Jonah Energy for sharing their leak detection work with us.

This is part one in a two-part series by Amber Reimondo, Outdoor Council Environmental Quality Advocate, on fugitive methane emissions during oil and gas production and how we can fix the problem. Read part two in the series here.

The gravel crackles under the tires as I pull off of the pavement of Highway 191 and onto a mostly-nondescript BLM road in the middle of a western Wyoming sagebrush expanse. I spent countless days as a child rock hounding and exploring with my mom and dad out here in the Upper Green River Basin. But that was years ago. We stopped our sagebrush adventures just before I started high school because a drilling boom had taken off in the area. There were rumors of poor air quality in Pinedale where my grandparents had lived for years and it wasn’t the quiet, open landscape I had experienced on so many adventures as a young girl.

Over the past 10 years, I’ve researched and worked to address oil and gas related issues in different capacities and I’ve been on my share of tours in various oil and gas fields, even this one, near the peak of the last natural gas boom. I always learn something new and I’ve often seen a thing or two that sends me home frustrated, and on one occasion, even physically sick. But today’s tour is different. I’m here to get a first-hand look at what one mid-sized, independent company has managed to accomplish for air quality. And notably, they’ve done so while many other companies have claimed lesser measures untenable.

A Dire Problem

Since 2010, Jonah Energy—and prior to the 2014 acquisition, Encana—has used infrared cameras to conduct regular monthly inspections of their production sites in the Jonah Field. These inspections enable them to quickly find and fix otherwise undetectable or simply unseen methane leaks, also known as fugitive emissions, on production and processing equipment.

You might wonder why fugitive emissions monitoring (FEM) is noteworthy. Do fugitive methane leaks actually account for much? And what about all the talk that natural gas is a cleaner energy source? First, leaks do account for significant damaging emissions; more on that in a moment. And second, if extraction, processing, storage and transportation of natural gas are done right, the combustion of natural gas is indeed cleaner than the combustion of coal. But that’s a big if. Natural gas, which is mostly methane, has higher energy content than coal and thus produces less CO₂ when it’s burned – roughly half the amount of CO₂ for the same amount of energy. But in its entire lifecycle as an energy source, from the point it leaves the ground to the point it ignites your furnace or powers a city bus, natural gas can be a greater source of concern with respect to greenhouse gas emissions than coal. That’s because raw, uncombusted methane actually has a far more potent warming potential than carbon dioxide in the atmosphere – approximately 84 times more potent over the course of 20 years.[1] So if raw methane leaks unnoticed from faulty or misused oil and gas production equipment—which happens at even the newest facilities—before it gets to market, natural gas as a “bridge” away from dirtier alternatives could be described as a bridge to nowhere.

In recent years, research has started to reveal how ubiquitous the problem of fugitive methane leaks is. A Center for American Progress study estimated that in 2012, approximately 8.1 million metric tons of fugitive natural gas emissions were released from both conventional and unconventional natural gas production facilities on federal lands alone – that’s the same volume of CO₂ equivalent (CO₂e) as emissions from 42 million vehicles in a year.[2] NASA’s Jet Propulsion Laboratory and the Administration’s partner researchers discovered a methane plume the size of Delaware above 40,000 oil and gas wells in the Four Corners area of Utah, Colorado, New Mexico and Arizona. A primary cause? Fugitive emissions.[3] Another study,[4] the largest of its kind to date, involved fly-overs of 8,000 oil and gas wells in seven states using infrared technology to determine just how common fugitive emissions are. The findings were telling: Fugitives were estimated to comprise the vast majority of the 9 million tons of methane emissions (including those from intentional venting) from oil and gas operations every year. The study also confirmed what other research has found, which is that fugitive emissions are largely unpredictable. They can and do occur from all oil and gas facilities to some degree—whether from unnoticed equipment malfunctions or simple human error (e.g. leaving a hatch open on a tank).

The contentious, slow, but promising path to curbing fugitive emissions

In response to the growing evidence of a problem, regulatory agencies responded. Wyoming’s Department of Environmental Quality, which regulates oil and gas air emissions, now has policies and a new rule aimed at reducing fugitive emissions in the Upper Green River Basin both from new and modified sources and existing sources. Including inspections for the latter source is key to effectively reducing emissions.[5] Instrument-based inspections must be made on a quarterly basis in the Upper Green. This is a model that the Outdoor Council believes can be applied to the rest of Wyoming. The DEQ, however, has yet to expand these same requirements beyond the Upper Green. This is a problem because it is areas outside the Upper Green that today are experiencing the greatest increase in drilling applications and activity.

The Environmental Protection Agency has updated its New Source Performance Standards under the Clean Air Act for new and modified oil and gas operations. These require regular, though not quarterly, site inspections for leaks. Members of industry and fifteen states are currently challenging these requirements in court. And although an implemented rule is still a long way out, the EPA also began to collect information in May on how best to regulate fugitive emissions from existing sources.

The Bureau of Land Management is finalizing a rule that aims to raise the bar on oil and gas operators on public and American Indian lands. The proposed rule seeks to reduce resource waste from flaring, venting and leaks at oil and gas production sites partly through bi-annual, and in some cases only annual leak inspections. The proposed rule would also mandate that operators use infrared cameras with some exceptions for smaller operators (with 500 wells or less). This rule will likely also face litigation.

The Outdoor Council is working with regulators, industry, public health organizations, and other conservation advocates to find solutions for areas outside the Upper Green. We need to agree on a suite of effective, common sense regulations that will offer the same strong air quality protections and keep natural gas in the pipe for every area of Wyoming, no matter the zip code.

Enter Jonah Energy

In the area of fugitive emissions mitigation, Jonah Energy is a leader and an example of what can be done when industry leaders step up to the plate for more than just their own bottom line. My next post delves deeper into my visit and field tour with Jonah Energy, which offered a bright light in what can feel like an overwhelming problem. I’ll explain further the technology and proactive protocols this company proudly uses to get out in front of the problem of fugitive emissions and why, even in a slumped natural gas market, Jonah Energy’s FEM program is “more than paying for itself.”

[1] https://www.edf.org/methane-other-important-greenhouse-gas
[2] Moser, Claire, Nidhi Thakar, and Matt Lee-Ashley. “Reducing Methane Pollution from Fossil-Fuel Production on America’s Public Lands.” Center for American Progress. Oct. 2014. Pp 2.
[3] Frankenberg, Christian, Andrew K. Thorpe, David R. Thompson et al. “Airborne methane remote measurements reveal heavytail flux distribution in Four Corners region.” Proceedings of the National Academy of Sciences. August 2016.
[4] Lyon, David R., Ramone A. Alvarez, Daniel Zavala-Araiza, et al., “Aerial Surveys of Elevated Hydrocarbon Emissions from Oil and Gas Production Sites.” Environmental Science and Technology. April 2016. http://pubs.acs.org/doi/abs/10.1021/acs.est.6b00705
[5] ICF International for Environmental Defense Fund. “Economic Analysis of Methane Emission Reduction Opportunities in the U.S. Onshore Oil and Natural Gas Industries.” March 2014. Pp 1-1. https://www.edf.org/sites/default/files/methane_cost_curve_report.pdf.

This guest column by Jon Goldstein, with the Environmental Defense Fund, provides an excellent look at the BLM’s methane rules in advance of two hearings this week in North Dakota and Colorado.

You Can’t Argue With Math: BLM’s Methane Rules Enjoy Strong and Diverse Support

By Jon Goldstein | Bio | Published: February 26, 2016

These numbers don’t lie. They represent the strong support new methane waste and pollution reduction rules from the Department of Interior’s Bureau of Land Management enjoy across the west. Methane is a potent climate pollutant and the main constituent of natural gas, so when oil and gas companies on public land allow  methane to be leaked, burned or vented to the atmosphere, it not only impacts air quality and our climate, it also represents an economic loss to taxpayers.

Here’s how this math adds up to a win for taxpayers, public health and the climate.

Two (or Three) are Better Than One

Last week the BLM kicked off its public comment process for important new rules designed to limit methane waste from oil and gas operations on Federal and Tribal lands.  The agency held hearings in Farmington, New Mexico and Oklahoma City seeking input from the public on the proposal. Despite the fact that both New Mexico and Oklahoma  are in the heart of oil and gas country, comments in support of these new rules outweighed opposing viewpoints by significant margins in both locations. More than twice as many concerned citizens in Farmington and three times as many in Oklahoma City testified in support of BLM taking action on methane.

At these hearings, Latino and Tribal voices joined public health professionals, veterans, taxpayer groups, andenvironmental advocates in voicing strong support for the BLM proposal. Last week, 40 current and former local elected officials representing diverse constituencies from across New Mexico also issued a letter in support of strong BLM methane rules.

Supporters out-commenting the opposition two- and three- to-one in the oil and gas patch, and dozens of elected officials endorsing sensible rules in a major oil and gas producing state are indicative of the strong, broad and diverse support that BLM’s proposal is garnering across the West. It’s not surprising then that a recent poll found that a bipartisan majority (fully 80 percent) of Westerners support commonsense rules to cut oil and gas waste on BLM managed lands.

A big reason for this support: Westerners understand that wasting our natural gas through venting, flaring and leaks not only pollutes our air and damages our climate; it shortchanges taxpayers by millions of dollars each year. BLM doesn’t collect royalty payments on natural gas that escapes to the atmosphere before being sold; therefore local communities lose out on funding that could have gone to better schools, roads and other needed infrastructure. In fact, according to a recent report, taxpayers could lose out on $800 million over the next decade as a result of the wasteful venting and flaring of natural gas.

Next Up

BLM’s proposal is a strong step toward better management of our energy resources. But there’s room for improvement especially to provisions that could and should require oil and gas companies to inspect sites for methane leaks on at least a quarterly basis as leading states require.

While some are asking for more delays, we think the time to act is now. Join us in getting the strongest possible BLM methane rule across the finish line by filing comments before the BLM deadline on April 8 and offering public testimony at the BLM’s final two public hearings in Lakewood, CO on March 1 and Dickinson, ND on March 3^rd. We’ll be there, joining the fight for better climate protections, reduced waste, and cleaner air.

The Wyoming Outdoor Council has worked for more than two years to reduce flaring and venting at oil wells in Wyoming. Now, as the state prepares to vote on long-awaited revisions to its rules governing these practices, we need your help.

As a reminder, flaring is the burning of natural gas at oil wells and venting is the release of raw methane and other gases into the atmosphere. Both activities waste a non-renewable resource and deny revenue to the state and taxpayers. Flaring and venting also emit harmful greenhouse gases.

The Wyoming Oil and Gas Conservation Commission recently released a proposed draft of its revised flaring rule. While the proposal includes some improvements, it doesn’t go far enough.

Consider that in 2014, enough natural gas was flared or vented in our state to heat more than 45,000 Wyoming homes for a full year. In 2015, that number grew to more than 62,000 homes.* Consider, too, that most of the flaring and venting that took place in Wyoming last year was not even reviewed by regulators because it happened at wells that fall below an arbitrary production threshold. Anything less than this arbitrary amount (60,000 cubic feet of vented or flared natural gas per well, per day) is currently considered non-wasteful by the state and doesn’t require a permit.

Some flaring, of course, is necessary, especially when it’s done for workers’ safety during drilling. But that’s a determination the state should be making for all cases of flaring and venting. The fact is that much flaring—and the vast majority of venting—can and should be eliminated. With better planning at the permitting stage, for instance, operators could capture non-renewable natural gas instead of burning it, and avoid many cases of venting altogether.

This is a growing problem the state has the power to solve. Here’s how you can help.

If you can, attend the upcoming public meeting in Casper.

• Ask the state to prohibit venting entirely. It’s dirty and dangerous. Operators who must vent small amounts for technical reasons could still receive an exemption.
• Ask the state to ensure the safety of workers and people nearby with minimum air quality control requirements for flares.
• Ask the state to require a permit for any and all flared natural gas.
• Ask the state to require operators to provide economic justification in their flaring application for delays in gas infrastructure connection.

When: 5-7 p.m. Thursday, February 4, 2016
Where: Office of the State Oil and Gas Supervisor, 2211 King Blvd., Casper, Wyoming

*Information on flared and vented volumes obtained from the OGCC, Wyoming household energy use obtained from the Energy Information Administration, and number of households in Wyoming from the U.S. Census Bureau.

FOR IMMEDIATE RELEASE

Media Contacts:
Kelsey Robinson, (512) 691-3404, krobinson@edf.org
Chris Merrill, (307) 349-7288, chris@wyomingoutdoorcouncil.org 

Proposed Wyoming Flaring Rule Needs Improvements to Prevent Waste, Protect Clean Air

Proposed rule changes improve data collection and planning practices, but more can be done to reduce waste and air pollution

CASPER — The Wyoming Oil and Gas Conservation Commission announced proposed revisions to the state’s flaring rules on Tuesday. While the text of the proposal has not yet been released, a description of its provisions by WOGCC Supervisor Mark Watson revealed both important deficiencies and important progress.

“This proposal contains some good improvements, including better data reporting and a requirement that operators submit a gas capture plan with their application for a permit to flare,” said Amber Wilson, environmental quality advocate for the Wyoming Outdoor Council. “But we also urge the commission to ensure that flaring and venting are reduced as much as possible.”

“We look forward to reviewing the proposal once it is available,” said Jon Goldstein, Senior Energy Policy Manager at Environmental Defense Fund.  “We are encouraged that WOGCC is addressing this serious problem.  However, we are concerned that the proposal will not go far enough to curb the venting and flaring of natural gas in Wyoming.”

The proposal, as described by Supervisor Watson, does not include a prohibition on venting, which is the intentional release of natural gas to the atmosphere. It also lacks any requirement that operators demonstrate an economic justification for venting or flaring.

Venting of gas directly to the atmosphere poses serious environmental risks and both venting and flaring are wasteful practices that needlessly deplete an important domestic energy resource. The new proposal places few new restrictions on venting or flaring — other than lowering the threshold under which venting would be allowed to 30,000 cubic feet per day.

“One major improvement to this proposal would be to eliminate all unpermitted flaring in Wyoming,” Wilson said. “As currently drafted, companies can flare up to 60,000 cubic feet of natural gas per day without ever having to get a permit.”

Venting of natural gas is flatly prohibited in some states such as North Dakota. Furthermore, flared and vented natural gas represents the waste of a valuable natural resource. According to a recent report from ICF International, due to venting, flaring and equipment leaks, Wyoming wasted more than $42 million worth of gas in 2013 on federal and tribal lands alone. According to a report from Western Values Project, if captured and sent to market, this would have brought an additional $88 million in federal royalty payments to Wyoming since 2009.

“Our goal should be to eliminate venting altogether,” said Jon Goldstein, senior policy manager at Environmental Defense Fund. “It’s both wasteful and unnecessary. Not only is vented gas and associated air pollution bad for local air quality, it also represents a waste of a valuable natural resource, depriving the state of needed revenue at a crucial time. And operators who are flaring natural gas should, at the very least, offer an explanation to the state and to royalty owners as to why they are wasting this valuable resource.”

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Wyoming Outdoor Council (wyomingoutdoorcouncil.org), the state’s oldest independent conservation organization. We’ve worked to protect Wyoming’s environment and quality of life for future generations since 1967.