More people are talking today about oil and gas methane “leaks,” and that’s great! But, it’s essential to know the difference between a methane leak, intentional release, and an emission event. When a tsunami is coming, no one says there is a seawater leak headed for the coast. Firefighters don’t fight wildfires with a leaky faucet. What we have is a climate-wrecking oil and gas methane tsunami that is made up of leaks, intentional releases, and emission events.
Natural gas is methane, an odorless, invisible gas that has a global warming potential (GWP) of 86 compared to carbon dioxide’s GWP of 1. I explained GWP and how stopping the methane would slow climate change back in 2015, and even before.
Optical gas imaging (OGI) makes visible the invisible hydrocarbon gases, including methane, coming from oil and gas facilities. The above image of a blowdown at the Enterprise Carlsbad Compressor Station demonstrates how OGI works.
The optical gas imaging instrument I use is a FLIR GasFind 320 camera, and I’ve been an ITC certified thermographer for over five years.
I’m still learning. Below are some things I’ve learned.
Leaks
A Matador Production facility leak on state lands in New Mexico
Leaks can often be fixed reasonably easily, sometimes with a wrench. But typically the fixes are only temporary. A gas under pressure will find the pathway of least resistance. Most sites will have several leaks. I recently visited a model site that was used to demonstrate how cleanly oil and gas can operate, so the best they can do. I found two substantial leaks, and it was only a small site. The oil and gas system design is deeply flawed to encourage leaks.
Intentional venting
Energy Transfer Hoban Gin Compressor Station venting from the tank vent,
thief hatch, and small topless tank in the foreground.
Venting is an intentional release of methane by design to prevent overpressurization. I have learned in conversations with industry and regulators that technology does not yet exist to stop venting. I once thought vapor recovery solved venting, but sites with vapor recovery equipment still vent. I’m still learning.
As seen in the image above, hydrocarbon gases, including methane, are venting from the pipe that sticks up. Tank venting is designed to occur only when pressure builds up in the tanks. Valves, sometimes called Enardo Valves, are designed to hold the hydrocarbon gases in until the pressure builds up. The valves wear out and fail, allowing endless venting if not replaced. I first visited the above Energy Transfer facility in October 2016, and I visit it regularly–six or more times each year. It is consistently venting. I have reported these conditions to the Texas Commission on Environmental Quality (TCEQ), providing video as evidence many times, but they take no action.
I recently learned that thief hatches are also considered a pressure release device–tank vents are not enough. Thief hatches sit on top of the tanks and can be opened to test the tank liquids and levels. The hatches get corroded and if not replaced will always leak like the worn out tank valves. In the image above, the thief hatch is venting, always.
The small tank in the foreground has no lid and no vent. I supposed it’s grandfathered in under some long ago rule.
Even if they find and fix all the leaks and keep them fixed, there will still be venting.
Emission events and accidents
Apache Corp. Cheyenne Central Processing Facility during an emission event
According to Apache, this was an accidental release that happened due to some equipment failure that was not their fault. I documented this event over the three days I was in the area, but it could have lasted longer. These emission events do not count against the facilities emission inventory, and if the cause is not neglect, there is no violation.
TCEQ has a searchable Air Emission Event Report Database where operators are “required” to report emission events. I don’t know what it means that the Apache event above never showed up in the database.
An unlit flare could be an emission event. When the flame goes out, a flare vents hydrocarbon gases until someone re-lites it.
Primexx Red Unit unlit flare
Some operators cannot keep their flares lit, creating a methane tsunami, especially in the Permian and Eagle Ford Basins. I documented the Primexx Armstrong lease from March 2017 through August 2018, and the flare was unlit each time I visited. The TCEQ took no action on the complaints I made. On my last visit to Reeves County, I inspected about 33 sites and found more unlit flares than lit ones.
After documenting an unlit Apache Corp. flare for four days, I spoke with someone in operations and asked why they weren’t checking the site. They rely on the pumpers to check the site, but they don’t have OGI cameras so can’t tell if a flare is lit or unlit. If no one knows it needs to be lit, no one is likely to lite it for days or weeks or months. I have documented this!
Maintenance startups and shutdowns are also emission events. The facility empties all the hydrocarbon gases into the air aka “blowdown” so the facility can be maintained or repaired.
Enterprise Carlsbad Compressor Station Blowdown
Some of the emissions from maintenance startups and shutdowns could be captured. But even if they fix all the leaks and keep them fixed, and invent some way to stop all the venting, there will still be emission events.
How much methane is it or…
Feel like playing Russian Roulette with the future?
The industry likes to downplay my findings by saying an OGI camera cannot tell how much is emitting. That’s true. But, using the example I gave earlier, I can tell the difference between what’s happening at the Matador site, which is a badly leaking faucet, and the Apache release, which is somewhere beyond a firehose.
Scientists like to duel about methane emissions comparing industry supplied estimates to measurements taken in a one-time study here and there. The result is always a need for more studies.
The industry promises to do better, and some major players have even called for strict regulations. “Hurt me, beat me, make me write hot checks, and contain my methane.”
Oil and gas facilities are spread far and wide across the U.S. in urban areas and rural areas. Current regulation is almost entirely voluntary. Adequate regulation of this industry would require building a regulatory framework that has never before existed. It would take many years and vast amounts of tax dollars to create. It’s far too late to start building an oil and gas regulatory system.
If we figure out exactly how much methane is emitting, stop the leaking, intentional releases, and emission events, and build an adequate oil and gas regulatory system, it still creates carbon dioxide when burned.
Stop the oil and gas methane tsunami that is devastating our climate! KeepItInTheGround
About Sharon Wilson
Sharon Wilson is considered a leading citizen expert on the impacts of shale oil and gas extraction. She is the go-to person whether it’s top EPA officials from D.C., national and international news networks, or residents facing the shock of eminent domain and the devastating environmental effects of natural gas development in their backyards.
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Deena Walker says
Thanks Sharon for keeping us educated and informed. Knowledge is power.
John Young says
EPA told TCEQ to air emissions related to plant/operation/facility startup, shutdown, and malfunction (SSM) events. TCEQ refused.
Now EPA Region 6 wants to defund the regulation and penalizing of unacceptable air emissions related to SSM events.
The deadline for submitting comments opposing this was 06-28-2019. To see the 04-29-2019 Federal Register posting on this proposed rule change, go to https://www.environmentallawandpolicy.com/wp-content/uploads/sites/452/2019/05/Region-6-SSM-SIP-Call-Withdrawal-for-Texas-Proposed-Rule.pdf
Recently the EPA official in charge of air quality was forced to resign. Someone who moved from TCEQ to EPA Region 6 has replaced him.
Now “E.P.A. Plans to Curtail the Ability of Communities to Oppose Pollution Permits,” Coral Davenport, 07-12-2019, The New York Times, https://www.nytimes.com/2019/07/12/climate/epa-community-pollution-appeal.html?fbclid=IwAR0roLObDfP09Av2xYeI_xri0gqcuVQQBY7ostJWGtWhSct3HMUyzHGV-wo
See “Extended: PHMSA LNG by rail car exception until 2019-08-07 on 2019-07-09,” WWALS Watershed Coalition, 07-09-2019, http://wwals.net/2019/07/09/extended-phmsa-lng-by-rail-car-exception-until-2019-08-07-on-2019-07-09/?fbclid=IwAR3-T2rdfSm_Z9bmlnkc6nYL0HiW_vMutqubsKmq8JDPvOPyO7hxApx1NTo Also see http://wwals.net/2019/07/05/phmsa-lng-by-rail-car-exception-2019-06-06/
See the Federal Register posting about the deadline extension to 08-07-2019 at https://www.govinfo.gov/content/pkg/FR-2019-07-09/pdf/2019-14532.pdf
See the regulations.gov “PHMSA-2019-0100” page at https://www.regulations.gov/searchResults?rpp=25&po=0&s=PHMSA-2019-0100&fp=true&ns=true. So far, there have been 1,131 comments.
To post a comment, go to: https://www.regulations.gov/comment?D=PHMSA-2019-0100-0002
Check out SAVE RGV from LNG’s website at http://www.savergvfromlng.com/ and Facebook page at https://www.facebook.com/saveRGVfromLNG/.
Check out SAVE RGV from LNG’s website at http://www.savergvfromlng.com/ and Facebook page at https://www.facebook.com/saveRGVfromLNG/.
Select... says
Is it just methane being released? We know there are dangerous chemicals l ike benezene – are those other dangerous chemicals being leaked as well?
TXsharon says
Yeah, all kinds of bad chemicals are released with the methane.
Lửa Rồng says
Thanks Sharon for keeping us educated and informed. Knowledge is power.