My email dialogue with Lepore

I sent an email to new COGCC Executive Director Matthew Lepore. I thought he had left the EAB meeting (9/6) before public comments. My mistake. He did stay. I’m glad he heard the public comments and I’m glad I emailed him. So it all worked out. We had an interesting email dialogue. I didn’t include my initial email to him here. It was essentially an explanation of the situation with Bill Barrett’s flare stacks and my objections, plus the text of my public comment.

I did add that I believe the state is charged with larger responsibility that has been laid out in Colorado’s Oil and Gas Conservation Act:

§34-60-106 – The COGCC has the authority to regulate “Oil and gas operations so as to prevent and mitigate significant adverse environmental impacts on any air, water, soil, or biological resource resulting from oil and gas operations to the extent necessary to protect public health, safety, and welfare, including protection of the environment and wildlife resources, taking into consideration cost-effectiveness and technical feasibility.” (§34-60-106(2)(d))

Here is Lepore’s reply and the email exchange that followed:

Dear Ms. Tibbetts:

Thank you for your message and your kind words. I actually did hear your remarks during the public comments. As you know from my remarks, I believe improving our understanding of air emissions from oil and gas operations is one of the most important tasks facing COGCC, CDPHE, and the industry.  Garfield County’s commitment to fund a major study of air emissions is truly a landmark event, and I am please industry is cooperating both with significant funding and by providing access to their operations to facilitate the study.

Flaring methane and other gases produced from a well is a long-standing industry practice. The byproducts of combusting methane are carbon dioxide and water.  Hydrogen sulfide, if present in the gas being flared, would be converted to sulfur dioxide during combustion. In this regard, the byproducts of flaring are not dissimilar from vehicle emissions. Flaring typically occurs for a relatively short period of time early in a well’s life cycle, either because the well has begun producing before a gas line has been connected to the site, or because during early production the well produces a large volume of condensate and produced water that cannot easily be captured and contained.  A similar situation occurs following a workover or re-stimulation of a well.  The COGCC encourages companies to capture these gas streams rather than flare them, but capture is not required absolutely required in all cases. BBC’s operations at the site in question are governed by COGCC Rule 805.b.(3), which specifies limited circumstances under which gas may be flared. Based on his investigation of your complaint, Mr. Kellerby determined that BBC is in compliance with Rule 805.b.(3). Mr. Kellerby’s personal gas monitor indicated no presence of methane or hydrogen sulfide in the air on site.

As you likely are aware, flaring is used in other industries, including refining and coal mining. In our modern industrial society, there are numerous sources of chemical emissions to the air – landfills emit methane; vehicle emit an array of pollutants; coal-fired plants are major sources of air pollutants, including mercury, and ozone precursors.  We simply do not live in a zero-emissions, pollution-free world. Happily, our understanding of pollution sources and the means of reducing them have evolved tremendously in the past 40  years or so, and will continue to do so. At the same time, while striving toward a “pollution free” environment is a laudable goal, I believe the cost of achieving such a thing – assuming it is even possible to do so – must be weighed against the benefits. For example, we could drastically reduce air pollution by restricting private vehicle miles driven; yet few of us seem willing to put our cars in storage and ride a bike, walk, or take public transportation. Of course, for huge numbers of us, doing so would require us to relocate or find a job much closer to home, if possible. In short, while incremental steps certainly are achievable, there are real and significant barriers to large scale change in this arena. To use another analogy, reducing city speed limits to 10 mph would almost certainly reduce vehicle accidents and associated injury, death, and property damage. Yet city officials allow higher speeds for the sake of efficiency.

I have attached two recent articles I find interesting and would recommend to you. The first concerns the risks associated with radiation released from the Fukushima reactors.  Although specific to radiation, I think the risk and causation principles discussed are relevant to industrial emissions as well. The second article is by Nature Conservancy scientist and describes his vision for the modern conservation movement.

I would be interested in reviewing any specific data, information, or studies that form the basis of your belief that Barrett’s flares are severely impacting your air quality.

I appreciate your engagement with these issues.

Sincerely,

Matthew Lepore
Director
Colorado Oil and Gas Conservation Commission

********************

Dear Mr. Lepore,

Thank you for your response to my email. I was not aware you stayed for public comments so I appreciate you clearing that up for me.

Regarding the CSU study: it will not address public health impacts, the oil & gas industry will likely choose which sites to monitor, and the results won’t be published until 2015.

In your email you mentioned two recent articles, one about Fukushima radiation, and another from the Nature Conservancy. You forgot to attach them to your email. When you have a moment, please do send them to me. I am interested in reading them.

Included below is an article from E&E News, about a new study in Texas regarding high emissions from compressor stations and flares, which I believe adds much substance to my claim (though I am not alone in this regard) about the impacts on air quality from BBC’s flare stacks.

Thank you,
Peggy Tibbetts
Silt, CO

AIR POLLUTION: Study sees big potential problems from gas processing facilities  (Thursday, September 6, 2012)
By Gayathri Vaidyanathan, E&E reporter

Emissions from natural gas compressor stations and flares may be contributing significant amounts of ground-level ozone and formaldehyde in the Dallas-Fort Worth area, according to a new study.

The area, which overlies the gas-rich Barnett Shale, historically has exceeded the federal standard of 75 parts per billion of ozone, or smog, averaged over eight hours. If a city exceeds the standard by as little as 2 ppb, U.S. EPA may increase regulation, costing industry millions of dollars in additional controls. Even then, achieving the ozone standard could be a difficult task, possibly requiring controls on everything from lawn mowers to cement kilns.

Against this scenario, the new study has found that a single natural gas processing facility in the Barnett could add as much as 3 ppb to the hourly average ambient ozone. The emissions would mostly be from compressor engines that pump gas along pipelines. Flaring, a practice in which excess gas is burned off, could add even more ozone, but further downwind from the source. The study was published last month in the Journal of the Air & Waste Management Association.

If a single processing facility could have such a large impact, many such oil and gas facilities together may contribute several parts per billion of ozone, even averaged over eight hours as in the federal standard.

The study also found potential high levels of formaldehyde emitted near compressors and flares. The chemical has short-term health effects including nosebleeds, vomiting and skin irritation and contributes to ozone formation in the long term.

“The study calls attention specifically to large compressor engines and flares as potentially problematic from an ozone and hazardous air pollutant (formaldehyde) standpoint,” wrote Eduardo Olaguer, author of the study and a senior research scientist at the Houston Advanced Research Center (HARC), in an email.

The study concludes that there need to be better regulation and recording of emissions from compressors and flares in places with a booming petrochemical industry.

Olaguer recommends that operators take care to reduce emissions during maintenance, startup and shutdown of engines and other equipment.

Methodology

Measuring and controlling ozone in nonattainment areas such as Dallas can be complicated for regulators, especially in regions with high oil and gas activity. Officials rely on computer models to identify the facilities emitting large amounts of ozone precursors such as nitrogen oxides (NOx) and volatile organic compounds. Those, if controlled, would yield significant ozone reductions.

But the models cannot differentiate between emitters located within 4 kilometers of each other. Regulatory decisions based on these coarse models can have errors, especially in evaluating how efficiently controls are working. And the models are too coarse to study ozone created close to sources such as compressors and flares.

Olaguer’s computer model is more fine-grained, able to measure at 200 meters resolution, enough to say with certainty that flares and compressor engines may be significant contributors to the ozone problem. The model was cross-checked through a real-world test in Houston, which confirmed that the model works accurately.

But since there are no high-resolution data available in the Barnett Shale, as a compromise for the high-resolution, the model can be only hypothetical. The study, therefore, looked at a hypothetical natural gas processing facility located in the Barnett. Olaguer fed in data from earlier studies that had roughly estimated measured concentrations of ozone precursors emitted by the equipment. Using the information, the model estimated the amount of hourly averaged ozone that would be generated within 2 kilometers of the hypothetical facility at 3 ppb.

********************

Thank you, Peggy.  I realized I hit send before attaching the articles!  Here they are.

The Panic Over Fukushima

Conservation in the Anthropocene: Beyond Solitude and Fragility

I will read the E&E article. I was disappointed to learn the results of the CSU study will not be finalized until 2015. I am hopeful CSU and CDPHE will control the design and implementation of the study. I understand they will monitor emissions from all phases of drilling and completion, with an emphasis on the completion phase (flowing back the well, etc.). I sincerely hope it will produce a good data set.

Best regards,
Matt

*******************

Ms. Tibbetts:

I read the article E&E article. My take away is we need to remain vigilant, keep our antennae up, and gather more data. Like many articles appearing these days, this one is filled with qualitative language: flares may be contributing significant amounts; a natural gas facility could add as much as 3 ppb . . . mostly from compressor engines; potential high levels of formaldehyde . . . Also, note that the study is based on a computer model of a hypothetical gas processing plant. Computer modeling can be an important, but it is also only as good as the assumptions (inputs) used by the modeler. Finally, if I understand correctly, the BBC facility you are concerned about is a gas production well site, not a processing facility. The compressor engines referenced in the study, for example, would not normally be present at a well site.

Best regards,
Matt

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4 Comments on “My email dialogue with Lepore”

  1. Carl Mc Williams Says:

    WOW! This Matthew Lepore fellow is a real piece of work. One can only imagine how very carefully Lepore was selected to become the new Executive Director of the COLORADO OIL & GAS CONSERVATION COMMISSION (COGCC). The COGCC is a “Captured Agency” and in my layman’s opinion the COGCC would never stand Constitutional muster if legally challenged in federal district court.

    That said, in this Peggy TIbbet’s Blog, Attorney Matthew Lepore wrote:

    “Flaring typically occurs for a relatively short period of time early in a well’s life cycle, either because the well has begun producing before a gas line has been connected to the site, or because during early production the well produces a large volume of condensate and produced water that cannot easily be captured and contained. A similar situation occurs following a workover or re-stimulation of a well.”

    This statement is quite misleading and absent of truth and common sense as I will explain below:

    Attorney Mathew Lepore wrote: “Flaring typically occurs….because the well has begun producing before a gas line has been connected to the site”.

    Carl Mc Williams responds: “If the well is ‘producing’ CH4 (methane) that is clean enough to be sold “downline”, but a gas line is needed to transfer the CH4 from the well site to the natural gas marketplace, simply close the main valve on the wellhead, (known as “shutting the well in”) and wait for the gas line to be connected. Why burn up all that valuable natural gas, while also making everyone in the local neighborhood very uneasy as the residents hear the deafening noise of a flaring tower and see night sky aflame from the flaring of valuable natural gas? Furthermore, flaring operations are labor intensive costs to the drilling companies bottom line. Obviously, if the gas that is burning in the flaring is clean CH4 and does not contain any hazardous gases that cannot be sold “downline”, then instead of flaring valuable CH4, the correct and more profitable procedure would be to simply close the main valve on the wellhead (‘”shut the well in”) and wait for the well site to be connected, by pipeline, to ‘sales’ .”

    Attorney Mathew Lepore also wrote: “Flaring typically occurs….. because during early production the well produces a large volume of condensate and produced water that cannot easily be captured and contained.”

    Carl Mc Williams responds: “Condensate” is oil & water combined, and; “Produced water” is coal bed H2O that has risen to the earth’s surface through the well because of the drilling into the coal bed below. On each well site there are two large “production tanks” located immediately adjacent to each other. At the top of these two tanks is a large (4 “) pipe that connects the two tanks together. Between the well and the two production tanks is a gas separator that separates, by gravity, the gas from the well, from the liquid from the well, (the condensate and the produced water”). Once the gas and water are separated by the separator, the gas is piped to “sales” and the condensate-water is piped to the first production tank.

    After the gas and liquid separation; the oil in the condensate is worth a lot of money ($90.00 + barrel) thus the economic incentive for the two production tanks to be located side-by-side: Because oil is lighter than water, as the first production tanks is filled from the well, the oil stays on top of the water. Once the oil portion of the condensate (oil on top of the water) is filled to the 4″ connecting pipe, (at the top of the two production tanks), the oil spills into the empty second production tank. Thus the drilling company now has pure oil in the second tank. Then a water hauler truck, under the supervision of the drilling company’s “pumper”, loads the “oil-free-water” from the first tank into his water hauler trailer for travel from the well site to an injection well somewhere else. And the “pure oil” in the second production tank, under the supervision of the drilling company’s “pumper”, is loaded into an oil hauler’s trailer-tank and taken to a refinery in Denver or Utah and sold for $90.00 barrel. If the gas (at the gravity separator), from the well is clean enough to be sold “downline”, , the gas is directed into the “sales” pipeline infrastructure.

    Therefore, Attorney Lepore’s written statement does not make economic sense and the unfortunate conclusion is that we are not being told all the truth. I assert that the gas that is being flared contains much more than methane. And the byproduct (exhaust) of the flarings contain more than “carbon dioxide and water” as Attorney Lepore alludes. I suggest there is only one possibility for the drilling companies to go to the expense of flaring a well:

    Immediately after fracking a well, the resultant gas that reaches the surface is a “VOLATILE ORGANIC COMPOUND” (VOC) which is a compound of methane and also contains the deadly byproducts of the fracking fluids. As these deadly byproducts within the VOC’s cannot be “sold downline”, the cheapest way to remove these “VOC’s” from the well is to burn them with the methane as the combustible agent. Once the gas is clean of the deadly VOC’s the flarings will cease.

    In closing Carl Mc Williams states: If the flaring of the wells are only producing carbon dioxide and water as Attorney Lepore states, then the Garfield County Commissioners are planning on spending $1 Million in tax payer money on a COLORADO STATE UNIVERSITY “Air Quality Study” that is moot before the study begins. To reiterate, if the new Director of the COGCC is correct, in that the natural gas well flarings only emit carbon dioxide and water into the air we breathe, then GARCO COMMISSIONERS MIKE SAMSON, JOHN MARTIN AND TOM JANKOVSKY are spending $1 Million of tax-payer money on a CSU “Air Quality Study” that is predetermined by the Director of the COGCC to be moot.

    The $1.7 Million will fund COLORADO STATE UNIVERSITY and a privately owned consulting company, AIR RESOURCE SPECIALISTS, to detect and measure airborne emissions from Garfield County natural gas wells, potentially proliferating deadly and carcinogenic airborne emissions containing such hazardous materials as H2S, benzene, toluene, ethylbenzene, xylenes, volatile hydrocarbons and other VOC’s (HAZMAT). Obviously, because the HAZMAT study is funded in part by the very industry whose HAZMAT airborne emissions are to be measured, in a CSU collaboration with a private consulting firm who normally works for the natural gas drilling industry; the work conducted by COLORADO STATE UNIVERSITY will not be acceptable for publication within the scientific journals, because of the obvious, inherent and blatant financial conflicts of interest. [NOTE: Quite frankly, I find this “joined-at-the-hip-arrangement” to be tasteless and I am shocked that the good name of COLORADO STATE UNIVERSITY would stoop to these low levels of soiling and compromising the international integrity of CSU within the global scientific community!!!]

    What is needed is an “Air Monitoring Study” that is solely tax-payer funded and at a complete arm’s-length-distance from the natural gas industry. The present GARCO CSU study is replete with inherent financial conflicts of interest in that the natural gas industry is also co-funding the study. To strongly reiterate, from a scientific perspective the CSU-GARFIELD COUNTY “Air Monitoring Study”- will never be accepted for publication within the scientific journals because of the blatant and obvious financial conflicts of interest.

    The real pisser is that the COGCC, the Garfield County Commissioners and the oil & gas industry think We the People are ignorant peasants, (aka sheeple)

    Carl Mc Williams

  2. Peggy Tibbetts Says:

    Thank you Carl. I lack your knowledge and expertise on the technical stuff so it was impossible for me to explain what a load of bullshit he was feeding us. I’m glad you did.

  3. Jeanne Huyser Says:

    I join in thanking Carl McWilliams for explaining the process in detail and in a way that we, laymen, can understand. This just adds fuel to the critical need to elect a BOCC that will exact absolute accountability and compliance from the gas and oil industry. We cannot continue with the same old “good old boys club” who are seemingly giving away our land, along with our water and air quality.

  4. Barb Coddington Says:

    Thanks Carl. Will try to spread your knowledge of the process to others.

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