em feature

Air Pollution Issues Associated

by Ramn A. Alvarez
and Elizabeth Paranhos

Ramn A. Alvarez, Ph.D.,

is with the Environmental
Defense Fund in Austin, TX.
Elizabeth Paranhos is with
Delonelaw Inc. in Boulder, CO.
E-mail: [email protected].

Exploration and production of natural gas and oil are rapidly expanding across the country due
to technological developments that have made extraction of previously untapped unconventional
resources, such as shale gas, economically feasible. In part due to expansion of operations to
locations where the industry has never been active, emissions of air pollutants, along with other
potential environmental and public health impacts, have come under increasing scrutiny.
An overview of environmental and public health
risks and the need for improved regulation and
industry practices is presented in a recent report of
the National Petroleum Council.1 Although some
efforts are underway to improve our knowledge
about air emissions from the oil and gas industry,
there remains much uncertainty about the actual
amount released. Notwithstanding this uncertainty,
studies suggest that emissions from the oil and gas
industry could be comparable to other major
source categories in some concentrated areas.
Moreover, while smokestack emissions of greenhouse gases (GHGs) from coal-fired power plants
are substantially higher than from natural gas (NG)fired plants, questions have been raised about how
the upstream emissions associated with the extraction, processing, and transportation of each fuel
affect the relative climate footprint of NG when the
complete fuel cycles are considered.
This article reviews key air pollution concerns and
air policy considerations associated with the gas
and oil industries.

Sources of Air Emissions

Leaks and routine venting during the extraction,
processing, and transportation of NG result in
emissions of GHGs and, depending on the local
composition of unprocessed gas, other pollutants
that contribute to locally- and regionally-elevated
air pollution that may threaten public health. There
are numerous individual components used throughout NG and oil production systems that are prone
to leaks, including compressors, valves, pumps,
flanges, gauges, and pipe connectors.
In addition to unintentional leaks, a number of
sources intentionally vent gas. For example, one
technology used throughout NG systems is pneumatic valves, which operate on pressurized NG
and by design bleed small quantities of gas during
normal operation. Additionally, gas is often vented
from storage tanks, dehydrators, depressurization
of equipment before maintenance, and wells after
hydraulic fracturing or when accumulated liquids
are removed. Within the oil sector, nearly all
methane (CH4) emissions come from production
fields in the form of venting from oil wells, storage
tanks, and processing equipment.2
Engines and other combustion sources associated
with the upstream and midstream segments of the

22 em june 2012

Copyright 2012 Air & Waste Management Association

awma.org

with Natural Gas and Oil Operations

NG and oil industry also produce emissions that
can affect local and regional air quality.

Air Pollution Concerns

The fugitive and vented emissions from NG operations consist predominantly of CH4, a potent
GHG, but often also include organic compounds
that contribute to the formation of ground-level
ozone (smog), as well as hazardous air pollutants
like benzene.
Methane
Methane is the principal component of NG and is
a potent GHG with a warming potential 25 times
that of carbon dioxide (CO2) over the long term
(100-year time horizon) and 72 times over the
short term (20-year time horizon). [Note: The values
of 25 and 72 are CH4s global warming potential
(GWP); GWP is a commonly used concept to compare the radiative forcing of GHGs relative to that
of CO2. The Intergovernmental Panel on Climate
Change (IPCC) typically uses a 100-year time
horizon for the calculation of GWP; but a 20-year
horizon is sometimes used.]
In addition to its climate impacts, CH4 contributes
to higher global background levels of ozone pollution.3-5 Natural gas and oil operations are the
largest source of U.S. CH4 emissions. The U.S.
Environmental Protection Agencys (EPA) estimate
of the amount of CH4 released in 2009 because of
leaks and venting in the NG network between
production wells and the local distribution network
is 10.5 million metric tons (MMT);6 this corresponds
to just over 2% of gross U.S. NG production. A

awma.org

recent paper based on a pilot study using innovative air sampling approaches concluded that NG
leakage in the DenverJulesburg Basin might be
even higher than EPAs estimate; although the
measurements provide only one snapshot of what
is happening in NG production fields, 4% was the
central estimate reported.7 This discrepancy points
to the need for more direct measurement of emissions, as discussed later.
Ozone Precursors
Natural gas and oil industry activities also emit
Volatile Organic Compounds (VOCs) and oxides
of nitrogen (NOx), which are precursors to groundlevel ozone. In areas of concentrated activity, the
emissions can be substantial.
For example, NG and oil activities were the single
largest source of ozone precursor pollutants in
Colorado in 2008.9 The Texas Commission on
Environmental Quality has reported that storage
tanks used in the exploration and production of
NG and oil are the single largest source of VOCs
in Texas.10 In the Barnett Shale of North Texas, the
combined VOC and NOx emissions from NG and oil
production have been estimated to be comparable
to those from the roughly 4 million cars and trucks
in the adjoining Dallas Fort-Worth metro area.11
The air quality impacts of these emissions vary
based on local conditions, but they can be important, especially in rural areas.12 Wintertime ozone
levels in excess of the nations health-based air
quality standards have been recorded in remote

Copyright 2012 Air & Waste Management Association

june 2012 em 23

parts of Wyoming and Utah, where little industrial

activity other than NG and oil production occurs.
Air modeling for the Haynesville Shale projects an
increase in ozone levels near NG drilling and production and in adjacent regions due to ozone
transport.13
Hazardous Air Pollutants
Hazardous air pollutants (HAPs) from NG and oil
operations include hydrogen sulfide and certain
hydrocarbons such as benzene, a known human
carcinogen. Formaldehyde is a HAP found in the
exhaust of compressor engines. Elevated levels of
benzene have been detected near NG production
sites in Texas14 and Colorado.15,16 In these cases,
ambient concentrations appear to be variable and
lower than health-based screening levels. Although
little work has been done to characterize the health
effects of such exposures, media reports anecdotally
suggest growing complaints of health concerns
(e.g., respiratory and skin irritation, neurological
problems, dizziness, and headaches) by people
living near NG operations.17,18

Policy Considerations
Methane Emissions
Although NG burns cleaner than coal and
petroleum- based fuels, uncombusted CH4 leaked
along the NG supply chain erases some of the
carbon advantage that NG has over other fossil
fuels at the point of combustion. At some point,
NG leakage can be large enough to make NG use
worse overall for climate for some period of time. A
number of scientific papers on the climatic implications
of NG production and use relative to other fuels
have been published in the past 18 months.19-24
These papers have inadvertently figured into a growing sense of confusion due to sometimes divergent
conclusions and approaches.

There are two main differences among these

papers. The first is how they compare the timedependent effects on climate of CH4 and CO2, the
principal contributor to man-made climate change.
CH4 is a much more potent GHG than CO2,
molecule for molecule, but it is removed from the
atmosphere much more quickly; these competing
effects complicate the comparison of their climate
impacts. The second, more fundamental difference
is the choice of CH4 leakage assumed for the NG
supply. This choice is challenging due to the limited
empirical data available on the actual amount of
CH 4 released to the atmosphere across the
NG supply chain, including during production,
processing, and delivery to customers.
A recent paper proposed a more transparent analytical approach that reveals the inherent climatic
trade-offs of different policy and investment choices
involving NG for electricity and transportation.25
Using the best available data from EPA on CH4
leakage in the NG supply and similar data for other
fuel cycles, this paper concluded that new NG combined cycle plants are beneficial on all time frames
for climate compared to new coal plants, as long as
leakage stays under 3.2%. On the other hand, for
NG vehicles to produce climate benefits on all
time frames, well-to-wheels CH4 leakage would
have to be reduced to 1.01.6%.26
Because of the pivotal role that NG leakage plays in
determining whether fuel switching scenarios
involving NG are better or worse for the climate, it
is critical that definitive, scientifically rigorous measurements of actual emissions be made. While NG
operators will begin reporting CH4 emissions to
EPA later this year, it is unclear how accurate these
data will be, especially during the first year or two
of reporting because companies have been allowed
a grace period to use less rigorous estimation methods than technically required in EPAs rules.

How Important Is CH4 Leakage from NG Systems?

Over a 100-year time horizon, EPAs estimate that NG systems emitted 10.5 MMT
of CH4 in 2009 has the same effect on climate as 263 MMT of CO2. For comparison,
263 MMT of CO2 is the same amount of CO2 that is released annually by 62 coalfired power plants or 52 million passenger vehicles.8 The cumulative climate influence (more specifically, the cumulative radiative forcing) of this CH4 leakage is 3.9%
of the total from all U.S. GHG emissions over a 100-year time horizon. Considering
a 20-year time-horizon, which more fully captures the short-term climate influence
of CH4, NG leakage accounts for 9.1% of the total climate influence from all U.S.
GHG emissions.

24 em june 2012

VOC and HAP Emissions

On April 17, 2012, EPA adopted final rules establishingfor the first timeemission standards for
NG well sites and strengthening existing standards
for gas processing plants and pipeline compressors.27
While EPAs rules represent an important step
forward in reducing pollution from hydraulically
fractured gas wells and discrete equipment types,
gaps remain. Additional standards are needed to
reduce VOC and HAP emissions from other

Copyright 2012 Air & Waste Management Association

awma.org

sources, such as wells that co-produce oil and NG

and certain existing sources, as are standards
that directly limit CH4.

reducing CH4 leakage, although more must be

done to reduce CH4 leaks directly.

Conclusion
EPAs rules will reduce air pollution through proven
and highly cost-effective air pollution controls; they
will standardize manycommon sensepractices and
technologies already implemented in states such
as Colorado and Wyoming, and that are already
being used by many NG companies throughout
the country. The rules will also prevent the needless
waste of a valuable domestic energy source by preventing leaks and venting of NG. Though EPAs
new rules do not directly regulate CH 4, it will be
reduced as a co-benefit of the required controls.
Consequently, EPAs rules will lead to some
improvement in the climate footprint of NG by

Achieving and maintaining low emissions of air

pollutants from NG and oil operations is crucial to
minimizing adverse health impacts in adjacent
communities and maximizing the climate benefits
of NG fuel switching pathways. Significant
progress (surpassing that expected through
implementation of EPAs new air emissions rules)
appears possible given the economic benefits of
capturing and selling lost NG and the availability of
proven technologies.28 Additionally, better emissions data are needed to confidently evaluate the
risks of NG and oil operations to health and
climate and to effectively manage operations. em

Though EPAs new

rules do not directly
regulate CH4, it will
be reduced as a
co-benefit of the
required controls.

References
1. Prudent Development: Realizing the Potential of North Americas Abundant Natural Gas and Oil Resources; National Petroleum Council, 2011;
available online at www.npc.org/Prudent_Development.html (accessed April 2011).
2. Addendum to U.S. Methane Emissions 1990-2020: 2001 Update for Inventories, Projections, and Opportunities for Reductions; U.S. Environmental
Protection Agency, 2004.
3. West, J.J.; Fiore, A.M.; Horowitz, L.W.; Mauzerall, D.L. Global Health Benefits of Mitigating Ozone Pollution with Methane Emission Controls;
Proc. Natl. Acad. Sci. USA 2006, 103, 3988.
4. Fiore, A.M.; Jacob, D.J.; Field, B.D.; Streets, D.G.; Fernandes, S.D.; Jang, C. Linking Ozone Pollution and Climate Change: The Case for Controlling
Methane; Geophys. Res. Lett. 2002, 29, 1919; doi:10.1029/2002GL015601.
5. West, J.J.; Fiore, A.M. Management of Tropospheric Ozone by Reducing Methane Emissions; Environ. Sci. Technol. 2005, 39, 4685.
6. Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990-2009; U.S. Environmental Protection Agency, 2011.
7. Ptron, G., et al. Hydrocarbon Emissions Characterization in the Colorado Front Range: A Pilot Study; J. Geophys. Res., 2012, 117, D04304;
doi:10.1029/2011JD016360.
8. EPA Greenhouse Gas Equivalencies Calculator. See www.epa.gov/cleanenergy/energy-resources/calculator.html.
9. Colorado Department of Public Health and Environment, Air Quality Control Commission; Regulation Number 7, Section XIX.K; available online
at www.cdphe.state.co.us/regulations/airregs/5CCR1001-9.pdf (accessed April 2012).
10. Texas Commission on Environmental Quality. See ftp://ftp.tceq.state.tx.us/pub/ChiefEngineer/AIR/SIP/misc/PIR%2310.05.28.09/kcauble/
OPA16747_Burnam.pdf.
11. Armendariz, A. Emissions from Natural Gas Production in the Barnett Shale Area and Opportunities for Cost-Effective Improvement. Report by Southern Methodist University, Dallas, TX, 2009; available online at www.edf.org/sites/default/files/9235_Barnett_Shale_Report.pdf (accessed April 2012).
12. Rodriguez, M.A.; Barna, M.G.; Moore T. Regional Impacts of Oil and Gas Development on Ozone Formation in the Western United States;
J. Air & Waste Manage. Assoc. 2009, 59, 1111; doi:10.3155/1047-3289.59.9.1111.
13. Kemball-Cook, S.; Bar-Ilan, A.; Grant, J.; Parker, L.; Jung, J.; Santamaria, W.; Mathews, J.; Yarwood, G. Ozone Impacts of Natural Gas Development
in the Haynesville Shale; Environ. Sci. Technol. 2010, 44, 9357.
14. Whitelet, T.; Doty, T. Barnett Shale Formation Area Monitoring Projects; Texas Commission on Environmental Quality, Mobile Monitoring Operations
Division, Austin, TX, 2009.
15. Goyal, R. Air Toxic Inhalation: Overview of Screening-Level Health Risk Assessment for Garfield County; Colorado Department of Public Health,
2008; available online at www.garfield-county.com/public-health/documents/Air%20Toxics%20Screening%20Level%20Risk%20Assesment
%20Presentation%206%2017%2008%20-%20Dr%20%20Raj%20Goyal.pdf (accessed April 2012).
16. Coons, T.; Walker, R. Community Health Risk Analysis of Oil and Gas Industry Impacts in Garfield County 2008; available online at www.garfield-county.com/
public-health/documents/1._COMMUNITY_HEALTH_RISK_ANALYSIS-(Complete_Report_16MB).pdf (accessed April 2012).
17. See for example, Shogren, C. Air Quality Concerns Threaten Natural Gass Image; National Public Radio, aired June 21, 2011; available online
at www.npr.org/2011/06/21/137197991/air-quality-concerns-threaten-natural-gas-image (accessed April 2012).
18. See for example, Olsen, E. Natural Gas and Polluted Air; New York Times, February 26, 2011, New York Times Video; available online at
http://video.nytimes.com/video/2011/02/26/us/100000000650773/natgas.html (accessed April 2012).
19. See for example, Howarth, R.W., Santoro, R.; Ingraffea, A. Methane and the Greenhouse Gas Footprint of Natural Gas from Shale Formations;
Climatic Change Lett. 2011, 106 (4), 679-690; doi:10.1007/s10584-011-0061-5.
20. See for example, Wigley T.M.L. Coal to Gas: The Influence of Methane Leakage; Climate Change 2011, 108 (3), 601-608; doi: 10.1007/s10584011-0217-3.
21. See for example, Venkatesh, A.; Jaramillo, P.; Griffin, W.M.; Matthews, H.S. Uncertainty in Life Cycle Greenhouse Gas Emissions from United
States Natural Gas End-Uses and Its Effects on Policy; Environ. Sci. Technol. 2011, 45, 8181-8189.
22. See for example, Cathles, L.M.; Brown, L.; Taam, M.; Hunter, A. A Commentary on The Greenhouse Gas Footprint of Natural Gas in Shale
Formations by R.W. Howarth, R. Santoro, and A. Ingraffea; Climate Change 2011; doi 10.1007/s10584-011-0333-0.
23. See for example, Burnham, A.; Han, J.; Clark, C.E.; Wang, M.; Dunn, J.B.; Palou-Rivera, I. Life-Cycle Greenhouse Gas Emissions of Shale Gas,
Natural Gas, Coal, and Petroleum; Environ. Sci. Technol. 2012, 46 (2), 619-627.
24. See for example, Myhrvold, N.P; Caldeira, K. Greenhouse Gases, Climate Change, and the Transition from Coal to Low-Carbon Electricity;
Environ. Res. Lett. 2012, 7 (1); doi:10.1088/1748-9326/7/1/014019.
25. Alvarez, R.A.; Pacala, S.W.; Winebrake, J.J.; Chameides, W.L.; Hamburg, S.P. Greater Focus Needed on Methane Leakage from Natural Gas
Infrastructure; Proc. Natl. Acad. Sci. USA 2012, 109 (17), 6435-6440; doi:10.1073/pnas.1202407109.
26. Well-to-wheels includes the CH4 emissions from vehicle refueling and use. 1.5% is for the comparison to gasoline cars; 1.0% is for diesel trucks; CH4
emissions would need to be cut by half and by 70% to immediately produce climate benefits in light duty cars and heavy-duty trucks, respectively.
27. New Source Performance Standards (NSPS) and National Emission Standards for Hazardous Air Pollutants (NESHAPS). See www.epa.gov/airquality/
oilandgas/pdfs/20120417fs.pdf (accessed April 2012).
28. EPAs Natural Gas STAR program shows many examples. See www.epa.gov/gasstar/tools/recommended.html (accessed April 2012).
awma.org

Copyright 2012 Air & Waste Management Association

june 2012 em 25