Lessons from Aliso Canyon, Part II

Leaks in Regulation

 

Today, Southern California Gas announced it has successfully and permanently stopped the methane leak at its Aliso Canyon storage site. This marks the (fingers-crossed) end of a multi-month environmental crisis in northwest Los Angeles, causing residents to move and schools to close. Earlier this month, I blogged about the possible lessons we could learn from the methane leak at the Aliso Canyon natural gas storage facility about California’s regulation of the oil and gas sector and the institutional enforcement structure. In this blog post, I will focus on what we may learn from Aliso Canyon about California’s current climate change agenda and regulations, and by extension, those of the U.S.

California has the most ambitious and far-reaching GHG emissions trading system in the country, but even this scheme does not encompass the methane being released into the atmosphere at Aliso Canyon. Although methane is one of the greenhouse gases included in California’s cap-and-trade system, only certain sources of emissions are covered. For underground storage facilities, operators have a compliance obligation (i.e. must hold allowances) for the emissions from the combustion or flaring of any gas at the facility, equipment and pipeline blowdowns, and venting from certain equipment. The leak at Aliso Canyon is actually coming up through the ground around the well due to a corroded pipe far below the surface. Since this is not included in the short list of non-combustion emission sources for which underground storage operators must hold allowances, SoCal Gas will not have an obligation to procure allowances on the market for the 2.3 MMTCO2e emitted by the Aliso Canyon facility leak. It will be able to meet its emissions cap despite causing a release equal to almost 13% of the oil and gas sector’s annual methane emissions, and records of the cap-and-trade system will not give any indication that this leak occurred.

That is worrisome. This is California – the most progressive, ambitious state when it comes to environmental issues, especially climate change. Our Cap-and-Trade system is hailed as the broadest in history, covering more categories of economic activity than even the European Trading System. Yet it is not designed to address the fugitive emissions that are responsible for most of the methane released by oil and gas activities. CARB intends to create targeted emission reduction programs to capture these and other emission sources not included in the cap-and-trade system, but the regulatory process takes time, and that is one thing we are very short on when it comes to climate change. If California, historically the first state to act on environmental issues, doesn’t have methane regulations in effect until 2017 (if not later), other states will surely not follow suit for many years to come. Considering methane’s global warming potency, this would be very bad news for the climate.

The Aliso Canyon leak is only one example of this. Abandoned oil and gas wells also emit methane, and California has a long history of oil and gas development. The California Energy Commission estimates that there are tens to hundreds of thousands of abandoned wells in California alone, and many of these are “lost” – they were developed before regulations requiring meticulous record-keeping, and there are no records of their existence. Perhaps this, in combination with the great uncertainty as to how much methane any given well actually emits, is why ARB did not even include an estimate of these emissions in the statewide GHG Inventory. And if California’s GHG Inventory doesn’t accurately reflect its real emissions, how can it claim a specific reduction in those emissions?

Of course, this is perhaps asking too much. California, along with the EPA and most countries in the world, is taking on a monumental task in trying to measure the various gases its residents, industries, and animals emit into the air. No such inventory is going to be completely comprehensive or exact, nor do we have the time for such demanding perfectionism even if it were possible. What we need is an inventory that captures, as accurately as possible, the major sources of GHGs and their proportionate contribution to total emissions, so that we can make informed policy decisions about what reductions will have the most impact. That being said, if we neglect entire categories of emissions, such as abandoned wells, we might skew the emissions portfolio and miss opportunities for easy reductions.

States are not the only players that need to address these issues. In March 2014, the White House released the latest piece of its Climate Action Plan – its Strategy to Reduce Methane Emissions. The strategy outlines several planned actions to reduce methane emissions, both at home and abroad, including reducing fugitive emissions from the oil and gas sector and from coal mines. This summer, on August 18, 2015, EPA followed through on this strategy when it released proposed regulations of new and modified sources in the oil and natural gas industry. The proposed regulation updates the 2012 New Source Performance Standard (NSPS) that set standards under the Clean Air Act for volatile organic chemicals (VOCs). The 2015 proposed amendment would add standards from methane emissions and would also apply these standards to emissions sources the 2012 rule did not cover: completion of hydraulically fractured oil wells, pneumatic pumps, and certain equipment used at natural gas transmission compressor stations and storage facilities, and, notably, equipment leaks (fugitive emissions).

These are very important additions to the NSPS for oil and gas, but they will only apply to new or significantly modified facilities. As noted in my last blog post, the wells and pipes most vulnerable to leaks are the oldest ones, like the one at Aliso Canyon. Although it stopped short of issuing methane emission standards for existing sources, EPA did new guidelines for states to determine the “reasonably available control technology” (RACT), the emission standard for sources in nonattainment areas, for VOCs in ozone nonattainment areas. Many of these technologies also reduce methane emissions, so EPA is indirectly requiring methane reductions at existing sources. But these guidelines do not require the maintenance and repair of aging infrastructure, the only thing that would have prevented Aliso Canyon. And from an initial review of the new source standards, those also only require repair and replacement of equipment after a leak is detected. Not all repairs will take four months, but as those of us in Los Angeles just saw, it only takes one to cause a crisis.

Reader Comments

6 Replies to “Lessons from Aliso Canyon, Part II”

  1. Dear Sarah Duffy,
    All of the methane released at Aliso Canyon has drifted away. The wind mixed and dispersed it all over the world. The climate never noticed, it was not effected nor will it ever be. Mother Earth used it to nourish the environment. Some of it may be here in Texas, who knows, who cares, our weather is good, no complaints.

    Maybe you can persuade SoCal, the taxpayers, or someone else to give you a grant, fund your research, pay your salary, pay a fine, settle a lawsuit or do something to ameliorate your feelings. Our climate does not care one way or the other. Hillary cares and so does Burney (but not much). Obama doesn’t care, why should he? The methane is gone and the climate is fine.

  2. From the unofficial electronic version of the Regulation for the Mandatory Reporting of Greenhouse Gas Emissions, page 206 (CARB):

    (f) For underground natural gas storage, the operator must report CO2, CH4, and N2O
    from the following sources:
    (1) Metered natural gas pneumatic device and pump venting;
    (2) Non-metered natural gas pneumatic device venting;
    (3) Equipment and pipeline blowdowns;
    (4) Flare stack or other destruction device emissions;
    (5) Centrifugal compressor rod packing venting;
    (6) Reciprocating compressor venting; and
    (7) Equipment leaks from valves, connectors, open ended lines, pressure relief
    valves, and meters.

    As Sarah notes, it does not look like the regulation includes leaks from well casing or well tubing, and the well did not even have subsurface safety valve, as it was removed many years ago.

    Concerning the other comment on this excellent article, methane rises into the stratosphere where it absorbs and re-emits heat that has been previously radiated by the Earth. One pound of methane traps and re-emits heat 86 times as intensely as does one pound of carbon dioxide using a twenty year time interval (20 year methane GWP). That is documented fact.

    1. Todd said;
      “….. One pound of methane traps and re-emits heat 86 times as intensely as does one pound of carbon dioxide….”

      Dear Todd,
      One pound of water vapor traps and re-emits energy over 1000 times as intensely as methane plus carbon dioxide combined. Most climate kooks completely ignore water vapor and would have us believe that water vapor has no effect on the global climate. Why not regulate human caused water vapor emissions?

        1. Dear Professor Hecht,
          Thanks for posting the article. It appears that some climate modelers construct a rather dubious model which characterizes carbon dioxide as somehow “forcing” while water vapor is treated as “feedback.” The distinction is political and it doesn’t matter, the climate does not care.

          Solar radiation is “forcing” and water vapor is the primary atmospheric gas that causes the earth’s greenhouse effect because water undergoes phase changes which trap and release enormous amounts energy. Carbon dioxide does not change phase in the atmosphere, it is a trace gas and its contribution to warming is also trace and insignificant.

  3. In reply to BQRQ concerning water vapor, I quote from page 666 and page 667 of Chapter 8, IPCC AR5 (2013)

    “As the largest contributor to the natural greenhouse effect, water vapour plays an essential role in the Earth’s
    climate. However, the amount of water vapour in the atmosphere is controlled mostly by air temperature, rather
    than by emissions. For that reason, scientists consider it a feedback agent, rather than a forcing to climate change.
    Anthropogenic emissions of water vapour through irrigation or power plant cooling have a negligible impact on
    the global climate . . . Currently, water vapour has the largest greenhouse effect in the Earth’s atmosphere. However, other greenhouse gases, primarily CO2, are necessary to sustain the presence of water vapour in the atmosphere. Indeed, if these other gases were removed from the atmosphere, its temperature would drop sufficiently to induce a decrease of water vapour, leading to a runaway drop of the greenhouse effect that would plunge the Earth into a frozen state. So greenhouse gases other than water vapour provide the temperature structure that sustains current levels of atmospheric water vapour. Therefore, although CO2 is the main anthropogenic control knob on climate, water vapour is a strong and fast feedback that amplifies any initial forcing by a typical factor between two and three. Water vapour is not a significant initial forcing, but is nevertheless a fundamental agent of climate change.”

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About Sarah

Sarah Duffy

Sarah Duffy is a Shapiro Fellow in Environmental Law and Policy at UCLA School of Law. Her research interests include water conservation, state-level climate change poli…

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