The US Chamber of Commerce petitioned the US Environmental Protection Agency to correct assumptions EPA has used to develop greenhouse gas requirements for natural gas producers since 2010.
The EPA used a well completion emissions factor of 9,175 Mcf/completion, which the Chamber calls an overestimate.
In a Dec. 19 filing, the Chamber said the EPA estimate was based on unverified information from a limited number of wells regarding gas captured by green completions and gas emitted from nongreen completions obtained through Natural Gas Star Program.
“No one had addressed this issue in this way,” Ross Eisenberg, the Chamber’s environment and energy counsel, told OGJ on Dec. 21. “The Information Quality Act requires information developed for regulations to be reasonably correct. We wanted to ask EPA to correct information in this case that was flat-out wrong.”
The Chamber cited an IHS CERA report, “Mismeasuring Methane: Estimating Greenhouse Gas Emissions from Upstream Natural Gas Development,” and the petition said methodology used by EPA’s Climate Change division was flawed.
The petition also said that URS Corp. conducted a survey of seven producers’ shale gas well completions and emissions, which provided data on 1,200 wells.
The survey found actual GHG emissions from the wells’ completions were more than 1,200% lower than EPA’s estimate, that green completions were used on 92% of the wells, and that gas from 55% of the non-green completion wells was flared instead of vented.
The Chamber’s petition sought a correction from EPA within 90 days, or a notice, explanation, and estimated completion date if more time is required.
Contact Nick Snow at firstname.lastname@example.org.