The Gas Well Task Force, despite the best efforts of some of its members, was insufficiently creative. They did not do enough to generate new ideas to modernize Denton’s drilling and production ordinance. A majority bloc on the Task Force did not want more regulations. They offered little of their own ideas and attacked and stonewalled those presented by others. What I called an ‘uneasy alliance' around the general idea of ‘best practices’ fell apart.Once the public phase of the Task Force’s work was completed in March, the ensuing legal and scientific review was not going to add anything new. Its job was to inquire into the ‘defensibility’ of whatever stock of ideas the voting members of the Task Force advanced.
This lack of creativity is evident in the draft ordinance. Much has been left out. The DAG is currently compiling a list of missing pieces, drawing from many sources, including the original DAG report from December, 2011 and the minority report from Ms. Oppenheim and Dr. La Point.There is another crucial source that never received a mention by the Task Force. It is the EPA’s Natural Gas Star Program, which outlines dozens of “Recommended Technologies and Best Practices” for capturing methane and other emissions.
Why was there no discussion of mandating these practices and technologies? This is especially troubling given the real possibility here for common ground -- they are, after all, already recognized by the industry as potential money-saving tactics. These are practices that all promise quick returns on investment due to their ability to capture methane (i.e., money) that would otherwise be vented and lost. Had Task Force members considered these best practices, they might have created more ideas capable of advancing common interests.
Here are just ten ideas from that site:
· Replace wet seals with dry seals in centrifugal compressors (to reduce leaks)
· Use zero emissions dehydrators (to capture gas normally emitted)
· Install flash tank separators in glycol dehydrators (to capture gas normally emitted)
· Convert pneumatics to mechanical controls (to prevent leaks)
· Recover gas during condensate loading (to prevent losses when loading trucks)
· Install pressurized storage of condensate (to prevent flashing of methane, VOCs, and HAPS)
· Install excess flow valves (to shut off gas in case of pipeline break)
· Connect vapor recovery units to casing where there is casinghead gas (to capture gas in annular space between casing and tubing)
· Install plunger lift systems (to reduce emissions during operations to remove liquids that have reduced the flow of gas – an alternative to traditional ways of blowing down the well)
· Utilize reduced emission completions (RECs) or green completions for new wells and workovers (capturing emissions and fluids that initially flow at such high rates/volumes that standard equipment cannot capture it – so typically vented, dumped into pit, flared).
From what I have seen thus far, it looks like only the last of these is included in the new ordinance (see 188.8.131.52e). That is an important step, for sure, but clearly more could have been done to incorporate ideas from this list into Denton’s ordinance.
This further confirms for me that we need to subject the ordinance to greater scrutiny – including an alternative expert review process. Our citizens and elected leaders need to know what the range of possible alternatives is for regulating shale gas development. So far, our official advisory process has not been up to that task.