Department of energy office of fossil energy
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37 increased production will come from shale gas, 13 percent from tight gas, and 8 percent from coalbed sources. 137 Sierra Club states that air pollution is emitted during all stages of natural gas production. Sierra Club claims that natural gas production operations emit methane (CH4), volatile organic compounds (VOCs), nitrogen oxides (NOx), sulfur dioxide (SO 2 ), hydrogen sulfide, particulate matter (PM), and significant quantities of hazardous air pollutants (HAPs) that contribute to cancer risks and other acute public health problems. 138 Sierra Club asserts that methane is the dominant pollutant from the oil and gas sector, and that EPA has identified natural gas systems as the largest contributor to anthropogenic methane emissions in the United States. Sierra Club argues that methane is a potent greenhouse gas that substantially contributes to global climate change. Sierra Club states that the natural gas industry is also a major source of VOCs and NOx. Sierra Club asserts that, as a result of significant VOC and NOx emissions associated with oil and gas development, numerous areas of the country with heavy concentrations of drilling are now suffering from serious ozone problems. Sierra Club identifies the Dallas-Fort Worth area in Texas, the Wyoming Upper Green River Basin, and the Uintah Basin in Northeastern Utah in particular as ozone non-attainment areas where there is a significant concentration of oil and gas production activities. As another example, Sierra Club states that, in 2008, the Colorado Department of Public Health and Environment concluded that the smog-forming emissions from oil and gas operations exceeded vehicle emissions for the entire state. According to Sierra Club, significant development in the San Juan Basin in southeastern Colorado and northwestern New Mexico, in combination with several coal-fired power plants in the vicinity, has caused serious 137 See id. at 32 n.85 (citing 2012 EIA Study at 11). 138 See Sierra Club Mot. at 32. 38 ozone pollution, which in turn has increased emergency room visits associated with high ozone levels. Sierra Club states that emissions from oil and natural gas development are also harming air quality in national parks and wilderness areas. Sierra Club asserts that as oil and gas development moves into new areas, particularly as a result of the boom in shale resources, ozone problems are likely to follow. Moreover, Sierra Club charges that VOCs are likely to be co- emitted with HAPs (such as benzene) which are carcinogenic and endocrine disrupters. 139 Sierra Club argues that oil and gas production also emits sulfur dioxide, primarily from natural gas processing plants, and that some natural gas in the United States contains hydrogen sulfide. Sierra Club reports that EPA has concluded that the potential for hydrogen sulfide emissions from the oil and gas industry is “significant.” 140 According to Sierra Club, hydrogen sulfide can be emitted during all stages of development, including exploration, extraction, treatment and storage, transportation, and refining. Sierra Club asserts that, although direct monitoring of hydrogen sulfide emissions is limited, there is evidence that these emissions may be substantial. Sierra Club states that people living near gas wells that have been exposed to hydrogen sulfide have reported eye, nose, and throat irritation, nose bleeds, dizziness, and headaches. Although hydrogen sulfide was originally included in the Clean Air Act’s list of hazardous air pollutants, Sierra Club acknowledges that it has since been removed from the list, but disputes that the removal was appropriate. 141 Sierra Club states that the oil and gas industry is also a major source of PM pollution, which is generated by heavy equipment used to move and level earth during well pad and road construction. According to Sierra Club, PM emissions from the oil and gas industry are leading 139 See id. at 38-41. 140 Id. at 43 (citation omitted). 141 See id. at 43 & n.152. 39 to significant pollution problems. For example, according to Sierra Club, monitors in Uintah and Duchesne Counties in Utah have repeatedly measured wintertime PM concentrations above federal standards. Sierra Club maintains that these elevated levels of PM have been linked to oil and gas activities in the Uinta Basin. 142 Focusing on Delfin LNG’s requested authorization, Sierra Club argues that the proposed Project will induce significant production-related air emissions. Specifically, Sierra Club asserts that Delfin LNG’s proposed exports will induce approximately 723.25 Bcf/yr of new natural gas demand, which will amount to 455.65 Bcf/yr in new natural gas production. Assuming a 1.0 percent leak rate, this new natural gas demand allegedly will be responsible for the incremental emission of 94,775 tons per year of methane, 13,828 tpy of VOCs, and 1,005 tpy of HAPs. 143 Next, Sierra Club states that increased natural gas production will transform the landscape of regions overlying shale gas plays, bringing industrialization to previously rural landscapes and significantly affecting ecosystems, plants, and animals. According to Sierra Club, land use disturbance associated with natural gas development impacts plants and animals through direct habitat loss (where land is cleared for natural gas uses) and indirect habitat loss (where adjacent land loses some of its important characteristics). 144 Sierra Club argues that natural gas production also poses risks to ground and surface water. Sierra Club notes that most of the increased production will involve hydraulic fracturing, a process of injecting various chemicals into gas-bearing formations at high pressures to fracture rock and release natural gas. According to Sierra Club, each step of this process presents a risk to water resources. Sierra Club states that hydraulic fracturing requires large quantities of water 142 See id. at 44. 143 See id. at 45 & Table 1. 144 See id. at 46. Yüklə 353,3 Kb. Dostları ilə paylaş:
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