This is a useful and important project that shows that
natural gas can be developed and produced responsibly and without harmful air
emissions. Industry improvements over the past 15 years have led to very significant
reductions in air pollution and greenhouse gas emissions from well sites and
production facilities. This is in addition to the air pollution benefits of
replacing coal power plants with natural gas power plants.
CNX announced
its radical transparency project at a well pad in Pennsylvania in November
2023. It was attended by Governor Shapiro. CNX CEO Nick Deiuliis described the
project at the time:
·
We will monitor air, water, waste, and
methane in and around our operations.
·
We will open source this data for all to see
in real time.
·
And the Pennsylvania Department of
Environmental Protection (PA DEP) will also share custody of this data to
provide further transparency and confidence to the public in its reliability.
The goal of the project is to increase transparency,
radically, and to encourage others in the industry to do the same. I agree with
his goal to reduce the speculation, rhetoric, and sensational headlines that
suggest without significant data for backup that the natural gas industry is causing
great environmental harm. That is not to say there is no environmental harm, but there is
far less than is often perceived and that such headlines suggest. CNX’s Chief
Risk Officer Hayley Scott thinks it could allay some of the concerns leading to
proposals for unreasonable setback distances for natural gas operations:
“This data should put to bed the calls for increased
setbacks between gas sites and buildings, which based on the proposed buffer
zones of 2,500 feet, would be a de facto ban on natural gas drilling.”
The project shares data directly with the PADEP and with
the public without altering it first. It is considered to be a collaboration
between CNX, PADEP, and the public. The data are collected by an independent and
accredited third party and CNX gets that data at the same time the PADEP and
the public do. The project provides continuous monitoring data for air quality,
waste monitoring, and water quality. Air monitoring data include data for
particulate matter (PM 2.5), Benzene, Toluene, Ethylbenzene, and Xylene (or
“BTEX compounds”). Data is gathered within 500 ft of the wellbores to ensure it
is representative of the air quality near the wellbores. Other data gathered
include chemical additives, water quality, radiation, and methane leaks
detected.
According to
Scott, initial results include:
·
PM2.5 concentrations were (i) below NAAQS
levels at all sites and (ii) well below levels observed within regional urban
environments.
·
Measured concentrations of BTEX are well
below minimum risk levels at all sites.
Currently, as
of August 2024, CNX is reporting air quality monitoring at 11 active
unconventional gas well pads and two compressor stations. That is expected to
grow and encompass all of CNX’s unconventional operations in time.
Scott points
out that past investigations and studies of health effects near well sites were
flawed and did not assess pollution from other sources which are very
significant in the area that has lots of power plants and industry. Studies
found some correlation but could prove no causation, although the headlines
strongly (and wrongly) suggested otherwise.
The project
goals and methodologies are given in more detail below:
In the arena of Air Quality:
·
For any unconventional gas wells or
compressor stations, continuous monitoring of PM2.5 concentrations and
continuous collection of air samples for VOC analysis for characterizing
long-term average concentrations during all phases of well pad development and
well production, including six months of monitoring during the production
phase.
·
Data collected is being shared publicly in
real time on our company website at CNX Radical TransparencyTM
·
All data is collected by and reviewed for
quality assurance by a qualified third party, Clean Air Engineering, whose
activities are governed by their Ambient Monitoring Quality Management Plan
(QMP), which details their quality control program for ambient air quality
monitoring services. The QMP was audited by the United States Environmental
Protection Agency (EPA) in 2017, and the company was approved for the operation
of State and Local Air Monitoring Stations (SLAMS) as a Primary Quality
Assurance Organization. All data is provided unabridged directly to the
Pennsylvania Department of Environmental Protection (DEP) and to CNX Resources.
In the arena of Water Monitoring:
·
Expanded pre-drill water survey for private
residential drinking water supplies (wells and springs) to within 2,500 ft of a
vertical unconventional well bore, centralized large volume storage tank
battery, or centralized impoundment.
·
The pre-drill survey includes at least four
samples taken seasonally/quarterly ahead of drilling activity to obtain a more
comprehensive understanding of groundwater quality ahead of natural gas
activity. While private well/spring owners are not required to participate in
this groundwater survey, those who do will be provided with copies of all
analyses within 10 days of the receipt of the results by the operator and may
elect to include their results anonymously in a broader public database.
·
After well turn-in-line, at least four
samples taken seasonally/quarterly are collected on private wells/springs to
compare to pre-drill conditions, with the same election options for including
in a broader public database.
·
In addition to the pre- and post-drill
samples, operators collect similar pre- and post-drill seasonal upgradient and
downgradient samples of the nearest streams receiving surface run-off.
In the arena of Chemicals:
·
Disclosure to the public of chemicals
anticipated to be utilized during drilling and fracking ahead of operations,
including chemicals used in mixtures protected as trade secrets.
In the arena of Waste:
·
Publish Comprehensive Radiation Protection
Plans and the results of the program’s annual self-assessment including any
unanticipated action items resulting from findings. Provide transparent reporting
of test results.
The graphs below show some of the results.
In her conclusions/summary Scott makes the following
comment:
“The results show that there have been no increases of
any significance of PM2.5 or BTEX at these sites during any phase of
development. There are no exceedances of the NAAQS or BTEX levels near the
minimum risk levels at the sites (and emissions concentrations reduce with
distance due to dispersion). There is no indication that air emissions from
natural gas operations have an impact on human health in the over 101,000 data
points that we have collected to date.”
Indeed, this
is good news. Concerns about poor air quality around well sites should be generally
put to rest. It was a false alarm for the most part. However, many of these
improvements have come more recently with less diesel and more natural gas and
electricity being used to power well site activities including drilling and
hydraulic fracturing. Other air monitoring studies around well sites, such as
those provided by Range Resources, also showed little to no concerns about air
pollution. Other studies in the West where many vertical wells are operated
near each other and where weather inversions are more common such as in the DJ
Basin area of Colorado, have shown elevated levels of VOCs and one of their
results – ground-level ozone. This is likely attributable to the use of diesel fuel
as well as to leaks that can be fixed.
While I really
like this CNX project I am more ambivalent about their CEO. He seems to be an
intellectual Trumpist with strong views about things, some extreme IMO. He has
developed an Appalachia First campaign that obviously references Trump’s
America First campaign (the KKK had an America First campaign too). I have read
parts of his book, ‘The Leech’, where he divides people into those that produce
and enable and those that have other societal functions, some of whom are
referred to as leeches, presumably by sucking the lifeblood of society through
their work. I found that rather distasteful, incorrect, demeaning, and arrogant
of him to do. I also see his LinkedIn posts (that others comment on or like)
about the insanity of climate policies. I sometimes agree with him but not
always. He expresses a lot of views in his book, podcast interviews with him,
and his posts. In his book, he refers to teachers’ unions (and by proxy teachers
themselves) as leeches. Since both of my parents were teachers, I found this pretty
offensive. He also seems to put environmental regulators in that category, but they
are helping to assure a clearly agreed upon public good, environmental
protection. The administrative state may be ubiquitous and tedious, but they
are also needed, to ensure that public good. Like teachers, they are not burdens
on society but enablers to use his terminology. To suggest otherwise is
nonsense. His views on the ‘energy transition’ are on the Trumpist side as
well, seemingly advocating for clean energy subsidies to be abandoned and other
comments. Again, I do agree with some of his musings but others I find out of
step or just bunk.
References:
Initial
Results are in: Radical Public-Private Collaboration Demonstrating CNX Natural
Gas Development Poses No Public Health Risks. CNX. August 14, 2024. Positive
Energy Hub. Initial
Results are in: Radical Public-Private Collaboration Demonstrating CNX Natural
Gas Development Poses No Public Health Risks (positiveenergyhub.com)
Radical
Transparency: Making History Once Again. CNX. Positive Energy Hub. November 2, 2023.
Radical
Transparency: Making History Once Again (positiveenergyhub.com)
Shining
a Light with Radical Transparency. CNX. Positive Energy Hub. November 9, 2023. Shining
a Light with Radical Transparency (positiveenergyhub.com)
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