EPA's Fracking Rules

    Jeff Johnson has an article entitled, "EPA Issues Fracking Rules", in the April 23 issue of Chemical and Engineering News.
    Fracking is an improved technique of recovering natural gas from underground deposits. The previous technique was to drill into an underground reservoir, similar to oil drilling, and then pipe natural gas to the surface. In time, the production from that particular well decreased. The fracking technique involves pumping water into a gas well at high pressure. This breaks up the underground structure and releases significantly more gas to be pumped to the surface. The use of fracking techniques have increased availability of natural gas, which has decreased its price to about one half.
    `The environmental groups, Wild Earth Guardians and San Juan Citizens Alliance, sued EPA to issue regulations controlling air contaminating emissions from the fracking wells. Given the previously observed ideology and regulatory track record of the EPA, it may be a willing partner to the suit.
    In a separate article, it was stated that more than a year ago, a court order required EPA to issue final air regulations for oil and gas drilling under the Clean Air Act. The EPA issued its regulations on April 18 of this year. The new regulations require fracking operations to install equipment by January 2015. The new equipment must reduce emissions of ozone-producing volatile organic compounds (VOCs) and hazardous air pollutants, such as benzene and hexane. There is no mention in the C&E News article concerning the VOC emission from each well. However, there is mention that the equipment will automatically reduce emission of methane to the atmosphere, which EPA indicates is a noxious greenhouse gas 20 times more potent than carbon dioxide.
    Although I don't know the details of the court order, I consider the EPA order to be the EPA's usual overreach. The EPA has no business telling the natural gas production industry how to run its business. The EPA is a regulatory body set up to implement laws passed by Congress. The EPA is supposed to set limits on production emissions, which have been shown to be detrimental to health. In other words, the EPA can decide what emissions should be controlled and amounts allowable to the atmosphere. It must be left to industry to decide how that can be accomplished. Of course, the EPA must have some idea of practicality, so as not to set impossible limits.
    The basis of Jeff Johnson's article is the emission of  VOCs by natural gas producers from fracking operations. However, whether fracking or traditional production, the same considerations involving VOCs are involved. A little consideration on natural gas processing is in order.
    Natural gas contains variable amounts of VOCs, in addition to the major constituent methane, as it comes from the well. Well gas is always almost processed to remove VOCs, which generally have a higher value per pound than methane. There are basically two processes to remove VOCs. It is not clear how much VOCs are still contained in each of the treated gases, which are then known as pipeline gas, but the likelihood is that it is very low. One process extracts the VOCs in a tower using an oil which dissolves the VOCs. The loaded oil is then heated to remove the VOCs, which are collected, and may be separated into further components by distillation. The second process involves cooling the total well gas to a level where the VOCs condense as liquids, which are then separated from the remaining methane. Again, the mixed VOCs may be separated into components by distillation.
    Since EPA's regulation of April 18 first mentioned ozone, we will now take a look at that.
    Ground level ozone is not emitted directly into the air, but is created by chemical reactions between oxides of nitrogen (NOx) and volatile organic compounds (VOC) in the presence of sunlight. Emissions from industrial facilities and electric utilities, motor vehicle exhaust, gasoline vapors, and chemical solvents are some of the major sources of NOx and VOC.
    The detrimental health effects of breathing ozone contaminated air are respiratory compromise and increased tendency to leukemia. Mortality effects have been noticed at 60 parts per billion. The EPA has set a limit of 75 parts per billion.
    It is apparent from the chemical reaction generating ozone that its decrease could be accomplished by limiting the availability of the reactants NOx and VOCs. However, the source of these substances is so ubiquitous that no simple solution of control is available. The only way to do this is by broad brush. We could start with further study of the chemical reaction to determine ozone yields, when considering individual VOCs.
    In 2009, the EPA standard for NOx in air was 58 parts per billion, which was the national average at the time. Whether that's a good number or not is conjectural, but with all the sources of NOx emission, it would seem almost impossible to get a good handle on this. Perhaps we can be more successful in controlling the second reactant generating ozone; namely VOCs.
    Some typical VOCs are acetone, benzene, ethylene glycol, formaldehyde, methylene chloride, perchloroethylene, toluene, xylene, and 1,3-butadiene, but there are many more. Again, it seems almost impossible to establish a concentration limit in air for each VOC.   
    The best approach might be to look at the problem on a global scale, starting with the fact that the total weight of Earth's atmosphere is estimated at 1.2 E19 pounds. However, dangerous ozone exists only at the ground level and an estimate would have to be made on the weight of the global atmosphere at some arbitrary elevation. Another difficulty would be in assuming that only the US is responsible for VOC generation. However, an estimate could be made on US contribution. From there, and a better understanding of the capability of each VOC to produce ozone, the total globally allowable quantity of each VOC could be calculated and divided among the generators as a "maximum allowable weight".
    The EPA's April 18 regulation also covers specific hazardous chemicals, unrelated to ozone generation. One of these as benzene, which can be considered separately.
    OSHA recommends that workers use special breathing equipment when the benzene content of the air is 100 ppb. From that we can likely assume that a permissible concentration in the air may be one part per billion. It is probable that benzene vapor mixes completely with the atmosphere, and we could use total weight of the atmosphere and calculate a permissible weight of benzene. This can then be divided as allowable among various emitters.
    From most of the above, it is apparent that a limited benzene allocation could be assigned to each emitter. This could be done by a quantity to each type of emitter, such as natural gas frackers, or even to an individual fracker. The calculations would be extensive, but the mathematics is simple and the EPA has lots of people and computers to easily accomplish this task.
    Using the same technique and a more developed understanding of the chemical equation, the EPA could then go on to calculate category limits for NOx and VOCs generators.
    Lastly, the EPA's April 18 regulation mentions reducing methane emissions as a favorable aspect related to installation of emission control equipment. However, the whole purpose of gas drilling is to obtain methane, and it is likely that every driller will make a reasonable effort to control methane loss. In addition, we have separately shown that methane is not likely a significant greenhouse gas in the atmosphere, because of its very low concentration. See "Debunking Global Warming Theory" in http://arthur-climatecontrol.blogspot.com.


References:
    1. Read more at Suite101: Weight of Earth's Atmosphere: Gravity, Force, and Pressure in Fluids & the Power of Physics | Suite101.com http://suite101.com/article/weight-of-earths-atmosphere-a56021#ixzz1xyN0uBUW
    2. http://www.naturalgas.org/naturalgas/processing_ng.asp#oil