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Reaction to EPA's Standards of Performance for New, Reconstructed, and Modified Sources and Emission

I am commenting on the proposed revised rules on methane as a retired physician, retired pediatric anesthesiologist, grandparent and graduate of the Masters program at the School of Public Health in the University of Pittsburgh. I am strongly in favor of much stricter rules, so that methane leaks can be eliminated. When methane leaks from a well, storage tank, pipeline, pneumatic pump, compressor station or any other structure that is part of the transfer of natural gas to where it will be burned, explosion from high concentrations of methane is not the only health risk. Many toxic compounds travel with methane. These include volatile organic compounds (VOC), radioactive particles, fine particulate matter (PM 2.5) and other hazardous substances. Using data from Pennsylvania between 2009 and 2017, Clark, et. al. (https://doi.org/10.1289/EHP11092) showed that proximity of residence to a fracking well is directly related to risk of acute lymphoblastic leukemia (ALL) in children. Children whose mothers lived within 1.2 miles of a fracking well before their birth, had twice the risk of ALL as those who lived much further away. ALL is associated with exposure to benzene, a VOC, that is spilled when methane leaks.


Of course, increased incidence of malignancies, is not the only health risk associated with proximity to industrial sites that leak methane. Before malignancies develop, air pollution from the creation and function of wells causes upper and lower airway disease, injuries to developing fetuses, neurologic impairment in general as well as increased incidence of autism and neurodegenerative diseases, and more cardiovascular disease. Ozone, produced by hazardous substances leaked from fracking wells, causes permanent lung injury, although the initial effects are easily overlooked. These environmental pulmonary injuries increase risk from infectious lung diseases, such as COVID-19 and influenza. These crippling conditions affect people of all ages and shorten life expectancy by many years, at least one decade.


I assisted in the medical care and chronic pain management of many children who were diagnosed with diseases associated with exposure to the toxins noted above. Prevention, that is reduced exposure to these toxins, is much better than attempting to cure or palliate these diseases.


Communities must be empowered to collect data and obtain relief. This has to happen on the federal level, because for example, some states, of which Pennsylvania is one, may recognize a settlement proposed by judicial ruling for water rendered poisonous by fracking, and later renege, allowing fracking to continue too close to residences and failing to provide clean water to replace what was damaged. The same basic idea applies to methane leaks because the presence of a leak irrevocably damages health of people living nearby. The leak must not be ignored by local authorities. The leak must be stopped as quickly as possible and the health of the community affected must be documented. To attempt to provide justice in such a situation, the adverse health outcomes documented in the following years should be acknowledged by the industry causing the leak and compensation made for associated costs to individuals. Greater bonds must be demanded for every new well drilled. This may be outside the scope of the current proposal for methane regulation, but it is not outside the scope of the injuries caused by lack of such regulation.


I agree that it is necessary to prevent leaks from abandoned and unplugged wells by requiring documentation that well sites are properly closed and plugged before monitoring is allowed to end. Because many wells, in Pennsylvania at least, may continue to leak methane so long after they have been abandoned that their location has been lost, there should be a program developed and funded to find these wells using sensors on drones or satellites.


I agree with setting a zero-emissions standard for methane at pneumatic pumps at affected facilities in all segments of the industry. But there should be no exceptions for sites without access to electricity. It should be mandated that such sites install solar panels and batteries to provide adequate electricity to run pumps that do not emit methane. This is a serious public health issue that must not be impacted by costs to industry. Because one third of the warming of the Earth that is producing the Climate Crisis is due to human-caused emissions of methane, rapid cuts in methane emissions could have a near-term beneficial effect on climate. This opportunity must not be lost. Increasing temperatures on Earth produce a host of adverse health effects. This is already happening and therefore methane leaks must be reduced as quickly as possible at as many locations as possible.


For similar reasons, I agree that owners/operators of oil wells with associated gas must be required to implement alternatives to flaring the gas. There must be no excuses for technical or safety reasons. Such a well must undergo detailed analysis to demonstrate the harm that is expected to occur if it is capped permanently. I propose that when evidence is found that such harm would be great, that is justification for denying any new permits to drill in that geographic area in the future. Perhaps the area should be defined by a 50 mile radius, but this should be subject to more detailed assessment by professional geologists. If the Department of Environmental Resources in any state does not adhere to this rule, that Department should be found negligent in it duties and its leaders replaced rapidly.


I am encouraged by the proposals to examine wells of all sizes and ages for methane emissions and to develop a transparent program to identify and address Super Emitters of methane, etc. This program should be given highest priority status so that it can be developed and made functional very quickly.

I am concerned that allowing flaring under exceptional conditions will encourage this practice. If flaring would be allowed only if the owner or operator submits a certified demonstration that a sales line is not available and that other beneficial uses are not feasible for technical or safety reasons, the size or volume of each flare should also be documented and permits for new wells in this geographic area must be denied until beneficial uses for the flared products are developed. There must be no excuse for continued flaring.


Thank you for the opportunity to register my opinions about these new rules designed to reduce methane pollution.


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