Natural gas is widely recognized as a clean-burning fossil fuel compared to other fossil fuels such as oil or coal with respect to greenhouse gas (GHG) emissions. Through our Marcellus and Utica Shale development and expansion of pipeline infrastructure in Appalachia, National Fuel has played a key role in increasing the availability and accessibility of clean-burning natural gas in the northeastern United States and eastern Canada. The increase in the use of natural gas for power generation and in manufacturing has been the primary driver of the country’s overall reduction in GHG emissions and improved energy reliability for the U.S. economy.
While natural gas has lower GHG emissions than other fossil fuels, the natural gas value chain can and does result in GHG emissions, including methane. National Fuel recognizes that we play an important role in reducing GHG emissions. That is why we continue to direct our efforts toward implementing best practices and technologies, investing in the modernization of our pipeline infrastructure and ensuring compliance with stringent federal and state regulations as the best ways to have a meaningful impact on reducing GHG emissions.
Consistent with many of our peers, we do not report GHG emissions reduction targets due to a number of factors. With frequent changes to baseline GHG reporting rules, the unique nature of our assets and operations and the variety of factors at play in evaluating our total GHG emissions, we choose instead to focus our efforts and resources on implementing day-to-day activities and processes that can generate continuous, daily improvements instead of a specific, extended reduction target. In that regard, National Fuel Gas Company and five of our subsidiaries that span all key sectors of the natural gas value chain participate in the U.S. Environmental Protection Agency’s (EPA) Natural Gas STAR Methane Challenge Program. This voluntary program within the energy industry is designed to provide a transparent platform for utilities, pipeline and storage companies, and energy producers to make, track and communicate commitments to reduce methane emissions.
The company’s exploration and production subsidiary, Seneca Resources, is focused on minimizing GHG emissions and other air criteria pollutants to be responsive to our stakeholders’ environmental concerns and reduce the risk for lost revenues.
Seneca Resources regularly reviews emissions management and monitoring protocols. Seneca Resources has implemented a number of initiatives, technologies and processes to ensure compliance with federal and state reporting regulations and continuously seeks out new ways to minimize GHG and other air emissions generated by operations. Such activities include:
Seneca Resources complies with all federal EPA Greenhouse Gas Reporting Program (GHGRP) reporting requirements for facilities that qualify under the regulations. Facility-level data is publicly available at the EPA’s Facility-Level Information on the Greenhouse Gases Tool (FLIGHT) website.
For Seneca Resources’ Marcellus and Utica Shale operations, Seneca Resources reports air and GHG emissions data, including methane, on an annual basis to the Pennsylvania Department of Environmental Protection (PaDEP), which is available on PaDEP’s Unconventional Natural Gas Emission Inventory. In 2018, Seneca Resources’ methane emissions represented 0.037% of the total Appalachian natural gas production for the calendar year.
Seneca Resources participates in The Environmental Partnership, a group organized by the American Petroleum Institute committed to improving the natural gas and oil industry’s environmental performance. The Environmental Partnership has developed three separate environmental performance programs for participating companies to implement and phase into their operations that began Jan. 1, 2018. These programs were selected based on EPA emissions data and are designed to reduce emissions of methane and volatile organic compounds (VOCs), using proven best practices and cost-effective technologies. Areas of focus include:
Since 2015, Seneca Resources has voluntarily participated in the EPA’s Natural Gas STAR Program, which is designed to provide oil and gas companies with a framework for implementing methane-reducing technologies and practices, and to document emission-reduction activities. As part of the program, Seneca Resources has committed to implement a number of best management practices for reducing methane emissions where feasible, often beyond regulatory requirements, and reports these methane reduction actions annually to the EPA.
Demonstrating commitment to responsible oil and gas development, Seneca Resources has voluntarily participated in the EPA’s Natural Gas STAR Methane Challenge Program since 2018. The Methane Challenge Program is voluntary and is focused on the reduction of methane emissions through the use of technology and/or process improvements. The program is structured to allow participation in different operational segments ranging from production through distribution. Seneca Resources has chosen to participate in the following operations segments: Onshore Production, Gathering and Boosting, and Natural Gas Processing. For each operational segment, the EPA has identified a number of emission sources for which a company may choose to commit to reduce emissions through several mitigation options. Participants of the program will report annually to the EPA.
Seneca Resources employs “green completion” techniques on nearly all Marcellus and Utica Shale development wells. Seneca Resources avoids venting or flaring during a well’s initial production whenever possible to minimize methane emissions. All of Seneca Resources’ development wells in fiscal 2019 employed green completions.
Seneca Resources pioneered the industry’s onshore use of ultrasonic leak detection technology on the Marcellus well pads. Now, with more than 110 units in place, Seneca Resources is able to remotely detect the presence of any leaks on well pads and immediately shut down production for repair, if necessary.
Control measures are in place for combustion and non-combustion equipment to abate and/or mitigate methane and VOC emissions. Seneca Resources uses infrared cameras to perform optical gas imaging for leak detection surveys on all of their unconventional well pads and permitted compressor facilities in Pennsylvania, including the 189 wells that are exempt from these inspections. In California, Seneca Resources goes beyond the required quarterly regulatory inspection frequency of the California Air Pollution Control rules by performing them monthly on approximately 2,950 wells and associated facilities using EPA-approved instruments.
In October 2011, Seneca Resources began utilizing EPA-certified natural gas engines to provide all electrical power needed to support drilling rig operations, the first natural gas (LNG)-fueled drilling rigs in Pennsylvania’s Marcellus Shale region. As of the spring of 2020, all of Seneca Resources’ two drilling rigs are dual fuel, allowing the replacement of diesel with clean-burning natural gas. In 2019, Seneca Resources also began using a dual-fuel frac, furthering our replacement of diesel with clean-burning natural gas. Seneca Resources continues to look for opportunities to convert diesel engines utilized in field operations to dual-fuel or natural gas engines; temporary natural gas fluid transfer pumps are just one example of this effort. In addition, some of Seneca Resources’ fleet vehicles in the East Division are also dual-fuel engines, extending the capability to run both natural gas and gasoline.
In July 2016, Seneca Resources completed installation of a 3.1-megawatt photovoltaic solar power generation facility at the North Midway Sunset field in Kern County, Calif. This state-of-the-art complex was California’s largest solar power generation system in the oil and gas industry at time of construction. It’s estimated that the project generates 5.4 million kilowatt-hours of electricity each year, all of which is consumed by Seneca Resources’ production equipment at North Midway Sunset. With this project, Seneca Resources became the first California oil producer to take advantage of the California Air Resource Board’s Low Carbon Fuel Standard “Innovative Method” credit program. In California, Seneca Resources further reduced their carbon footprint in 2018 through the installation of a 90-kilowatt photovoltaic solar power facility to power the Bakersfield division office.
For decades, our utility segment has been at the forefront of efforts to improve safety while reducing direct methane emissions from our pipelines through system modernization, as well as initiatives to lower our customers’ carbon footprint through energy efficiency and conservation. Significant initiatives and achievements include:
We’re a proud partner in the EPA’s Natural Gas STAR Methane Challenge Program. Through this program, we have made voluntary commitments to reduce methane emissions by replacing aging mains and services as well as monitoring damage causing the uncontrolled release of natural gas. As a Methane Challenge partner, National Fuel will also provide data beyond that required by current regulations.
National Fuel Gas Distribution Corporation reports direct and indirect GHG emissions, including methane, under the EPA’s GHGRP for both our New York and Pennsylvania service territories. See National Fuel Gas Distribution Corporation’s EPA reported emissions data.
In addition to mandatory reporting, National Fuel voluntarily discloses various emissions metrics developed by the American Gas Association (AGA) and the Edison Electric Institute (EEI). Going forward, the AGA-EEI partnership, led by a CEO taskforce, has established the Natural Gas Sustainability Initiative (NGSI), which is in the process of developing additional metrics beyond those required by mandatory reporting. National Fuel has been an active participant in this process.
National Fuel directs capital spending to pipeline repair, replacement and maintenance that support our statutory obligation to provide safe and reliable service to our more than 750,000 utility customers. While safety will always be our number one motivation, National Fuel’s continued investments in the modernization of our utility system have had the additional benefit of helping to reduce our GHG emissions. Our replacement of aging natural gas infrastructure with modern materials and technologies has resulted in fewer leaks across the system and significantly lower methane emissions. Since 2012, we have seen a 24.7% reduction in direct greenhouse gas emissions, primarily methane, as reported to the U.S. EPA under Subpart W of 40 CFR Part 98. We expect this trend to continue as we accelerate our investments in system modernization.
Although New York’s ambitious Climate Leadership and Community Protection Act (CLCPA) creates additional challenges, National Fuel’s aggressive modernization program has positioned us to meet, and likely exceed, CLCPA’s 2030 goal to reduce GHG emissions by 40% from 1990 levels.
Renewable natural gas (RNG) is pipeline-quality natural gas produced from a variety of existing waste streams and biomass sources, including animal waste, food waste, landfill gas, organic waste from wastewater treatment plants, and organic waste from landfill-diversion facilities. It presents an exciting opportunity for the industry to be part of the solution to climate change.
RNG can also:
National Fuel recently added our first RNG source and is developing a number of other projects.
Damage to natural gas pipelines and other infrastructure is not only a safety hazard and an inconvenience, it causes unnecessary emissions. For several years, National Fuel has been collecting and analyzing data regarding damage and using that information to tailor programs aimed at preventing these incidents. These efforts have resulted in a decrease in damage incidents by more than 30% over the last five years.
For over four decades, National Fuel has been focused on promoting energy efficiency and conservation. We partner with regulators, industry groups and local businesses to develop and administer outreach and incentive programs designed to reduce our customers’ energy usage through improved appliance efficiency and consumption habits. As a result, our average residential customer consumption has decreased significantly since 1975, resulting in both lower customer bills and lower GHG emissions, primarily carbon dioxide. As suppliers of natural gas, we report indirect greenhouse gas emissions from end-user combustion to the U.S. EPA under Subpart NN of 40 CFR Part 98.
As National Fuel’s midstream businesses work to expand our pipeline network in Appalachia to satisfy the growing demand for local natural gas supplies, we are focused on designing and constructing infrastructure that utilizes best available materials and technologies that minimize emissions, while accommodating the U.S. economy’s conversion to a cleaner-burning energy source. National Fuel has a dedicated team of engineers who are committed to developing emission-management strategies to ensure continuous compliance with stringent federal and state agency permits and reporting requirements, as well as continuous improvement in engineering designs to meet our long-term emissions objectives. Areas of focus include:
In 2018, National Fuel Gas Supply Corporation, Empire Pipeline and National Fuel Gas Midstream Company voluntarily entered into EPA’s Methane Challenge Program as a partner in committing to continue to reducing methane emissions. The Methane Challenge Program is voluntary and is focused on the reduction of methane emissions through the use of technology and/or process improvements.
Supply and Empire are participating in the Transmission and Storage segments of the program, while Midstream is participating in the Gathering and Boosting segment of the program. The companies are committed to various voluntary best management practices (BMP), including those for reciprocating compressor rod packing vents and pneumatic controllers. As Methane Challenge partners, Supply, Empire and Midstream will also provide data beyond what is required by current GHG regulations. The partners were also provided an opportunity to highlight some of their historical methane reduction practices.
To learn more about National Fuel’s Methane Challenge commitments, please visit the partner profiles for the subsidiaries linked below.
In addition, we are committed to continually exploring the applicability of future BMPs or further expansions of the proposed BMPs. For example, our pipeline and storage subsidiary, Supply, proposed developing an implementation plan and appropriate BMP to reduce equipment leaks/fugitive emissions at compressor stations and is in the final approval stage with the EPA.
We regularly monitor and report on our midstream facilities’ GHG emissions, as required by federal EPA regulations. Facility-level data is publicly available at the EPA’s FLIGHT website.
Emissions data relating to Supply, Empire and Midstream’s Pennsylvania facilities is publicly available and can be found on the PaDEP’s Unconventional Natural Gas Emission Inventory website.
Across our businesses, we have been focused on developing best management practices and utilizing best available technologies and materials that mitigate and reduce emissions from our new facilities. A particular focus has been on the design, construction and operation of compressor station facilities, where we continue to invest in technologies that meet and often go above what is required by stringent federal and state regulations and ambient air quality standards. These best management practices include, but are not limited to:
National Fuel is also a voluntary participant in the Interstate Natural Gas Association of America (INGAA) Environmental Health and Safety Committee. National Fuel co-chairs the committee’s GHG Task Force, an industry trade group that seeks to develop and share best practices among industry peers.
Please see the following for:
As part of our robust leak detection policies, we regularly survey our interstate transmission and gathering pipelines to identify methane leaks which may cause potential safety or operational issues. All identified leaks are repaired or monitored. Additionally, we employ a number of different assessment practices, including hydro-testing, the use of inline inspection tools and cathodic protection surveys to assess pipeline condition, determine the potential for leaks, and prioritize repair or replacement of pipelines.
Further, our midstream businesses employ LDAR techniques, including EPA Reference Method 21 and/or optical gas imaging (OGI) technology at many of the facilities in Pennsylvania. Field personnel conduct regular inspections to address any leaks that impose a safety or operating issue, for overall methane emission reduction, and to meet regulatory requirements. We also use automated gas detection systems in compressor station buildings. These systems identify leaks, which allows us to react in real time and promote a safe work environment.