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View Diary: Contemplations on a Randomly Selected Natural Gas Production Well Pad, Uintah Basin, UT (31 comments)

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  •  I forgot about allowable concentrations (0+ / 0-)

    You guys are at concentrations high enought that optical methods work, so real time really is an option.

    •  You are stimulating my environmental enforcement (0+ / 0-)

      and compliance inner lizard.

      First I want to say that your UAV approach is an excellent idea for replacing the manned aircraft method of the present NOAA study.   It would result in more data over a long period of time.   I still have to read the paper to understand the consequences of the UAV approach for validation and accuracy of the NOAA back calculation model being discussed.

      Next, everyone needs to figure out exactly what regulatory consequences, if any, are raised by the proof of concept approach from the NOAA researcher.

      For example, in area-wide hydrocarbon basins, what exactly is the role of the NOAA-type determination method?   In a situation where not all uncontrolled sources will be addressed under the 6 ton per year rule, and where compliance assurance monitoring on the individual small sources is either not provided or not required, then area-wide monitoring for methane/VOC/HAP emissions that are detected in airborne sampling is a good idea.

      If I were the regional administrator of EPA Region VIII, I'd be looking at the Uintah Basin oil and gas emission control problems as a potential negotiating vehicle for getting the industry to address something like the NOAA area-wide monitoring methods in practice.

      Perhaps EPA can hold up some natural gas companies in a consent judgement action or supplemental environmental project to get commitments to such NOAA area-wide monitoring techniques.

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