Sara Dewey, Liz Hanson, Claire Horan, Wendy Jacobs & Shaun Goho, Opportunities to Address Climate Change in the Farm Bill (Harv. L. Sch. Emmett Envt’l L. & Pol’y Clinic, Dec. 2017).
Drew R. Michanowicz, Jonathan J. Buonocore, Sebastian T. Rowland, Katherine E. Konschnik, Shaun A. Goho & Aaron S. Bernstein, A National Assessment of Underground Natural Gas Storage: Identifying Wells with Designs Likely Vulnerable to a Single-Point-of-Failure, 12 Envtl. Res. Letters 064004 (2017).
The leak of processed natural gas (PNG) from October 2015 to February 2016 from the Aliso Canyon storage facility, near Los Angeles, California, was the largest single accidental release of greenhouse gases in US history. The Interagency Task Force on Natural Gas Storage Safety and California regulators recently recommended operators phase out single-point-of-failure (SPF) well designs. Here, we develop a national dataset of UGS well activity in the continental US to assess regulatory data availability and uncertainty, and to assess the prevalence of certain well design deficiencies including single-point-of-failure designs. We identified 14 138 active UGS wells associated with 317 active UGS facilities in 29 states using regulatory and company data. State-level wellbore datasets contained numerous reporting inconsistencies that limited data concatenation. We identified 2715 active UGS wells across 160 facilities that, like the failed well at Aliso Canyon, predated the storage facility, and therefore were not originally designed for gas storage. The majority (88%) of these repurposed wells are located in OH, MI, PA, NY, and WV. Repurposed wells have a median age of 74 years, and the 2694 repurposed wells constructed prior to 1979 are particularly likely to exhibit design-related deficiencies. An estimated 210 active repurposed wells were constructed before 1917—before cement zonal isolation methods were utilized. These wells are located in OH, PA, NY, and WV and represent the highest priority related to potential design deficiencies that could lead to containment loss. This national baseline assessment identifies regulatory data uncertainties, highlights a potentially widespread vulnerability of the natural gas supply chain, and can aid in prioritization and oversight for high-risk wells and facilities.