A portrait of wellbore leakage in northeastern British Columbia, Canada

The human health effects of unconventional oil and gas development (UOGD): A scoping review of epidemiologic studies

OBJECTIVE

Unconventional oil and gas development (UOGD, sometimes termed "fracking" or "hydraulic fracturing") is an industrial process to extract methane gas and/or oil deposits. Many chemicals used in UOGD have known adverse human health effects. Canada is a major producer of UOGD-derived gas with wells frequently located in and around rural and Indigenous communities. Our objective was to conduct a scoping review to identify the extent of research evidence assessing UOGD exposure-related health impacts, with an additional focus on Canadian studies.

METHODS

We included English- or French-language peer-reviewed epidemiologic studies (January 2000-December 2022) which measured exposure to UOGD chemicals directly or by proxy, and where health outcomes were plausibly caused by UOGD-related chemical exposure. Results synthesis was descriptive with results ordered by outcome and hierarchy of methodological approach.

SYNTHESIS

We identified 52 studies from nine jurisdictions. Only two were set in Canada. A majority (n = 27) used retrospective cohort and case-control designs. Almost half (n = 24) focused on birth outcomes, with a majority (n = 22) reporting one or more significant adverse associations of UOGD exposure with: low birthweight; small for gestational age; preterm birth; and one or more birth defects. Other studies identified adverse impacts including asthma (n = 7), respiratory (n = 13), cardiovascular (n = 6), childhood acute lymphocytic leukemia (n = 2), and all-cause mortality (n = 4).

CONCLUSION

There is a growing body of research, across different jurisdictions, reporting associations of UOGD with adverse health outcomes. Despite the rapid growth of UOGD, which is often located in remote, rural, and Indigenous communities, Canadian research on its effects on human health is remarkably sparse. There is a pressing need for additional evidence.

Density and proximity of oil and gas wells and concentrations of trace elements in urine, hair, nails and tap water samples from pregnant individuals living in Northeastern British Columbia

BACKGROUND

Oil and gas exploitation can release several contaminants in the environment, including trace elements, with potentially deleterious effects on exposed pregnant individuals and their developing fetus. Currently, there is limited data on pregnant individuals' exposure to contaminants associated with oil and gas activity.

OBJECTIVES

We aimed to 1)measure concentrations of trace elements in biological and tap water samples collected from pregnant individuals participating in the EXPERIVA study; 2)compare with reference populations and health-based guidance values; 3)assess correlations across matrices; and 4)evaluate associations with the density/proximity of oil and gas wells.

METHODS

We collected tap water, hair, nails, and repeated urine samples from 85pregnant individuals, and measured concentrations of 21trace elements. We calculated oil and gas well density/proximity (Inverse Distance Weighting [IDW]) for 4buffer sizes (2.5 km, 5 km, 10 km, no buffer). We performed Spearman's rank correlation analyses to assess the correlations across elements and matrices. We used multiple linear regression models to evaluate the associations between IDWs and concentrations.

RESULTS

Some study participants had urinary trace element concentrations exceeding the 95th percentile of reference values; 75% of participants for V, 29% for Co, 22% for Ba, and 20% for Mn. For a given trace element, correlation coefficients ranged from -0.23 to 0.65 across matrices; correlations with tap water concentrations were strongest for hair, followed by nails, and urine. Positive (e.g., Cu, Cr, Sr, U, Ga, Ba, Al, Cd) and negative (e.g., Fe) associations were observed between IDW metrics and the concentrations of certain trace elements in water, hair, and nails.

SIGNIFICANCE

Our results suggest that pregnant individuals living in an area of oil and gas activity may be more exposed to certain trace elements (e.g., Mn, Sr, Co, Ba) than the general population. Association with density/proximity of wells remains unclear.

Methane Emissions from Non-producing Oil and Gas Wells and the Potential Role of Seismic Activity: A Case Study in Northeast British Columbia, Canada

Increasing seismic activity due to fluid injections for oil and gas production may be contributing to leakage along non-producing oil and gas wells and emitting methane, a potent greenhouse gas. However, the extent to which nearby seismicity may drive or exacerbate methane emissions and cause well integrity issues is unknown. Therefore, we analyze field evaluations at 448 non-producing oil and gas wells in Northeast British Columbia (NEBC) and geospatially analyze oil and gas well and fluid injection data alongside locations of 3515 earthquakes from 2001 to 2021 and 130 faults. Through analysis of ground and helicopter-based field evaluations of non-producing wells in NEBC, we show that methane emission rates of non-producing wells average at 8301 mg/h/well but vary by 10 orders of magnitude. We find that higher methane emission rates (milligrams of methane/h/well) are observed at wells with larger flowing pressures at the wellhead during completion (kPa) and with shorter distances (m) to earthquakes, particularly at plugged wells. These results imply that seismicity may increase the likelihood of non-producing well integrity issues and methane leakage, thereby also exacerbating groundwater contamination and environmental degradation risks.

Methane Emissions from Abandoned Oil and Gas Wells in Alberta and Saskatchewan, Canada: The Role of Surface Casing Vent Flows

Abandoned oil and gas wells can act as leakage pathways for methane, a potent greenhouse gas, and other fluids to migrate through the subsurface and to the atmosphere. National estimates of methane emissions remain highly uncertain, and available measurements do not provide details on whether the emissions are associated with well integrity failure (indicating subsurface leaks) or aboveground well infrastructure leaks. Therefore, we directly measured methane emission rates from 238 unplugged and plugged abandoned wells across Alberta and Saskatchewan, Canada, separately quantified emissions from surface casing vents and other emissions from the wellhead (non-surface casing vent), and developed emission factors to estimate Canada-wide emissions from abandoned wells. Our highest measured emission rate (5.2 × 106 mg CH4/hr) from an unplugged gas well was two to three times higher than the largest previously published emission rate from an abandoned well. We estimated methane emissions from abandoned wells in Canada to be 85-93 kilotonnes of methane per year, of which surface casing vent emissions represented 75-82% (70 kilotonnes of methane per year). We found that subsurface leaks, as evidenced by surface casing vent flows, occurred at 32% of abandoned wells in Alberta, substantially higher than previously estimated using provincial data alone (6 and 11%). Therefore, well integrity failures and groundwater contamination are likely to be more common than previous studies suggest.

Fluid migration pathways to groundwater in mature oil fields: Exploring the roles of water injection/production and oil-well integrity in California, USA

Mature oil fields potentially contain multiple fluid migration pathways toward protected groundwater (total dissolved solids, TDS, in nonexempted aquifer <10,000 mg/L) because of their extensive development histories. Time-series data for water use, fluid pressures, oil-well construction, and geochemistry from the South Belridge and Lost Hills mature oil fields in California are used to explore the roles of injection/production of oil-field water and well-integrity issues in fluid migration. Injection/production of oil-field water modified hydraulic gradients in both oil fields, resulting in chemical transport from deeper groundwater and hydrocarbon-reservoir systems to aquifers in the oil fields. Those aquifers are used for water supply outside the oil-field boundaries. Oil wells drilled before 1976 can be fluid migration pathways because a relatively large percentage of them have >10 m of uncemented annulus that straddles oil-well casing damage and/or the base of groundwater with TDS <10,000 mg/L. The risk of groundwater-quality degradation is higher when wells with those risk factors occur in areas with upward hydraulic gradients created by positive net injection, groundwater withdrawals, or combinations of these variables. The complex changes in hydrologic conditions and groundwater chemistry likely would not have been discovered in the absence of years to decades of monitoring data for groundwater elevations and chemistry, and installation of monitoring wells in areas with overlapping risk factors. Important monitoring concepts based on results from this and other studies include monitoring hydrocarbon-reservoir and groundwater systems at multiple spatiotemporal scales and maintaining transparency and accessibility of data and analyses. This analysis focuses on two California oil fields, but the methods used and processes affecting fluid migration could be relevant in other oil fields where substantial injection/production of oil-field water occurs and oil-well integrity is of concern.

Chemical Characterization of Natural Gas Leaking from Abandoned Oil and Gas Wells in Western Pennsylvania

The U.S. Environmental Protection Agency estimates that there are over 3.2 million abandoned wells in the United States. Studies conducted on gas emissions from abandoned wells have been limited to methane, a powerful greenhouse gas, due to concerns regarding climate change. However, volatile organic compounds (VOCs), including benzene, a known human carcinogen, are known to be associated with upstream oil and gas development and hence could also be released when methane is emitted to the atmosphere. In this investigation, we analyze gas from 48 abandoned wells in western Pennsylvania for fixed gases, light hydrocarbons, and VOCs and estimate associated emission rates. We demonstrate that (1) gas from abandoned wells contains VOCs, including benzene; (2) VOCs are emitted from abandoned wells, the magnitude of which depends on the flow rate and concentration of VOCs in the gas stream; and (3) nearly one-quarter of abandoned wells are located within 100 m of buildings, including residences, in Pennsylvania. Together, these observations indicate that further investigation is necessary to determine whether emissions from abandoned wells pose an inhalation risk to people living, working, or congregating near abandoned wells.

Assessing gestational exposure to trace elements in an area of unconventional oil and gas activity: comparison with reference populations and evaluation of variability

BACKGROUND

Located in Northeastern British Columbia, the Montney formation is an important area of unconventional oil and gas exploitation, which can release contaminants like trace elements. Gestational exposure to these contaminants may lead to deleterious developmental effects.

OBJECTIVES

Our study aimed to (1) assess gestational exposure to trace elements in women living in this region through repeated urinary measurements; (2) compare urinary concentrations to those from North American reference populations; (3) compare urinary concentrations between Indigenous and non-Indigenous participants; and (4) evaluate inter- and intra-individual variability in urinary levels.

METHODS

Eighty-five pregnant women participating in the Exposures in the Peace River Valley (EXPERIVA) study provided daily spot urine samples over 7 consecutive days. Samples were analyzed for 20 trace elements using inductively-coupled mass spectrometry (ICP-MS). Descriptive statistics were calculated, and inter- and intra-individual variability in urinary levels was evaluated through intraclass correlation coefficient (ICC) calculation for each trace element.

RESULTS

When compared with those from North American reference populations, median urinary levels were higher in our population for barium (~2 times), cobalt (~3 times) and strontium (~2 times). The 95th percentile of reference populations was exceeded at least 1 time by a substantial percentage of participants during the sampling week for barium (58%), cobalt (73%), copper (29%), manganese (28%), selenium (38%), strontium (60%) and vanadium (100%). We observed higher urinary manganese concentrations in self-identified Indigenous participants (median: 0.19 µg/g creatinine) compared to non-Indigenous participants (median: 0.15 µg/g of creatinine). ICCs varied from 0.288 to 0.722, indicating poor to moderate reliability depending on the trace element.

SIGNIFICANCE

Our results suggest that pregnant women living in this region may be more exposed to certain trace elements (barium, cobalt, copper, manganese, selenium, strontium, and vanadium), and that one urine spot sample could be insufficient to adequately characterize participants' exposure to certain trace elements.

IMPACT STATEMENT

Unconventional oil and gas (UOG) is an important industry in the Peace River Valley region (Northeastern British Columbia, Canada). Information on the impacts of this industry is limited, but recent literature emphasizes the risk of environmental contamination. The results presented in this paper highlight that pregnant women living near UOG wells in Northeastern British Columbia may be more exposed to some trace elements known to be related to this industry compared to reference populations. Furthermore, our results based on repeated urinary measurements show that one urine sample may be insufficient to adequately reflect long-term exposure to certain trace elements.

Composition and Origin of Surface Casing Fluids in a Major US Oil- and Gas-Producing Region

Fluids leaked from oil and gas wells often originate from their surface casing─a steel pipe installed beneath the deepest underlying source of potable groundwater that serves as the final barrier around the well system. In this study, we analyze a regulatory dataset of surface casing geochemical samples collected from 2573 wells in northeastern Colorado─the only known publicly available dataset of its kind. Thermogenic gas was present in the surface casings of 96.2% of wells with gas samples. Regulatory records indicate that 73.3% of these wells were constructed to isolate the formation from which the gas originated with cement. This suggests that gas migration into the surface casing annulus predominantly occurs through compromised barriers (e.g., steel casings or cement seals), indicative of extensive integrity issues in the region. Water was collected from 22.6% of sampled surface casings. Benzene, toluene, ethylbenzene, and xylenes were detected in 99.7% of surface casing water samples tested for these compounds, which may be due to the presence of leaked oil, natural gas condensate, or oil-based drilling mud. Our findings demonstrate the value of incorporating surface casing geochemical analysis in well integrity monitoring programs to identify integrity issues and focus leak mitigation efforts.

Commingled Fluids in Abandoned Boreholes: Proximity Analysis of a Hidden Liability

The interactions between old abandoned wellbores of suspect well integrity with hydraulic fracturing (HF), enhanced oil recovery (EOR), or salt water disposal (SWD) operations can result in upward leakage of deep aqueous liquids into overlying aquifers. This potential for upward fluid migration is largely unquantified as monitoring abandoned wells is rarely done, and leakage may go unnoticed especially when in deeper aquifers. This study performs a proximity analysis between old abandoned wells and HF, EOR, and SWD wells, and identifies commingled old abandoned wellbores, which are those wells where groundwater may flow from one aquifer to one or more other aquifers, to identify the locations with the greatest potential for upward aqueous fluid migration at three study sites in the Western Canadian Sedimentary Basin. Our analysis indicates that at all three study sites there are several locations where HF, EOR, or SWD operations are located in close proximity to a given old abandoned well. Much of this overlap occurs in formations above typically produced hydrocarbon reservoirs but below exploited potable aquifers, otherwise known as the intermediate zone, which is often connected between abandonment plugs in old abandoned wells. Information on the intermediate zone is often lacking, and this study suggests that unanticipated alterations to groundwater flow systems within the intermediate zone may be occurring. Results indicate the need for more field-based research on the intermediate zone.

Volatile organic compounds (VOCs) in indoor air and tap water samples in residences of pregnant women living in an area of unconventional natural gas operations: Findings from the EXPERIVA study

BACKGROUND

Northeastern British Columbia (Canada) is an area of unconventional natural gas (UNG) exploitation by hydraulic fracturing, which can release several contaminants, including volatile organic compounds (VOCs). To evaluate gestational exposure to contaminants in this region, we undertook the Exposures in the Peace River Valley (EXPERIVA) study.

OBJECTIVES

We aimed to: 1) measure VOCs in residential indoor air and tap water from EXPERIVA participants; 2) compare concentrations with those in the general population and explore differences related to sociodemographic and housing characteristics; and 3) determine associations between VOC concentrations and density/proximity to UNG wells.

METHODS

Eighty-five pregnant women participated. Passive air samplers were analyzed for 47 VOCs, and tap water samples were analyzed for 44 VOCs. VOC concentrations were compared with those from the Canadian Health Measure Survey (CHMS). We assessed the association between different metrics of well density/proximity and indoor air and tap water VOC concentrations using multiple linear regression.

RESULTS

40 VOCs were detected in >50% of air samples, whereas only 4 VOCs were detected in >50% of water samples. We observed indoor air concentrations >95th percentile of CHMS in 10-60% of samples for several compounds (acetone, 2-methyl-2-propanol, chloroform, 1,4-dioxane, hexanal, m/p-xylene, o-xylene, styrene, decamethylcyclopentasiloxane, dodecane and decanal). Indoor air levels of chloroform and tap water levels of total trihalomethanes were higher in Indigenous participants compared to non-Indigenous participants. Indoor air levels of chloroform and acetone, and tap water levels of total trihalomethanes were positively associated with UNG wells density/proximity metrics. Indoor air BTEX (benzene, toluene, ethylbenzene, xylenes) levels were positively correlated with some well density/proximity metrics.

CONCLUSION

Our results suggest higher exposure to certain VOCs in pregnant women living in an area of intense unconventional natural gas exploitation compared with the general Canadian population, and that well density/proximity is associated with increased exposure to certain VOCs.

Comparison of the Hydraulic Fracturing Water Cycle in China and North America: A Critical Review

There is considerable debate about the sustainability of the hydraulic fracturing (HF) water cycle in North America. Recently, this debate has expanded to China, where HF activities continue to grow. Here, we provide a critical review of the HF water cycle in China, including water withdrawal practices and flowback and produced water (FPW) management and their environmental impacts, with a comprehensive comparison to the U.S. and Canada (North America). Water stress in arid regions, as well as water management challenges, FPW contamination of aquatic and soil systems, and induced seismicity are all impacts of the HF water cycle in China, the U.S., and Canada. In light of experience gained in North America, standardized practices for analyzing and reporting FPW chemistry and microbiology in China are needed to inform its efficient and safe treatment, discharge and reuse, and identification of potential contaminants. Additionally, conducting ecotoxicological studies is an essential next step to fully reveal the impacts of accidental FPW releases into aquatic and soil ecosystems in China. From a policy perspective, the development of China's unconventional resources lags behind North America's in terms of overall regulation, especially with regard to water withdrawal, FPW management, and routine monitoring. Our study suggests that common environmental risks exist within the world's two largest HF regions, and practices used in North America may help prevent or mitigate adverse effects in China.

Semi-Analytical Solution to Assess CO2 Leakage in the Subsurface through Abandoned Wells

Geological carbon storage is an effective method capable of reducing carbon dioxide (CO2) emissions at significant scales. Subsurface reservoirs with sealing caprocks can provide long-term containment for the injected fluid. Nevertheless, CO2 leakage is a major concern. The presence of abandoned wells penetrating the reservoir caprock may cause leakage flow-paths for CO2 to the overburden. Assessment of time-varying leaky wells is a need. In this paper, we propose a new semi-analytical approach based on pressure-transient analysis to model the behavior of CO2 leakage and corresponding pressure distribution within the storage site and the overburden. Current methods assume instantaneous leakage of CO2 occurring with injection, which is not realistic. In this work, we employ the superposition in time and space to solve the diffusivity equation in 2D radial flow to approximate the transient pressure in the reservoirs. Fluid and rock compressibilities are taken into consideration, which allow calculating the breakthrough time and the leakage rate of CO2 to the overburden accurately. We use numerical simulations to verify the proposed time-dependent semi-analytical solution. The results show good agreement in both pressure and leakage rates. Sensitivity analysis is then conducted to assess different CO2 leakage scenarios to the overburden. The developed semi-analytical solution provides a new simple and practical approach to assess the potential of CO2 leakage outside the storage site. This approach is an alternative to numerical methods when detailed simulations are not feasible. Furthermore, the proposed solution can also be used to verify numerical codes, which often exhibit numerical artifacts.

A Brief Review of Gas Migration in Oilwell Cement Slurries

Gas migration in oil and gas wells is defined as gases and/or fluids from adjacent formations invading a freshly cemented annulus. During well completions, gas and/or fluids can migrate to zones with lower pressure or even to the surface. Static gel strength (SGS), related to the yield stress of the cement, is a widely accepted measurement used to predict and minimize gas migration. In this review article, we look at the mechanisms and some possible solutions to gas migration during oil and gas well cementing. The use of static gel strength (SGS) and experimental measurements for SGS and wellbore pressure reduction are discussed. Rheological properties, including the yield stress and the viscosity of cement slurries, are also briefly discussed. Understanding the rheological properties of cement is complex since its material properties depend on cement type, as well as the shape and size distribution of cement particles. From this brief review, it is evident that in order to reduce free water and settling of the cement particles, to lower fluid loss, and to develop compressive strength in the early stages of cementing, an optimal cement slurry design is needed. The SGS test is a standard method used in estimating the free water in the well and could be a reference for gas migration reduction for oilwell cement slurries.

Public data from three US states provide new insights into well integrity

There are over 900,000 active oil and gas wells in the United States. Estimates of the percentage of these wells that leak during their lifetime have been limited by data availability. We mined publicly available records from state regulatory databases and synthesized the results of various well testing methods into a uniform dataset that describes the integrity of 105,031 wells. Our analysis of the dataset provides insight into regional well leakage frequencies in three US states (Colorado, New Mexico, and Pennsylvania), spatial and temporal leakage trends among vertical and directional wells, and the characteristics of leaked fluids. Our findings demonstrate the value of statewide well testing programs and highlight the challenges of interpreting disparate interjurisdictional well testing data.

Oil and gas wells with compromised integrity are a concern because they can potentially leak hydrocarbons or other fluids into groundwater and/or the atmosphere. Most states in the United States require some form of integrity testing, but few jurisdictions mandate widespread testing and open reporting on a scale informative for leakage risk assessment. In this study, we searched 33 US state oil and gas regulatory agency databases and identified records useful for evaluating well integrity in Colorado, New Mexico, and Pennsylvania. In total, we compiled 474,621 testing records from 105,031 wells across these states into a uniform dataset. We found that 14.1% of wells tested prior to 2018 in Pennsylvania exhibited sustained casing pressure (SCP) or casing vent flow (CVF)—two indicators of compromised well integrity. Data from different hydrocarbon-producing regions within Colorado and New Mexico revealed a wider range (0.3 to 26.5%) of SCP and/or CVF occurrence than previously reported, highlighting the need to better understand regional trends in well integrity. Directional wells were more likely to exhibit SCP and/or CVF than vertical wells in Colorado and Pennsylvania, and their installation corresponded with statewide increases in SCP and/or CVF occurrence in Colorado (2005 to 2009) and Pennsylvania (2007 to 2011). Testing the ground around wells for indicators of gas leakage is not a widespread practice in the states considered. However, 3.0% of Colorado wells tested and 0.1% of New Mexico wells tested exhibited a degree of SCP sufficient to potentially induce leakage outside the well.

Density and proximity to hydraulic fracturing wells and birth outcomes in Northeastern British Columbia, Canada

BACKGROUND

Hydraulic fracturing, a method used in Northeastern British Columbia (Canada) to extract natural gas, can release contaminants with potential deleterious health effects on fetal development. To date, the association between hydraulic fracturing activity and birth outcomes has not been evaluated in this region.

OBJECTIVE

To evaluate the association between the hydraulic fracturing well density/proximity and birth outcomes (birthweight, head circumference, preterm birth and small for gestational age (SGA)).

METHODS

We used birth records from the Fort St John hospital between December 30, 2006 and December 29, 2016 (n = 6333 births). To estimate gestational exposure, we used inverse distance weighting (IDW) to calculate the density/proximity of hydraulic fracturing wells to pregnant women's postal code centroid. For each birth, we calculated three IDWs using 2.5, 5, and 10 km buffer zones around women's postal code centroid. We used linear and logistic regressions to evaluate associations between quartiles of postal code well density/proximity and birth outcomes, controlling for relevant covariates.

RESULTS

No associations were found between postal code well density/proximity and head circumference or SGA. A negative association was found between postal code well density/proximity and birthweight for infants born to women in the 2nd quartile of the 10 km buffer (β [95% confidence interval (CI)]: -47.28 g [-84.30; -10.25]), and in the 2nd (β [95% CI]: -40.87 g [-78.01; -3.73]) and 3rd (β [95% CI]: -42.01 g [-79.15; -4.87]) quartiles of the 5 km buffer. Increased odds of preterm birth were observed among women in the 2nd quartile of the 2.5 km buffer (odds ratio (OR) [95% CI]: 1.60 [1.30; 2.43]).

CONCLUSIONS

This is the first epidemiological study in Northeastern British Columbia evaluating associations between hydraulic fracturing and health outcomes. Our results show inconsistent patterns of association between hydraulic fracturing, preterm birth and reduced birthweight, and effect estimates did not match expected dose-response relationships.

A Review of Methane Gas Detection Sensors: Recent Developments and Future Perspectives

Methane, the primary component of natural gas, is a significant contributor to global warming and climate change. It is a harmful greenhouse gas with an impact 28 times greater than carbon dioxide over a 100-year period. Preventing methane leakage from transmission pipelines and other oil and gas production activities is a possible solution to reduce methane emissions. In order to detect and resolve methane leaks, reliable and cost-effective sensors need to be researched and developed. This paper provides a comprehensive review of different types of methane detection sensors, including optical sensors, calorimetric sensors, pyroelectric sensors, semiconducting oxide sensors, and electrochemical sensors. The discussed material includes the definitions, mechanisms and recent developments of these sensors. A comparison between different methods, highlighting the advantages and disadvantages of each, is also presented to help address future research needs.

Reported Methane Emissions from Active Oil and Gas Wells in Pennsylvania, 2014-2018

Oil/gas well integrity failures are a common but poorly constrained source of methane emissions to the atmosphere. As of 2014, Pennsylvania requires gas and oil well operators to report gas losses, both fugitive and process, from all active and unplugged abandoned gas and oil wells. We analyze 589,175 operator reports and find that lower-bound reported annual methane emissions averaged 22.1 Gg (-16.9, +19.5) between 2014 and 2018 from 62,483 wells, an average of only 47% of the statewide well inventory for those years. Extrapolating to the 2019 oil and gas well inventory yields well average emissions of 55.6 Gg CH₄. These emissions are not currently included in the state's oil and gas emission inventory. We also assess compliance in reporting among operators and note anomalies in reporting and apparent workarounds to reduce reported emissions. Suggestions for improving the accuracy and reliability in reporting and reducing emissions are offered.