New York Fracking Report Leaked to the New York Times

Extent of Marcellus Shale within the Devonian Shale of the Northeast- USGS

Last Thursday the New York Times reported that an analysis on fracking prepared in early 2012 was leaked to their paper. This analysis was prepared last year after the New York Department of Environmental Conservation’s 2011 draft environmental impact statement (EIS) on drilling comment period was closed and might have been prepared in response to the comments received. The 8 pages obtained by the New York Times were characterized by the paper as containing an analysis that showed that hydraulic Fracturing, or fracking, could be safely done in New York by implementing the proper mitigation measures. The report, obtained by the New York Times from and “expert who did not believe it should be kept secret,” was characterized by State Department of Environmental Conservation, DEC, as an out of date summary that was nearly a year old and will undergo significant changes. The revised version of the Environmental Impact Statement has not yet been completed or released and the DEC’s health assessment is being reviewed by three outside experts. I think someone may have violated the terms of their consulting contract.

The report (or summary) the New York Times had seems to be in agreement with the recommendations made in the report of the Shale Gas Subcommittee of the Secretary of Energy Advisory Board in 2011. That report had a rational approach to regulation recommending disclosure, testing, evaluation and modification of regulation and practices based on the information and data obtained. It assumes information and data will be gathered and analyzed and seems to be the accepted view, but fracking is a highly complex issue whose greatest risks are to our water resources. There needs to be much more data collected over time and analyzed. That has not being done in the past and until extensive data is collected and studied we will not truly know. The data needs to be collected on a state by state basis and provided to the US Geological Survey (USGS) and US EPA to consolidate on a national level. It is essential that the USGS be involved because of the unique expertise and research in geology and water resources.

In 2011, the EPA began a series of research projects into the impacts and potential impacts of fracking on water that are scheduled for completion in late 2014. These projects will be the basis of their actions and future regulations for oil and gas operations. Whether the EPA will regulate oil and gas exploration nationally or leave the oversight in the hands of the states is an open question. There is an argument that water resources and geology are very local phenomena and cannot be generalized over the nation and that hydraulic fracturing should remain under local oversight. According to the New York Times the leaked report rejects performing a quantitative risk assessment because such an assessment would ‘involve making a large number of assumptions about the many scenario-specific variables that influence the nature and degree of potential human exposure and toxicity.”

The EPA research projects may help with that though all the answers will not be known in 2014.  The current fracking projects at the EPA are a series of studies. Existing Data from multiple sources have been obtained for review and analysis. Well construction and hydraulic fracturing records provided by well drillers are being reviewed for 333 oil and gas wells across the United States; data within these records are being examined to assess the effectiveness of current well construction practices at containing gases and liquids before, during, and after hydraulic fracturing.

Computer models are being developed (or expanded) to identify conditions that may lead to impacts on drinking water resources from hydraulic fracturing. The EPA has created hypothetical scenarios for water acquisition, well injection, and wastewater treatment and waste disposal stages of the water cycle that they hope to have the models evaluate. Computer models are also being used to explore the possibility of subsurface gas and fluid migration from deep shale formations to overlying aquifers in different scenarios. The effectiveness of the models would be dependent on how closely the model predicts transport behavior in rock and shale and the similarity in behavior of different formations.

Laboratory studies are being performed to identifying potential impacts of inadequately treating hydraulic fracturing wastewater and discharging it to rivers. Experiments are being designed to test how well common wastewater treatment processes remove selected contaminants from hydraulic fracturing wastewater, including brines, heavy metals, radionuclides and organic contaminants. Since wastewater treatment plants are not designed to remove more than biological waste and bacteria, any removal of fracking chemicals and contaminants would be incidental.

The EPA has identified chemicals used in hydraulic fracturing fluids from 2005 to 2011 and chemicals found in flowback and produced water. The EPA is performing toxicity assessments based on chemical, physical, and toxicological properties for chemicals with known chemical structures and using exiting toxicology models to estimate properties in cases where information is not available. The important thing that EPA is doing is bringing together all the data and previous work to get as complete picture of what we know about how hydraulic fracturing may be impacting our water resources and that would allow a broad quantitative health risk assessment to be performed along the identified routes of exposure.  

New York placed a moratorium on drilling in the Marcellus Shale in 2010 while it assessed the effects of fracking. New York DEC’s draft environmental impact statement (EIS) on drilling was released in the fall of 2011 and recommended that drilling be permitted, but with conditions. The comment period was extended and the DEC began a revision to the EIS that has been going on for over a year. The leaked report indicates that the DEC is recommending lifting the ban on hydro fracking in New York, but that is not certain and fracking remains controversial for good reason.

A large swath of southwestern New York sits atop the Marcellus Shale, which is the third-largest natural gas field currently known in the world. The Marcellus Shale alone is estimated to be 500-trillion-cubic-feet of gas reserve. This resource could heat our homes for a generation or more, and power our electrical generating plants, even fuel cars either directly or through plug in hybrids. The possible impacts to our economy and environment are far reaching. The potential risks are also far reaching.

Our ability to recover natural gas buried a mile or more beneath the earth has increased. Advances in horizontal drilling which allows a vertically drilled well to turn and run thousands of feet laterally through the earth combined with advances in hydraulic fracking, the pumping of millions of gallons of chemicals and water into shale at high pressure have increased our ability to recover natural gas from shale. Hydraulic fracking while old has made tremendous advances in the past 15 years have made it possible to economically access this gas. Our knowledge of the impacts from fracking has lagged behind our ability to access the gas.

 

In hydraulic fracking on average 2-5 million gallons of chemicals and water is pumped into the shale formation at 9,000 pounds per square inch and literally cracks the shale or breaks open existing cracks and allows the trapped natural gas to flow. Each stage of the fracking water cycle is a potential area for impact to drinking water supplies especially from human error and irresponsibly and improperly handling chemicals and contaminated water and poorly managing and protecting our water resources. Water used for fracturing fluids is acquired from surface water or groundwater in the local area. Billions of gallons of water will be used in each region for fracking. Wastewaters from the hydraulic fracturing process (flowback or water produced in the well) needs to be properly treated before it is returned to the waters of the earth. The reality is all water on earth has been here for 4.5 billion years and no new water is being created. The fate of the water that flows back after fracturing has to be addressed, but not all fracturing fluids injected into the geologic formation are recovered. The EPA estimates that the fluids recovered range from 15-80% of the volume injected depending on the site. The long term fate of any residual fluid has not been studied.

 There have been documented cases of seepage into drinking water wells through improperly sealed or abandoned drilling wells.  An ongoing monitoring and data collection program needs to be part of the permitting process. Potential impacts to our water supply from hydraulic fracking needs to be studied over time and regulations modified to better protect our water supplies and natural resources as fracking expands in the region. Our water resources are sacred and irreplaceable. The gas will be there when we know how to access it safely.  The least risky course might be to delay lifting the moratorium until the US EPA finishes its research in late 2014 and then slowly allow a limited number of wells that will include monitoring over decades of the groundwater resources in the area with all the data given to the USGS for analysis.  Any area in consideration for fracking should have several years of quarterly groundwater testing and analysis before fracking begins to establish a base line for groundwater study. Now would be a good time to start developing groundwater monitoring programs.    

Fracking Contaminated a Drinking Water Well

Fracking or hydraulic fracturing as it is more properly known is the pressurized injection of water with chemical additives into a geologic formation. The pressure used exceeds the rock strength and the fluid cracks open or enlarges fractures in the rocks and shale. As the formation is fractured, a “propping agent,” such as sand or ceramic beads, is pumped into the fractures to keep them from closing when the pumping stops and the pressure is released. Natural gas will flow from the fractures in the rock and shale into the wells increasing the recovery of the methane.

Historically, shale wells had been drilled vertically and then hydraulically fractured with 80,000 gallons or less of water and sometimes water and diesel. Diesel use is no longer allowed. However, today the most efficient method for developing the vast low-permeability Marcellus shale reservoirs is high-volume hydraulic fracturing. Wells used for hydraulic fracturing are drilled vertically, vertically and horizontally, or directionally and may extend more than 8,000 feet below ground surface or less than 1,000 feet. The wells can extend several thousand feet horizontally, potentially allowing impact to properties and water supplies far away from the well heads. Fifty thousand to 350,000 gallons of water may be required to fracture one well in a coalbed formation while two to five million gallons of water may be necessary to fracture one horizontal well in a shale formation. Water used for fracturing fluids is acquired from surface water or groundwater in the local area.

No one has ever looked at what the long term implications are for the hydraulic balance and groundwater supply when fracking occurs. The removal of millions of gallons of water, the fracturing of the geological formations, and the high pressure injection of contaminants even at low concentrations into the subsurface could cause significant changes in groundwater flow and quality. Now, the often repeated statement by oil industry executives and the current EPA administration that no documented case of drinking water aquifer being contaminated with fracking fluid has been proven false.

In last Thursday’s New York Times was an article by Ian Urbana outlining information that was part of a 1987 E.P.A. report to congress titled “Management of Wastes from the Exploration, Development and Production of Crude Oil, Natural Gas and Geothermal Energy.” This three volume report was brought to the attention of the New York Times by Carla Greathouse, the study’s lead author. Corroborating documentation was obtained from state archives or from the agency’s library by the New York Times. It appears despite claims to the contrary, EPA has been aware of at least one well documented case of drinking water well contamination from fracking for 25 years. In addition, there are reports from several states noting contamination of drinking water wells in association with fracking. One New York state report reads: “Because of possible underreporting by individuals whose drinking water was contaminated and difficulties in detection, the full extent to which injected brines have contaminated underground sources of drinking water is unknown. However, 23 cases of contamination have been confirmed and 4 are suspected.” http://s3.documentcloud.org/documents/216377/doc-reader-with-epa-report.pdf
http://www.nytimes.com/interactive/us/drilling-down-documents-7.html#document/p1/a27935

In some parts of the country, groundwater is the primary source of drinking water. Residents of 34 of the 100 largest cities in the United States rely on groundwater, as do about 95% of rural households. My own home in the rural crescent would be worthless without my well. Groundwater needs to be protected from anything that can contaminate, damage the water table or impair well production potential. Groundwater hydrology is not fully understood and impairment is not easily seen, only slowly experienced. Groundwater contamination is a particular concern to many of the most vocal opponents of fracking, and although earth’s cleansing capacity is limited, impairment to groundwater storage, flow and well productive capacity should be of equal or greater concern. .

About half the population of the United States depends on groundwater for a significant portion of its drinking water. To help protect these supplies from contamination, the Congress passed Part C of the Safe Drinking Water Act in 1974. This law requires the Environmental Protection Agency (EPA) to establish an underground injection control (LJIC) program. Through this program, EPA, directly or through delegation to states, regulates the design, construction, and operation of underground injection wells, which inject wastes and other fluids below underground drinking water sources. It is time that EPA make their first priority the protection of groundwater.

The Deepwater Horizon BP Oil Spill

On the night of April 20th, 2010 a rush of methane gas up the well pipe to the sea surface occurred and the Deepwater Horizon Oil rig exploded, killing 11 workers and injuring 17. The oil well head, almost a mile deep, began gushing oil into the Gulf of Mexico. From the start Louisiana officials have argued that keeping oil away from the coastline, protecting the estuaries, marshlands and beaches to protect not only the ecology of the area, but also the fishing and tourist industries was of first importance. There was no immediate response, no deploying of manpower and resources to protect the coast for days as the oil gushed into the Gulf.

On April 22nd the Navy and Coast Guard were sent to fight the fire from the explosion. Since then, BP was left to respond to the spill and for days on end the oil catching booms sat idle. This is not the first blowout in history, though the difficulty of staunching the flow was compounded by the extreme depth of the well. For 40 days BP bumbled along trying different ideas to staunch the flow, these; however, were basically the same approaches used in the past. In 1979 when the Mexican Ixtoc well blew out in 150 feet of water it took just about nine months to staunch the flow. The Deepwater Horizon is about a mile deep so the difficulty of responding the spill ins not to be underestimated. The Mexican national oil company Pemex tried to stop the flow with drilling mud, and then with steel and lead balls dropped into the wellbore. It tried to contain the oil with a cap, but failed in all attempts despite being only 150 feet deep. Finally, after nine months a relief well successfully plugged the hole with cement and the flow was stopped after 138 million gallons of crude was released into the Gulf of Mexico.

Though BP has systematically tried to stop the flow by first an attempt to activate the blowout preventer valves, then by trying the first dome which became clogged with icy hydrates and failed, then by trying to divert and capture the flow with an insertion tube, followed by trying to plug the hold with mud and debris (as the Mexicans did). Finally this week BP was able to cut the riser and lower the second containment cap in place. This cap captured 6,077 barrels of oil during its first 24 hours in operation. This is estimated to be somewhere between 25%-50% of the flow. There are four vents at the top of the cap which are now open to relieve pressure and if they are successfully closed without blowing out the seal, the captured flow could be increased. This cap is a temporary measures to capture the flow until two relief wells are completed in the next three months and the Deepwater Horizon can be permanently sealed.

BP is preparing backup systems in the containment effort (risk management learned a little late). Several more caps are in the Gulf. BP plans to replace the currently installed cap with a heavier and more tightly sealed cap designed with storage capacity in case a hurricane forces the containment ship to leave the area. BP and US regulators appeared to believe that because there had not been such a catastrophic blowout in the Gulf since 1979, it would not happen. We were not prepared; we did not have an emergency plan or procedures to mitigate the impact from a catastrophic blowout. Inappropriate risk management took place and was compounded by inappropriate emergency response.

A thick film coats the shore from Louisiana to Florida, and tar balls and orange foam have washed up on Gulf Coast beaches, too. These are the immediate effects of a spill are obvious along with the images of oil soaked and suffocating and dead seabirds washing up on shore. More than 597 birds have been found dead along the coast, according to a federal tally released Friday. In addition more than 243 sea turtles have also been found dead. Dead dolphins were also washing ashore, 31 were dead as if June 7th. But some types of ecological damage are hard to measure and can take years to document. This ecological tragedy is immense. As David Leonhardt pointed out in the New York Times, people in general do a lousy job of estimating risk. Maybe requiring emergency response preparation and maintaining emergency response forces and measures is the true job of government.