Oil and Gas Drilling Oil and Gas Drilling and Production and Production

Chemicals, Waste Chemicals, Waste and Environmental and Environmental

ImpactsImpactsJune  23, 2009

Wilma SubraSubra Company

Earthworks Board Member

Non-Hazardous Oil and Gas Drilling Non-Hazardous Oil and Gas Drilling and Production Wasteand Production Waste

Wastes generated by the exploration, development, Wastes generated by the exploration, development, and production of crude oil and natural gas are and production of crude oil and natural gas are “exempt” by Federal law from being regulated as “exempt” by Federal law from being regulated as hazardous waste.hazardous waste.

The Solid Waste Disposal Act of 1980 prohibits EPA The Solid Waste Disposal Act of 1980 prohibits EPA from regulating drilling fluids, produced water and from regulating drilling fluids, produced water and other waste associated with the exploration, other waste associated with the exploration, development or production of crude oil or natural gas development or production of crude oil or natural gas as RCRA Subtitle C (hazardous waste. as RCRA Subtitle C (hazardous waste.

Therefore, oil and gas wastes are referred to and Therefore, oil and gas wastes are referred to and regulated at the state level as “non-hazardous regulated at the state level as “non-hazardous waste”waste”

Environmental Protection Agency Exempt Environmental Protection Agency Exempt Oil and Gas Waste CategoriesOil and Gas Waste Categories

Large Volume WasteLarge Volume Waste

     Produced Waters     Produced Waters     Drilling Fluids     Drilling Fluids     Drilling Cuttings     Drilling Cuttings

Associated WasteAssociated Waste

     Completion Fluids     Completion Fluids     Production Storage Tank Sludges     Production Storage Tank Sludges     Produced Oily Sands and Solids     Produced Oily Sands and Solids     Production Pit Sludges     Production Pit Sludges     Washout Water and Sludge from Tank     Washout Water and Sludge from Tank          Cleaning          Cleaning

Quantity of Waste Streams Analyzed as Quantity of Waste Streams Analyzed as Hazardous and Would be Regulated as Hazardous and Would be Regulated as Hazardous if Exemption Were RemovedHazardous if Exemption Were Removed

Large Volume Low Toxicity Waste Streams Large Volume Low Toxicity Waste Streams      10 to 70%     10 to 70%

High Toxicity Associated Waste StreamsHigh Toxicity Associated Waste Streams     40 to 60%     40 to 60%

++

Just because oil and gas wastes are exempt from being regulated as hazardous waste,  does not mean that the waste does not pose a hazard to workers and community members living in close proximity to the drilling, production and waste handling sites.  

Water Usage and Waste Water Production Water Usage and Waste Water Production during  Drilling, Fracturing and Natural Gas during  Drilling, Fracturing and Natural Gas ProductionProduction

A large quantity of water is required during the drilling and A large quantity of water is required during the drilling and fracturing process. fracturing process.

The use of large quantities of surface and groundwater can The use of large quantities of surface and groundwater can deplete and degrade shallow drinking water aquifers and deplete and degrade shallow drinking water aquifers and surface water resources. surface water resources.

A large quantity of produced water/waste water is A large quantity of produced water/waste water is generated as a result of the generated as a result of the      -fracturing process      -fracturing process      -during the natural gas production phase     -during the natural gas production phase

Shale fracturing requires Shale fracturing requires      1.2 million gallons of water for each      1.2 million gallons of water for each                Vertical well               Vertical well     3.5 million gallons of water for each      3.5 million gallons of water for each                Horizontal well               Horizontal well

Wastewater generated during the fracturing process Wastewater generated during the fracturing process is described as flowback water and is contaminated is described as flowback water and is contaminated with the fracturing chemicals and fluids.  Fracturing with the fracturing chemicals and fluids.  Fracturing fluids consist of :fluids consist of :     surfactants     surfactants     friction reducing chemicals     friction reducing chemicals     biocides       biocides       scale inhibitors      scale inhibitors      propping agents      propping agents

The biocides consist of polynuclear aromatic and The biocides consist of polynuclear aromatic and polycyclic organics that are possible and probable polycyclic organics that are possible and probable human carcinogens. human carcinogens.

The flowback water is contaminated with the The flowback water is contaminated with the fracturing fluids and could be potentially fracturing fluids and could be potentially contaminated with radioactive NORM which consist of contaminated with radioactive NORM which consist of the human carcinogen, Radium 226.the human carcinogen, Radium 226.

Each million gallons of hydraulic fracturing Each million gallons of hydraulic fracturing fluid contains @ 40,000 pounds of chemicals.fluid contains @ 40,000 pounds of chemicals.

Thus a vertical well would have 48,000 Thus a vertical well would have 48,000 pounds of chemicals in the fracturing fluid.pounds of chemicals in the fracturing fluid.

A horizontal well would have 140,000 A horizontal well would have 140,000 pounds of chemicals.pounds of chemicals.

20 to 30% of hydraulic fracturing flow back 20 to 30% of hydraulic fracturing flow back waste water remains underground.  The flow waste water remains underground.  The flow back water contains large quantities of the back water contains large quantities of the chemicals used in the fracturing process.chemicals used in the fracturing process.

Wastewater known as produced water is generated Wastewater known as produced water is generated as part of the natural gas production process and is as part of the natural gas production process and is contaminated with contaminated with      volatile organic chemicals     volatile organic chemicals     toxic heavy metals      toxic heavy metals      sulfur containing compounds     sulfur containing compounds     NORM - Radioactive Radium 226 and 228      NORM - Radioactive Radium 226 and 228      salt water minerals     salt water minerals

The volatile organic chemicals consist of Benzene a The volatile organic chemicals consist of Benzene a known human cancer causing agent and other known human cancer causing agent and other organic chemicals (Toluene, Ethyl Benzene, Xylene) organic chemicals (Toluene, Ethyl Benzene, Xylene) that are possible and probable human cancer causing that are possible and probable human cancer causing agents and mutagens.agents and mutagens.

The toxic heavy metals consist of arsenic, barium, The toxic heavy metals consist of arsenic, barium, cadmium, chromium, lead, mercury, and vanadium cadmium, chromium, lead, mercury, and vanadium which are known, possible and probable human which are known, possible and probable human cancer causing agents.cancer causing agents.

Air EmissionsAir Emissions

During the production of natural gas (methane), During the production of natural gas (methane), condensates are also produced.  The condensates condensates are also produced.  The condensates consist of extremely toxic volatile organic chemicals consist of extremely toxic volatile organic chemicals such as benzene (known human cancer causing such as benzene (known human cancer causing agent), xylene, toluene, ethyl benzene and other agent), xylene, toluene, ethyl benzene and other probable and possible cancer causing agents and probable and possible cancer causing agents and sulfur based compounds (sour gas).  These chemicals sulfur based compounds (sour gas).  These chemicals are released into the air from the separation process are released into the air from the separation process and tank storage of condensates. and tank storage of condensates.

Emissions into the air from produced water tanks on Emissions into the air from produced water tanks on the production site release methane,  toxic volatile the production site release methane,  toxic volatile organic chemicals and sulfur compounds into the air. organic chemicals and sulfur compounds into the air.

Natural gas is frequently vented to the air when a Natural gas is frequently vented to the air when a well is completed.well is completed.

Compressors and motors on the drilling and Compressors and motors on the drilling and production sites release combustion products into production sites release combustion products into the air.  These combustion products combine with the the air.  These combustion products combine with the volatile organic chemicals in the presence of heat volatile organic chemicals in the presence of heat and sunlight to produce ground level ozone.  and sunlight to produce ground level ozone. 

Elevated ozone levels result in increased respiratory Elevated ozone levels result in increased respiratory impacts for community members in the area. impacts for community members in the area.

The released methane gas contributes to global The released methane gas contributes to global warming.warming.

The air emissions could have the potential to cause The air emissions could have the potential to cause health impacts to workers and community members health impacts to workers and community members living in close proximity to drilling and production living in close proximity to drilling and production sites.sites.

Disposal Options for fracturing wastewater and Disposal Options for fracturing wastewater and production waste water consist of:production waste water consist of:

Injection into Disposal Wells - the water isInjection into Disposal Wells - the water is     wasted and no longer available for use     wasted and no longer available for use

Wastewater Treatment Facilities that discharge the Wastewater Treatment Facilities that discharge the treated wastewater into surface water bodies - strict treated wastewater into surface water bodies - strict monitoring and compliance measures are needed to monitoring and compliance measures are needed to insure the protection of surface water bodies.insure the protection of surface water bodies.

Emerging Technologies such as Thermal Evaporation Emerging Technologies such as Thermal Evaporation and Brine Concentrator Technologies - air emissions and Brine Concentrator Technologies - air emissions from the Thermal Evaporation system is an area of from the Thermal Evaporation system is an area of concern.concern.

Land spreading of waste waterLand spreading of waste water

Road spreading of waste waterRoad spreading of waste water

Sources of Environmental Sources of Environmental Contamination Contamination

Ground water, surface water, soil, sediments and air Ground water, surface water, soil, sediments and air are impacted by:are impacted by:

Fracturing which can create pathways that can allow Fracturing which can create pathways that can allow migration into other non-target formations.migration into other non-target formations.

Leaks and spills which can occur from injection wells, Leaks and spills which can occur from injection wells, flow lines, pipelines, pits, tanks, chemical storage flow lines, pipelines, pits, tanks, chemical storage containers, drums and trucks.containers, drums and trucks.

Road spreading and land spreading can introduce Road spreading and land spreading can introduce contaminants into the environment.contaminants into the environment.

Discharges into surface water resources of waste Discharges into surface water resources of waste water not meeting permit limits. water not meeting permit limits.

April 28, 2009 - Spring Ridge, LouisianaApril 28, 2009 - Spring Ridge, Louisiana

Hydraulic fracturing was occurring at a well site in the Hydraulic fracturing was occurring at a well site in the Haynesville Shale and production fluids ran off site.Haynesville Shale and production fluids ran off site.

40 beef cows with calves were grazing in the pasture next 40 beef cows with calves were grazing in the pasture next to the drill rig.  The pasture fence was 150’ from the drill to the drill rig.  The pasture fence was 150’ from the drill rig.rig.

19 cattle died after ingesting white, milky fluid in rainwater 19 cattle died after ingesting white, milky fluid in rainwater puddles in the pasture.puddles in the pasture.

The same white milky fluid was present in puddles on the The same white milky fluid was present in puddles on the rig site.rig site.

The cattle were foaming at the mouth, billowing and had The cattle were foaming at the mouth, billowing and had bleeding tongues prior to their deaths.bleeding tongues prior to their deaths.

During the hydraulic fracturing process yellow-green fumes During the hydraulic fracturing process yellow-green fumes were being released into the air and deposited on the were being released into the air and deposited on the ground around the drill rig and in the pasture.ground around the drill rig and in the pasture.

June 2009 - Cleburne, Texas - EarthquakesJune 2009 - Cleburne, Texas - Earthquakes

Population 30,000 - 50 miles SW of DallasPopulation 30,000 - 50 miles SW of Dallas

Near the heart of the Barnett Shale gas fieldNear the heart of the Barnett Shale gas fieldSince 2001 more than 200 natural gas wells drilled within the city Since 2001 more than 200 natural gas wells drilled within the city limits of Cleburnelimits of CleburneJohnson County - more than 1,000 gas wellsJohnson County - more than 1,000 gas wellsEarthquakes - 5 earthquakes in 8 days    Earthquakes - 5 earthquakes in 8 days    6-2-09    2.86-2-09    2.8     6-7-09    2.6     6-7-09    2.6     6-8-09    2.3     6-8-09    2.3     6-9-09    2.8 or less     6-9-09    2.8 or less     6-9-09    2.8 or less     6-9-09    2.8 or lessInstitute for Geophysics, University of Texas at Austin - Institute for Geophysics, University of Texas at Austin - Earthquakes probably related to gas drillingEarthquakes probably related to gas drillingUniversity of Texas professor and author of “Texas Earthquakes” - University of Texas professor and author of “Texas Earthquakes” - earthquakes are related to drilling for petroleum and gas. earthquakes are related to drilling for petroleum and gas. Bedford - a suburb of Dallas had 3 small earthquakes on May 16, Bedford - a suburb of Dallas had 3 small earthquakes on May 16, 2009 2009

Naturally Occurring Radioactive Naturally Occurring Radioactive Material (NORM)Material (NORM)

NORM consist primarily of Radium 226 and 228NORM consist primarily of Radium 226 and 228

Radium 226 has a half life of 1,622 yearsRadium 226 has a half life of 1,622 years

Radium 226 is a bone seeker and is a known Radium 226 is a bone seeker and is a known carcinogen associated with lung and bone cancer.carcinogen associated with lung and bone cancer.

NORM is potentially present in flowback NORM is potentially present in flowback water and produced water from the water and produced water from the Marcellus ShaleMarcellus Shale

The NORM becomes a problem when it is The NORM becomes a problem when it is concentrated, precipitated due to changes concentrated, precipitated due to changes in pressure and reacts with barium sulfate in pressure and reacts with barium sulfate to produce scale.  to produce scale. 

The scale accumulates in production piping The scale accumulates in production piping and in surface equipment such as tank and in surface equipment such as tank bottoms, valves and connectors, pit sludges bottoms, valves and connectors, pit sludges and gas-processing equipment.  and gas-processing equipment.  

State Review of Oil and Natural Gas State Review of Oil and Natural Gas Environmental Regulations Environmental Regulations (STRONGER)(STRONGER)www.strongerinc.org/

New York Office of Natural ResourcesNew York Office of Natural ResourcesDivision of Mineral Resources Division of Mineral Resources

Primary Regulatory Authority of Primary Regulatory Authority of programs dealing with waste programs dealing with waste generated from oil and gas generated from oil and gas exploration and production activitiesexploration and production activities

Reviews based on Guidelines for the Review of State Oil Reviews based on Guidelines for the Review of State Oil and Natural Gas Environmental Regulatory Programsand Natural Gas Environmental Regulatory Programs

Review performed in 1994 by a multi-stakeholder review Review performed in 1994 by a multi-stakeholder review committee committee

1994 Review - 36 Recommendations1994 Review - 36 Recommendations

   9 Recommendations - Administrative Criteria   9 Recommendations - Administrative Criteria

   3 Recommendations - Permitting   3 Recommendations - Permitting

   1 Recommendation - Siting   1 Recommendation - Siting

   6 Recommendations - Public Participation   6 Recommendations - Public Participation         1 Recommendation - Contingency Planning   1 Recommendation - Contingency Planning

   16 Recommendations - Technical Criteria   16 Recommendations - Technical Criteria

Recommendation Recommendation

There is a need to perform a follow up review of the New There is a need to perform a follow up review of the New York program.   A specific focus of the review should be on York program.   A specific focus of the review should be on the applicability of the regulations to protect human health the applicability of the regulations to protect human health and the environment with respect to the Marcellus Shale and the environment with respect to the Marcellus Shale drilling and production activities and procedures. A special drilling and production activities and procedures. A special emphasis of the Marcellus Shale situation should be emphasis of the Marcellus Shale situation should be focused on water resources, water usage and wastewater focused on water resources, water usage and wastewater disposal and reuse.  The adequacy of the regulations disposal and reuse.  The adequacy of the regulations should be evaluated to determine if they appropriately should be evaluated to determine if they appropriately address such issues as: address such issues as:

-Management of flowback fluids, drilling fluids and -Management of flowback fluids, drilling fluids and produced waterproduced water -Waste water treatment and handling capacity to treat and -Waste water treatment and handling capacity to treat and dispose of waste water generated from hydraulic fracturingdispose of waste water generated from hydraulic fracturing

-Ensure protection of ground water and -Ensure protection of ground water and surface water resources and prevent surface water resources and prevent contamination of soil and water resourcescontamination of soil and water resources

-Regulations for fracturing and re-fracturing-Regulations for fracturing and re-fracturing

-Buffer zone, set back and exclusion zones -Buffer zone, set back and exclusion zones for well sites, compressors and tank for well sites, compressors and tank batteries from water bodies, water wells, batteries from water bodies, water wells, homes, businesses, buildings, schools, and homes, businesses, buildings, schools, and parksparks

Abandoned/Orphan SitesAbandoned/Orphan Sites

In 1994, New York faced a substantial abandoned sites problem In 1994, New York faced a substantial abandoned sites problem with the full extent of the problem not yet known.with the full extent of the problem not yet known.   - Half of @ 60,000 wells drilled - lack records   - Half of @ 60,000 wells drilled - lack records   - Quality of data on 30,000 wells in data base   - Quality of data on 30,000 wells in data base     is uncertain - may drilled before 1966 -     is uncertain - may drilled before 1966 -     records first initiated.     records first initiated.   - Almost 18,000 of the 30,000 wells in data   - Almost 18,000 of the 30,000 wells in data     base - records indicate are not plugged       base - records indicate are not plugged 

There is a need to identify locations and assess environmental There is a need to identify locations and assess environmental threats of abandoned/orphan wells and sites in the area of the threats of abandoned/orphan wells and sites in the area of the Marcellus Shale.Marcellus Shale.

Need for a regulatory requirement that the abandoned/orphan Need for a regulatory requirement that the abandoned/orphan wells and sites in the Marcellus Shale be considered and evaluated wells and sites in the Marcellus Shale be considered and evaluated during the drilling permit review process and during the permit during the drilling permit review process and during the permit application review process for commercial and centralized application review process for commercial and centralized facilities.facilities.

NORM NORM

     Need to address the potential for NORM      Need to address the potential for NORM contamination of flowback water, produced water, contamination of flowback water, produced water, tank and pit bottoms, tubular and surface equipment tank and pit bottoms, tubular and surface equipment in the Marcellus Shale and the establishment of in the Marcellus Shale and the establishment of appropriate cleanup, treatment and disposal appropriate cleanup, treatment and disposal requirements. requirements.

Air MonitoringAir Monitoring

     Establish requirements for monitoring air      Establish requirements for monitoring air emissions during drilling, fracturing, and production emissions during drilling, fracturing, and production activities from all on site units.   activities from all on site units.  

Fracturing Responsibility and Awareness of Chemicals Act Fracturing Responsibility and Awareness of Chemicals Act (FRAC Act)(FRAC Act)

In 2005 the Energy Policy Act exempted Hydraulic In 2005 the Energy Policy Act exempted Hydraulic Fracturing from the Safe Drinking Water ActFracturing from the Safe Drinking Water Act

June 9, 2009, Two Bills knows as the FRAC ActJune 9, 2009, Two Bills knows as the FRAC Actwere introduced in the US House and Senate to regulate were introduced in the US House and Senate to regulate Hydraulic FracturingHydraulic Fracturing

House Bill - Introduced by Representatives fromHouse Bill - Introduced by Representatives from                New York and Colorado                New York and Colorado

Senate Bill - Introduced by Senators fromSenate Bill - Introduced by Senators from                  Pennsylvania and New York                  Pennsylvania and New York

Repeal the Hydraulic Fracturing exemption Repeal the Hydraulic Fracturing exemption currently contained in the Safe Drinking Water currently contained in the Safe Drinking Water Act, Underground Injection Control ProgramAct, Underground Injection Control Program

Give EPA the authority to regulate Hydraulic Give EPA the authority to regulate Hydraulic Fracturing under the UIC Program within the Fracturing under the UIC Program within the Safe Drinking Water ActSafe Drinking Water Act

Modify the definition of Underground Injection Modify the definition of Underground Injection specifically to include Hydraulic Fracturingspecifically to include Hydraulic Fracturing

Obligate oil and gas operators to disclose Obligate oil and gas operators to disclose fracturing fluid constituents to regulatory fracturing fluid constituents to regulatory agencies which in turn must provide the agencies which in turn must provide the information to the public.information to the public.