F L O W- B A C K W A T ER D I S P O S A L : A QU A L I T A T I V E RI S K A S S ES S M EN T

BY TH E ZO MBIE AS SAS S INS

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TABLE OF CONTENTS

Table of figures 3

Executive Summary 4

Introduction 4

What is Hydraulic Fracturing? 4

Flow Back Fluid 4

Disposal of Flow Back Fluid 5

Scope 5

Work Break-down structure 6

Resources 7

Methodology 8

Definition of Risk 8

Reasons to Assess Risk 8

Qualatative risk assessment 9

Analysis 9

Risks of HF flow-back fluid disposal 9

selection of risks 10

risk focus 11

Transportation................................................................................................................................................................................................ 11

Health risks....................................................................................................................................................................................................... 14

Protests............................................................................................................................................................................................................... 16

Conclusions 18

Recommendations 19

Refernces 20

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TABLE OF FIGURES

FIGURE 1: HYDRAULIC FRACTURE WATER CYCLE...................................................................................................................5

FIGURE 2: WORK BREAKDOWN STRUCTURE.......................................................................................................................................... 6

FIGURE 3: RACI CHART............................................................................................................................................................................... 7

FIGURE 4: RISK REGISTER........................................................................................................................................................................ 10

FIGURE 5: RISK MATRIX............................................................................................................................................................................ 10

FIGURE 6:COSTS OF TRANSPORTING FLOWBACK WATER...................................................................................................................11

Figure 7: FINANCIAL BREAK DOWN OF TYPICAL WELL (BAKKEN)............................................................................12

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EXECUTIVE SUMMARY

This qualitative risk analysis of hydraulic fracturing waste-water disposal seeks to identify the major risks for

enterprises associated with handling, transporting, treating, or disposing of flow-back water. Hydraulic fracturing

is described, and the stages of the fluid life cycle are clarified. The nature of risk for corporate enterprise is

established, and qualitative risk management is explained. Risks are ranked in accordance with their relevance,

and three significant risks areas are selected for in-depth analysis: transportation, health risks, and social protests

of and with regard to disposal of flow-back fluids. A selection of recommendations is offered for mitigating or

eliminating the risks: eliminating open pit storage of waste-water, conducting on-site recycling, establishing

centralized treatment plants, and conducting further research.

INTRODUCTION

WHAT IS HYDRAULIC FRACTURING?

Hydraulic Fracturing is an exciting technology for improving the permeability of petroleum reservoirs. A high

pressure mix of water, sand, and chemicals are pumped underground to create fractures in the deep rock layers

that hold valuable hydrocarbon resources. The fluid portion returns to the surface through the well bore, and the

sand remains in place to hold the fractures open under the tremendous pressure of the overlaid rock formations.

Since the sand is many times more permeable to fluid then the native rock, petroleum flows through the sand into

the well bore, and then to the surface for production.

Hydraulic Fracturing has been carried out for decades to improve the profitability of petroleum recovery.

Recently, though, the use of this method has exploded for tapping the vast natural gas resources that have been

discovered on the continental United States. The Marcellus shale formations in the Northeastern U.S., for example

are estimated to hold many decades of natural gas supply.

FLOW BACK FLUID

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The expansive growth of hydraulic fracturing on the continental United States has fueled a secondary industry of

hydraulic fracture flow back water disposal. Millions of gallons of fluids flow out of wells after hydraulic fracture

(HF) operations. These water-based fluids contain petroleum, HF chemicals, dissolved and colloid solids, sand, and

rock particles or chunks of various sizes. These fluids typically have salinity many times that of sea water.

Naturally occurring radon or radioactive tracers added to the HF fluid, completes the mess of water, solids, and

chemicals that needs to be dealt with.

Flow-back fluids can’t simply be turned around to use for the next HF operational segment. Hydraulic fracturing is

engineering with a high degree of physical and chemical specificity. HF fluids are researched and designed to

maximize long term petroleum productivity, based on the unique properties of each reservoir. Nor may the mix be

dumped into a local river without environmental hazard. So, what is done with the flow-back fluid?

DISPOSAL OF FLOW BACK FLUID

The most common procedure is to inject the flow-back fluid into a deep reservoir system, thousands of feet below

the surface. This is usually done near the site where the fluids are generated from the HF operations. This method

depends on the local availability of deep-rock reservoirs. Some research suggests that deep fluid injection may

lubricate fault systems under stress, resulting in small earthquakes. Environmental concerns also include the

leakage of flow back fluid into water reservoirs, and the large fresh water usage of such HF operations.

Some companies have begun to partially treat flow back fluids, combine them with fresh water, and recycle them

back for hydraulic fracturing operations. An industry has started to develop to treat and purify the fluids for

further hydraulic fracturing, or in some cases, for use in agriculture.

Flow back fluids are sometimes trucked or piped across state lines for disposal. Fluids may be temporarily stored

on site in reserve pits, or steel storage tanks. In other cases, municipal water treatment plants have handled flow

back fluids.

SCOPE

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Hydraulic fracture (HF) fluids have a life cycle that begins from water acquisition, extends through mixing and well

injection, and results in wastewaters and disposal (figure 1).

FIGURE 1: HYDRAULIC FRACTURE WATER CYCLE

Each stage of the HF water cycle has characteristic risks. For example, water acquisition risks causing water

shortages in arid regions, due to the millions of gallons of freshwater used for the hydraulic fracture of each well.

Chemical mixing offers the potential for spills of toxic chemicals and worker exposure.

This report deals exclusively with the last stage of the HF water cycle, waste water treatment and disposal. The

goal is to provide a qualitative risk assessment of these activities, with a focus on the particular risks with the most

significant combination of impact and probability. We will not examine the potential risks of recycling waste-water

for use in further hydraulic fracture activity.

WORK BREAK-DOWN STRUCTURE

The Project was organized with a Work Breakdown Structure (WBS) with a series of tasks running in overlapping

time periods. The tasks are organized with milestones consisting of the weekly meetings (figure 2).

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FIGURE 2: WORK BREAKDOWN STRUCTURE

The goal of this organization is to facilitate a clear understanding of the teams sequential activates, and mark

progress toward the deliverable report and presentation.

RESOURCES

A team of four students researched and produced this report together with a PowerPoint class presentation for

Project Management PETR 5392 at the University of Houston’s Cullen College of Engineering:

1. Rami Mosen – Team leader

2. Michael McDonald – Associate

3. Luis Rayes – Associate

4. Aron Troppe – Associate

Rami Mosen, the team leader, organized our responsibilities as depicted in figure 3:

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Define Scope

Develop Plan

Conduct Research

Develop PowerPoint

Develop Report

Deliver Report

Deliver Presentation

Rami A R R C C I RMike R C R I I I CAaron C C R I R R ILouis C C R R I I CR = ResponsibleA = Accountable

C = Consulted I = Informed

FIGURE 3: RACI CHART

Team members used the resources available at the University of Houston’s Anderson Library to meet and plan

activities. These included the computers, internet access, the Learning Commons meeting area, and the research

resources of the Library’s website. The final report and presentation have been submitted as of Saturday, April 20,

2013.

METHODOLOGY

DEFINITION OF RISK

Risk is the possibility of loss or gain due to a future event. This gain/ loss may be monetized, like an equipment

repair cost. It could also be intangible, such as a gain in respectability. Risk is a function of the potential impact of

an event, and the probability of its occurrence. The highest impact events, such as a massive asteroid crashing into

the Earth, tend to have the lowest possibility of occurrence. Similarly, the lowest impact events, like mosquito

bites, generally have the highest probability of occurrence.

By definition, risk requires that cause and effect, with impact and probability, are known, or able to be assessed. If

the cause and effect relationship of an event are unknown, it is termed ‘indeterminacy’. For example, the

relationship between market expansion and lower unemployment is indeterminate. If the probability of an event

is unknown, it is termed an ‘uncertainty’. The discovery of new methods of obtaining energy that revolutionize the

economy is a type of uncertainty. The terminology of risk also excludes controlled events, such as shutting down

an oil platform for scheduled maintenance. The loss of income that results is not considered a risk.

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REASONS TO ASSESS RISK

The future is inherently unpredictable. Uncertain events that impact on business and society will occur without

any type of forewarning. However, responsible businesses have an obligation to do what is reasonably possible to

manage the known risks of business activity.

Corporate risk management looks at three areas: market risk, operational risk, and credit & insurance risk. Market

risk includes corporate strategy, trading & marketing, and sales. Operational risk includes health & safety risks,

project management, and regulation & compliance risks. The Credit & insurance category includes corporate

treasury and insurance risks.

Businesses increase risk when projects have high performance objectives, or poorly defined ones. If a project

schedule is accelerated, the risk of costly errors will grow. Inexperienced managers, poor corrective action and

change control, or lack of qualified personnel or resources increase corporate risk. The use of new technology

generally involves elevated risk of failure. Whenever the impact and probability of a future event can be estimated,

and the impact is relevant to business or society, it is the responsibility of business leadership to manage the risks

under their influence.

QUALATATIVE RISK ASSESSMENT

Qualitative risk assessment is a process in which the potential impact and probability of an event are combined to

generate a value judgment of the relevance of a particular risk. The events are ranked in accordance with their

individual risks, and decisions may now be made as to which risks should be addressed. To accomplish this, risk

register is first created in which all known risks are listed, together with estimates of their probability and impact.

The register also depicts the type of impact, and its potential consequences.

Next, a risk matrix is created. This chart depicts the intensity of impact on one axis, and the probability of

occurrence on the other. Risk entries from the risk register are positioned in the correct locations in the risk

matrix. This method graphically illustrates the most significant known risks. These risks are selected for the

development of appropriate risk mitigation recommendations.

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An optional final step would be the development of a ‘Bow-tie’ analysis for selected risks, where the risk consists of

an adverse event occurring at one moment in time. The event under question is graphically positioned between

possible causes and probable effects. Barriers surrounding the event are identified. Each barrier may prevent a

particular cause from resulting in the event, or may prevent the event from resulting in a particular consequence.

Escalation factors that weaken particular barriers are positioned on the display. The Bow-tie graph thus creates a

holistic analysis of an adverse event, and naturally leads to recommendations for prevention or mitigation.

ANALYSIS

RISKS OF HF FLOW-BACK FLUID DISPOSAL

Hydraulic Fracture water disposal is an activity with a number of potential risks. In general, water disposal is

accomplished either through injection into underground disposal reservoirs, or through treatment and release.

Each activity has numerous sub steps, each with their own associated risks. For example, water treatment may not

fully remove all contaminants. The subsequently released water may then cause environmental damage. The

injection of wastewater into deep underground disposal wells may lubricate fault zones, resulting in seismic

activity and accompanying social protests. A risk register listing a number of diverse risks of the fluid disposal is

given in figure 4.

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FIGURE 4: RISK REGISTER

Each risk in the register has a tracking number, a categorization, an assigned owner and disposition action. These

organizing elements help to ensure that responsibility will be taken to effectively research and evaluate every risk.

SELECTION OF RISKS

The risks were selected based on the risk matrix analysis shown in figure 5 (below). This report focuses on the

risks due to transportation of flow-back water, health problems from exposure, and social protests.

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Tracking Number Risk Title

0.9 3 1 Radiation/ Health Problems

0.7 9 6,8,10 2,4 2 Protests

0.5 1 5 3 Environmentalists Lobbying

0.3 4 Damaged Roadways

0.1 7 5 Traffic Accidents

0.05 0.1 0.2 0.4 0.8 6 Community Traffic Disruption

7 Shipping Costs

8 Ground Water Contamination

9 Aquifer Contamination

10 Induced Seismicity

Risk Matrix

Prob

abili

ty

Consequence Severity

FIGURE 5: RISK MATRIX

These risks are displayed on the upper-right corner of the risk matrix, in the red zone. If additional resources

become available for risk analysis, additional risks from the adjacent yellow zone can be evaluated as well.

RISK FOCUS

TRANSPORTATION

Risks associated with transportation of flow-back water has been broken down into three categories;

financial risk, road damage, and risks associated with local residents which was further broken into traffic

concerns and fatalities due to vehicular accidents. We will begin with a discussion of the financial risks.

In order to have an understanding of the financial costs of transporting flow-back water several sources

were used to obtain minimum and maximum figures used to estimate costs. Figure 5 below shows the results,

using data obtained from the Bakken, Marcellus, and Eagle Ford Shale regions.

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Water

Used

(bbl)

Flow

Back

Total

Flowback

(bbl) Bbls/Truck

Flowback

Truck

Loads

Transportation

Costs (Bakken)

($/bbl) Total Cost $

Min 10000 10% 1000 190 5 $ 0.63 630.00

Max 60000 30% 18000 180 100 $ 9.00 162,000.00

Mean 35000 20% 9500 185 51 $ 4.82 45,742.50

FIGURE 6: COSTS OF TRANSPORTING FLOWBACK WATER

It’s very difficult to draw any strong conclusions from these figures alone. However, note that although virtually all

variables in these rough estimates change dramatically from region to region, and even from one well to the next

within a region, the max value of $162,000 will be used for further discussion. Also note the number of truck loads

calculated, as these figures will be discussed in subsequent sections.

Now we will look at the overall costs of typical horizontal well, drilled and fractured in the Bakken Shale, in

order to get a better understanding of the flow-back transportation costs relative to overall financial liabilities.

Figure 2 below shows that Hydraulic Fracturing indeed contributes the greatest percentage (35%) of the

total costs of the well. However, the majority of this cost is attributed to the extensive amount of equipment and

manpower needed for the actual process at the well site, rather than the transportation of the fluids. Flow-back

water in particular, when compared to the overall cost of $7.2 Million, only accounts for 2.25%, and drops to 0.6%

when you compare the average costs as opposed to the maximum from Table 1.

Ultimately, and to the author’s surprise, this cost contribution is relatively minimal.

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FIGURE 7: FINANCIAL BREAK DOWN OF TYPICAL WELL (BAKKEN)

Road damage in contrast proved to be a much greater risk associated with transportation of flow-back. Many of

the wells being produced currently are located in close proximity to very small quaint towns. When these towns

were settled and roads were constructed, no one had any idea that years later there would be continuous heavy

commercial truck traffic. Most roads in these towns were built to withstand the occasional maximum load of 10

tons. A fully loaded water tanker is generally on the order of 36 tons, and can reach in excess of 46 tons with

permits. Also, as mentioned previously, Table 1 shows that flow-back disposal can account for as many as 100

trips. Some reports have shown as many as 1,000- 2,000 trips are required for the entire fracturing process. It

comes as no surprise then that these roads are being virtually demolished everyday by this abuse.

Often roads are very narrow, with sharp turns, and not designed for tractor trailers. Over time these roads and

turns become widened as trailers are constantly drug through grass and dirt, leaving destruction in their wake.

Bridges are often damaged to the point that they must be closed, as they are no longer safe for even the smallest of

passenger cars to traverse.

Unfortunately, more often than not, local officials are left with the burden of repair, without being provided the

additional resources necessary to complete them. Naturally this has locals very upset, and demanding something

be done.

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Locals are also upset because the added commercial traffic is causing major traffic jams, and a significant

increase in accidents, too often resulting in fatalities. A report from the Eagle Ford Shale region, officials have

listed vehicle accidents among the top four threats to public safety. The other three are cartel violence, human

trafficking and natural disasters.

Fatalities from vehicular accidents within the oil and gas industry are becoming more and more prevalent.

Between 2003 and 2008, 202 of the 628 fatalities in the oil and gas industry were cause by vehicular accidents.

This accounts for 30%, and averages to approximately 10 to 11 deaths a year. Of those accidents approximately

27% of them involved tractor trailers.

According to a local resident in Midland, TX commercial traffic in her small town is simply out of control.

Accidents involving commercial vehicles are virtually a daily occurrence. She says that every night she watches the

evening news and hears report after report about how her local “boom town” is suffering day after day from the

influx of activity. She went on to explain that among the myriad of causes, hiring of inexperienced drivers to fill

demands seems to be a major contributor. Their lack of experience equates to bad judgments being made on the

roadways, which often result in collisions. She added that the inexperience is only compounded when the drivers

are paid “by the load” which results in excessive speeds and sleep deprivation, as these drivers are trying to

maximize their income. Unfortunately their fortune comes at the cost of other’s peril.

The risks of transportation in the oil and gas industry seem to have a lot of negative effects overall. Further

research and data collection is necessary in order to pinpoint the root causes of accidents and fatalities. Without

statistical data on these problems, it is very difficult to gauge the true magnitude of what appears to be a very

serious problem. One thing is for sure, the families who live in these small towns are paying a heavy price at the

moment, and deserve some answers to their grievances.

Although flow-back water transportation accounts for a small percentage of the oil and gas industry’s

transportation costs, the risk of damage is all but a certainty, and anything that can be done to cut back the number

of commercial trucks traveling through small towns on a daily basis, should be very strongly considered.

HEALTH RISKS

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Waste water disposal from hydraulic fracturing presents a variety of risks involving human health. The risks

include water pollution from improper disposal of wastewater to cancer caused by exposure/ingestion of

radioactive material from water ingestion.

Two types of waste water emerge after the hydraulic fracturing process is completed, flow back and

produced water. Flow-back consists of fracturing fluid, along with naturally occurring substances from

underground sources. Flow-back returns to the surface through the wellbore after the well pressure is released,

typically 15-20% of the injected fracturing fluid flows back within the first two weeks. Produced water consists

of wastewater emerging from the well after the initial two weeks, which consists mostly of salty water

contained within the formation. Produced water flows to the surface along with the formation fluid.

Recent studies provided evidence that waste water contains a higher level of salts, which are inconsistent

with the original level of salts used in the hydraulic fracturing fluid. The increase in salinity is due to hydraulic

fracturing releasing elements and the fluid transporting it to the surface. Amongst the elements are NORM

(natural occurring radioactive material), dating back to the Paleozoic era. NORM include of Radium 226,

Radium 228, Radon and Uranium. Radon and Radium are potent carcinogens. According to the EPA, the oral

exposure to Radium can cause lung, bone, head and nasal passage tumors; anemia and cataracts. And radon, if

inhaled, causes lung cancer. Sampled wastewater contained levels of Radium that are from 13-1300 the

maximum contamination level for drinking water standards.

Sometimes, wastewater is temporarily stored in pits, embankments, or tanks at the well site and then

transported to disposal sites. However, storage pits can lead to groundwater contamination when the lining is

either faulty or unlined. For example: In Pavilion, Wyoming, high concentrations of benzene, xylenes, and other

organic compounds associated with gasoline and diesel were found in groundwater samples from shallow

monitoring wells near pits.

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FIGURE 8: LINED STORAGE PIT

The disposal of wastewater in industrial wastewater treatment facilities can lead to elevated pollution levels in

rivers and streams due to most treatment facilities not being able to handle hydraulic fracturing wastewater, due

to high concentrations of salts and high levels of radioactivity in excess of federal drinking water standards.

PROTESTS

Disposing of hydraulic fracturing flow back fluids presents a social risk that is not uncommon among other

ventures in the oil and gas industry. However the risk of anti-industry activists protesting the disposal methods of

fracturing has become a much larger factor for consideration as hydraulic fracturing has grown in popularity. Protests of

flow back disposal have gained national momentum and are no longer a mere annoyance for the fracturing process,

protests have evolved into a legitimate concern which have impacted not only the legal and functional ability to complete

the entire fracturing process but also the safety of members involved in the fracturing process.

Environmentalists and local residents have been aggressively protesting disposal methods to their city and state

governments. The resulting pressure on the local politicians have led to stricter regulations and even disposal bans in

certain areas that have resulted in complicating and delaying the fracturing process and even halting the process all

together. Legislation passed in Pittsburgh Pennsylvania in 2010 serves as an early example of the pressure put on local

politicians by their constituents. The aforementioned legislation is Chapter 619 of the Pittsburgh City Code, Article VI

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that “makes it illegal to deposit toxic substances or potentially toxic substances within the body of any resident of

Pittsburgh, or into any natural community or ecosystem”. Former city councilmen Doug Shields who introduced the piece

of legislation justified its legitimacy by expressing the anger over disposed fracturing fluids threatening water supplies he

had been hearing from his constituents and developing legislation that “recognizes and secures expanded civil rights for

the people of Pittsburgh”. This outright ban on hydraulic fracturing has significant impacts on the industry since

Pennsylvania sits atop one of the nation’s foremost natural gas reservoirs known as the Marcellus Shale. The impact of the

ban complicates the ability to recover natural gas within Pennsylvania’s border, which will inadvertently lead to financial

losses for fracturing companies.

The state of Arkansas has followed in the path introduced by Pennsylvania and responded to protests and

concerns voiced by state residents by enacting regional bans on the disposal of fracturing flow back. City residents of Guy

and Greenbrier, Arkansas protested that their safety was in jeopardy because of increased seismic activity that was a result

of underwater injection disposal wells in the region. These concerns reached an all-time high in February 2011 when a

magnitude 4.7 earthquake devastated the region, prompting the state to take swift action and shut down two of the four

disposal wells in the region so that the impact of the shutdown could be monitored. According to the state geologic survey

“In the 18 days before the shutdown, there were 85 quakes with a magnitude 2.5 or greater,” but in the 18 days following

the shutdown there were only 20 quakes. Protests came to a fever pitch when it was discovered that the four disposal wells

were located on a fault line, forcing the state to unanimously pass legislation that called for the immediate closure of one

of the disposal wells and a ban on the construction of any new disposal wells in a 1,150 square-mile radius. Arkansas’ oil

and gas director Larry Bengal cited that the state’s decision was in immediate response to protesters concerns and that

“We have to side with that public safety concern”. Along with the state mandated injection well shutdown and

construction ban, 3 other wells were subsequently shutdown by the well owners to further comfort the public’s concerns.

Arkansas’ commission deputy director Shane Khoury explained that the moratorium would have a lasting impact on

companies that use hydraulic fracturing because they would now have to “truck the fluids to injection wells elsewhere in

Arkansas or in Oklahoma or Texas”. Companies are at risk of delays in the overall completion of the hydraulic fracturing

process because of the additional distance, and could be at risk of exhausting their resources if they choose to increase the

amount of trucks used for transportation to offset the impact of the additional distance.

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Protests that lead to legislative moratoriums and increased regulations will undoubtedly have lasting effects on a

company’s ability to operate and although risk analysis is done to limit those effects, those risks are common occurrences

of being in the oil and gas business. However when protests not only lead to impacts on operations but also impacts on the

safety of employees, the effects of the risk become even more damaging and of more importance. That is the exact

situation that occurred at the Green Hunter Water Facility in Ohio when over 100 protesters rallied against the existence

of the facility, causing a daylong shut down of the facility. An anti-fracking group called Appalachia Resist coordinated

the demonstration to protest the Green Hunter facility’s services as a storage and disposal facility for fracturing flow back

fluid. For roughly 5 hours the protesters shut down operations by locking the parking garage and setting up a 30ft pole

that one of the protesters sat atop so that disposal transportation trucks wouldn’t pass through in fears of injuring the

protester. Because the facility’s parking garage had been locked employees weren’t able to freely leave the premises,

employees were forced to call the authorities because “the protest grew more destructive.” The demonstration was co-

sponsored by a group called Earth first who has a violent past including members affiliated with eco-terrorism attacks in

the 1980’s. Authorities were able to limit the impact of the protests to only operation impacts by coming in and making

several arrests. The operational impacts of the protests include loss of production because fluid could not be stored or

disposed of during the shut-down causing a delay in the disposing process for nearby fractured wells. The safety risks of

the protests were the real concern, employees could have been held hostage or had their physical well-being threatened.

Although risks associated with protesters don’t always turn into safety situation, the operational effects they can

have on an industry can amount to complications that threaten the value of the operation as a whole. The continued

expansion of hydraulic fracturing around the world will engender further protests. That is why it is important to

understand the risks associated with protesters so that their impacts can be limited.

CONCLUSIONS

Hydraulic fracture waste-water fluid disposal is an enterprise with many risks that border on being uncertainties.

Due to the relatively recent expansion of hydraulic fracturing for shale rock reservoirs, the probabilities of adverse

events associated with their wastewater disposal are difficult to accurately judge. More research on the health,

safety, and environmental risks of disposal are certainly warranted.

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Nonetheless, enough is known about the problems of wastewater disposal to identify the areas of the most

significant risk. Businesses have an obligation to focus attention on finding ways and means to monitor or mitigate

these risks. The investors in energy companies, the workers who work with the flow-back fluid and the public

entities that must approve their safe disposal are all owed a clear statement of HF flow-back fluid disposal risk

management.

RECOMMENDATIONS

In consideration of all the previously mentioned risks of HF wastewater disposal, four basic recommendations may

be made:

Reduce or eliminate open storage of waste-water. The temporary storage of HF flow-back fluids in

open wastewater pits is a contamination waiting to happen. Defects in the design, manufacture, or

installation of the material that line the storage pits can result in wastewater leaking out of the pit. This

will cause an unacceptable groundwater contamination. Instead, waste water should be continuously

treated as it is produced.

Use on-site systems to recycle wastewater. This step will reduce the risks associated with

transportation (such as accidents and associated costs) and eliminate the grievances of anti-disposal

protesters.

Construct regional waste-water treatment facilities. These plants must be capable of treating water

with a high level of salts and radioactive material. The implementation of centralized treatment plants will

eliminate the possibility of the disposal process being interrupted by unexpected disposal bans or

regulations. Vehicular accidents will be reduced as truck drivers become familiar with a centralized

facility.

Conduct better studies on the risks of HF fluids disposal. Many of the risks purported to exist with HF

are hard to prove or disprove with the current scientific information. The fears associated with these risks

have an impact of their own, regardless of the actual risk level. Better studies can do much to reduce the

public anxiety over waste-water disposal and direct prevention efforts to where they are actually needed.

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REFERNCES

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EPA's Study of Hydraulic Fracturing and Its Potential Impact on Drinking Water Resource. (2013, April 8). Retrieved April 16, 2013, from United States Environmental Protection Agency: http://www2.epa.gov/hfstudy

CELDF. (2011, December 20). CELDF Press Release: Pittsburgh Council Votes to Ban Upstream Poisoning of City Residents and the Environment Caused by Corporations Fracking for Shale Gas. Retrieved April 18, 2013, from Community Environmental Defense Legal Fund: http://celdf.org/celdf-press-release-pittsburgh-council-votes-to-ban-upstream-poisoning-of-city-residents-and-the-environment-caused-by-corporations-fracking-for-shale-gas

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Linnitt, C. (2011, August 3). Arkansas Oil and Gas Commission Bans Fracking Disposal Wells Due to Earthquakes. Retrieved April 18, 2013, from DesMogBlog.com: http://www.desmogblog.com/arkansas-oil-and-gas-commission-bans-fracking-disposal-wells-due-earthquakes

Morgan, R. (2013, January 27). Isn’t this radiation naturally occurring? Retrieved April 18, 2013, from ShalePorter: http://www.shalereporter.com/environment/article_715b96a4-8388-51fd-a95c-27034db5d078.html

Rassenfoss, S. (2011). From Flowback to Fracturing:Water Recycling Grows in the Marcellus Shale. Journal of Petroleum Technology, 48-51.