Transcript The Underground Injection Control Program and Summary of

Hydraulic Fracturing and Drinking Water:
Presentation for the National League of
Cities - Energy, Environment and Natural
Resources Steering Committee
Kurt Hildebrandt, Environmental Scientist
EPA Region 7
US EPA - Region 7
Water, Wetlands & Pesticides Division
June 3, 2011
Preface
Hydraulic fracturing (HF) was first used over 100 years ago in
1903, but the first commercial fracturing treatment to stimulate
oil and gas production was performed in 1947/48. In fact, one of
the first – if not the first – application of HF for enhanced oil and
gas production occurred in Kansas in 1947. Since that time, HF
has been applied more than one million times to stimulate
production in old wells and enhance production process in
unconventional formations and unfavorable locations.
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Natural Gas Extraction
• Natural gas is an abundant domestic source of energy
– Power generation, cooking and heating, transportation,
fertilizer production, and other uses
• Electricity production using natural gas produces less CO2
emissions on a BTU basis than coal or oil
• Application of hydraulic fracturing and horizontal drilling has
enabled economic extraction of gas from shale formations
deep below the surface
– Rapid expansion across the U.S.
– International growth
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Gas Well Field
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Where Are We Today?
• Shale gas is produced in 20 states across the country
• Approximately 35,000 gas wells were fractured in 2010
• Many inactive gas wells are being looked at as candidates for
fracturing
• Significant growth projected: Energy Institute of America’s
(EIA) Outlook 2011 report estimates doubling of recoverable
shale gas
• International interest – France, Great Britain, Germany,
Poland, Australia, and others
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Importance of Shale Gas
2008 Proved
Reserves
(trillion ft3)
2009 Proved
Reserves
(trillion ft3)
Coalbed Methane
20.8
18.6
Shale
34.4
60.6
Conventional &
Tight
199.9
204.7
Total
255.0
283.9
Source of Gas
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Major Shale Gas Plays in the United States
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Well Drilling
•
Well drilling may be vertical or horizontal
•
Horizontal drilling is a new technology frequently used in less permeable
formations such as shale to increase production
Several wells using
horizontal drilling may
extend radially into a
formation from a
central wellpad, unlike
vertical wells
Vertical (left) and horizontal
drilling (right) with HF crosssection of well
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Production Well Construction
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Injection Well Construction
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What is Hydraulic Fracturing?
•
•
•
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Hydraulic fractures are created when a fluid is pumped down
production wells at high pressure for short periods of time
(hours)
The high-pressure fluid exceeds the rock strength and opens
fractures in the rock
A propping agent, usually sand, is pumped into the fractures
to keep them from closing when the fracturing pressure is
released
Hydraulic Fracturing Schematic
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Highly Industrialized Process
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Typical Wellpad Arrangement
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What is in Hydraulic Fracturing Fluid?
Typically, the fluids used in hydraulic fracturing are water-based
and contain:
–
–
–
–
–
–
–
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Biocides
Fluid-loss agents
Friction reducers
Surfactants
Acids
Petroleum distillates
Proppants
How Can HF Impact Sources of Drinking
Water?
• Potential endangerment of water supplies
– New and different geographic and geologic settings
– Adjacent formations may contain metals, radionuclides,
salts, or other constituents that may be mobilized and
impact water quality
• Environmental contaminants associated with hydraulic
fracturing chemicals, well drilling, water, wastes, and
residuals may pose risks to public health, water resources,
and the environment
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How Can HF Impact Sources of Drinking
Water? (cont.)
• Sustainability of water resources
– Sources used for HF come from public water sources, or
directly from ground or surface waters
– Average well water usage for production is order of
magnitude higher than conventional gas production
• Shale Gas - 2,000,000-6,000,000 gal. vs. CBM 50,000-350,000 gal. of water (not including proppant
and/or additive volume)
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Overview of Regulatory Authorities
• States hold authority to regulate most oil and gas production
activities
• State and local governments have siting authorities
• Federal authorities limited, but do exist, under a variety of
statutes administered by different agencies, e.g.:
– SDWA, CWA, CAA
– NEPA
– Endangered Species Act
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Safe Drinking Water Act Authorities
•
SDWA requires EPA to protect drinking water sources from contamination
caused by underground injection
•
•
EPA UIC Program established six classes of wells (Classes I – VI)
Class II wells inject fluids associated with oil and natural gas production
including:
– Fluids brought to the surface in connection with natural gas storage
operations, or conventional oil or natural gas production (e.g., produced
water)
– For enhanced recovery of oil or natural gas (e.g., well stimulation)
– For the storage of liquid hydrocarbons (usually as part of the US
Strategic Petroleum Reserve)
•
•
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UIC programs may not interfere with or impede production activities
SDWA also contains emergency powers to address imminent and
substantial endangerment
UIC Program Implementation
•
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33 states have primary enforcement authority (primacy) for the UIC
program; EPA and states share program implementation in 7 states and 2
tribes; EPA directly implements the entire UIC Program in 10 states
Energy Policy Act 2005
• EPA’s 2004 coal bed methane study of hydraulic fracturing found no
confirmed cases of contamination, but highlighted that diesel could
be an area of concern
• Congress revisited SDWA definition of “underground injection” and
exempted hydraulic fracturing, except when diesel fuel is used
[Section 1421(d)(1)(B)]:
– (i) the underground injection of natural gas for purposes of
storage; and
– (ii) the underground injection of fluids or propping agents (other
than diesel fuels) pursuant to hydraulic fracturing operations
related to oil, gas or geothermal production activities
• EPA is developing guidance to answer questions about the
permitting process for diesel fuels in HF fluids
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Overview of EPA’s Role
• Responsible development of America’s shale gas resources
offers important economic, energy security, and
environmental benefits
• EPA plays an important role in addressing public concerns,
ensuring environmental protection, and in working with
federal and state partners to manage the benefits and risks of
shale gas production
• The Agency is committed to improving scientific
understanding of the potential environmental impacts of shale
gas extraction and using tools at hand to address any known
concerns
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Concerns Raised by the Public and Others
• Flammable tap water; explosive conditions in the home from
methane
• Drinking water contamination from HF chemicals
• Stream and river water quality impacts
• Livestock deaths attributed to water contamination from HF
fluids
• Unknown chemicals in HF fluids injected into ground water
• Gas well blowouts, air emissions and fluid spills
• Seismicity in Arkansas
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Overall Reaction/Response
• Industry and state oil and gas agencies are beginning to
respond to concerns, but in some cases, the public may
question conflicts of interest
• State permitting processes for oil and gas vary in their
effectiveness, depending on how recently they were updated
– Some states have limited ability to enforce
– AL, AR, CO, NM, LA, OH, WY recently changed
regulations
• NY and localities in TX, MD have some form of moratorium
• Civil suits in PA, NY and TX
• Vigorous press and Congressional attention
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EPA’s Overall Approach on Shale Gas –
Best Design and Management Practices
• President Obama’s Blueprint for a Secure Energy Future
(March 2011)
– Working with Secretary of Energy’s Advisory Board to
develop recommendations to minimize adverse impacts to
public health and the environment from shale gas
production, and to inform regulatory development
www.whitehouse.gov/sites/default/files/blueprint_secure_energy_future.pdf
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EPA’s Approach in Addressing Hydraulic
Fracturing Concerns
• Research to improve our understanding of potential impacts,
to provide accurate information, and to respond to
Congressional requests
• Guidance to explain how existing regulations apply
• New regulations to update standards where they may be
outdated
• Coordination and partnerships with external stakeholders
• Enforcement to ensure compliance with environmental laws
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EPA Responses to Hydraulic Fracturing
Concerns (partial listing)
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•
•
•
•
•
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Series of Public Meetings
Information requests to nine hydraulic fracturing companies
Office of Research and Development (ORD) Study
EPA Region 6 enforcement action in Texas
Fort Peck Reservation contamination
Working with State of Pennsylvania
2010 Public Meetings
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2010 Public Meetings Summary
Citizens,
Communities,
Organizations
• HF critical to the
economic viability of
the community
• HF poses risks to:
• Drinking water
• Air
• Land
• Wildlife
• Citizens concerned
about undisclosed
chemicals in HF fluids
• Citizens requested
EPA intervention
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Industry
State Regulators
• HF has a long
history of safety
• Industry is willing
to share data
with EPA to
support safety
claims
• States are best
at regulating
industry
• HF has not been
proven to be the
cause of
contamination
• States are
adequately
regulating
• Willing to share
data with EPA
Information Requests
• In the fall of 2010, EPA issued a request to nine hydraulic
fracturing companies to voluntarily submit information on
hydraulic fracturing for the study
• Information requested:
– Chemical composition of fracturing fluid products
– Data on the health and environmental impacts of the
products and constituent chemicals
– Detailed information on the hydraulic fracturing process
– Sites where the companies have fractured and where they
will fracture
• Responses were received from all nine but many companies
claimed confidentiality on the chemical composition
information
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EPA’s Approach on HF - Scientific Study
• Congress asked EPA to study relationship between hydraulic
fracturing and drinking water resources
• Peer-reviewed study currently underway, with first results due in late
2012
• Lifecycle approach, use of case studies, focus on sources and
pathways of potential impacts to water resources
• Stakeholder involvement throughout process
 Serious concerns have also been
raised about air quality, impacts on
land and aquatic ecosystems, seismic
risks, public safety and occupational
risks
 These topics are not within the scope
of the current study
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Study Plan Framework
Phases of the Hydraulic Fracturing Study
• Water acquisition
• Chemical mixing
• Well injection
• Flowback and produced water
• Water treatment and waste disposal
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Scientific Questions
Water Acquisition
• How do large volume water withdrawals from ground water
and surface water impact drinking water resources?
- What are the impacts on water availability?
- What are the impacts on water quality?
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Scientific Questions
Chemical Mixing
• What are the possible impacts of on-site spills and/or leaks
on drinking water resources?
- What is the composition of hydraulic fracturing fluids and
what are the toxic effects of the constituents?
- What factors may influence the likelihood of
contamination of drinking water resources?
- What practices are used to contain or mitigate
spills/leaks?
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Scientific Questions
Well Injection
• How might the fracturing process lead to contamination of
water resources by hydraulic fracturing chemicals or naturally
occurring substances?
- How effective are well construction practices at
containing fluids during and after fracturing?
- What are the potential impacts of pre-existing man-made
or natural pathways/features on contaminant transport?
- What chemical/physical/biological reactions could impact
the mobilization, transport, fate or toxicity of substances
in the subsurface?
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Scientific Questions
Flowback and Produced Water
• What are the possible impacts of on-site spills and/or leaks
on drinking water resources?
- What is the composition and variability of flowback and
produced water, and what are the toxic effects of these
constituents?
- What factors may influence the likelihood of
contamination of drinking water resources?
- What practices are used to contain or mitigate spills
and/or leaks?
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Scientific Questions
Water Treatment and Waste Disposal
• What are the possible impacts of inadequate treatment of
flowback and produced water on drinking water resources?
- How effective are treatment and disposal methods?
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Hydraulic Fracturing Study Timing
• 2011: Finalize study plan and conduct research
• 2012: Report of Preliminary Results
• 2014: Report of Further Results
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Possible Uses of Research Results
• Research will identify key drivers for impacts of hydraulic
fracturing activities on drinking water resources
• Results may be used by:
– Local, state, tribal and federal governments
– Communities
– Industry
– Environmental groups
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Acronyms
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•
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•
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•
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CAA - Clean Air Act
CERCLA - Comprehensive
Environmental Response,
Compensation & Liability Act
CWA - Clean Water Act
NEPA - National Environmental
Policy Act
NESHAPs - National Emission
Standards for Hazardous Air
Pollutants
NPDES - National Pollutant
Discharge Elimination System
NSPS - New Source Performance
Standards
•
•
•
•
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OPA - Oil Pollution Act
RCRA - Resource Conservation
and Recovery Act
SDWA - Safe Drinking Water Act
SPCC - Spill Prevention, Control,
and Countermeasures
UIC - Underground Injection
Control Program
Other EPA Statutory Authorities Which Could
Impact HF Activities
In addition to the SDWA, EPA can use existing authorities to
prevent contamination from oil and gas production activities.
For example:
• CWA discharges into publicly-owned treatment works (POTWs) and
surface waters
• CAA’s New Source Performance Standards (NSPS), National
Emission Standards for Hazardous Air Pollutants (NESHAPs), and
Mandatory Reporting of Greenhouse Gases
• NEPA’s authority to review and comment on federal actions (e.g.,
leasing on federal lands)
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Guidance and Regulation Development
• CWA: Regulations and guidance for
treatment and disposal of
production wastewater
• SDWA: Guidance to provide
framework for use of diesel fuel in
hydraulic fracturing fluids
• CAA: Proposing air regulations that
govern certain activities at well sites
• RCRA: Guidance on how to
construct proper wastewater pits
and impoundments
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 Continuing partnership with
states – on the frontlines of
regulating this sector
Emergency Response Authorities
SDWA 1431 order to address imminent
and substantial endangerment caused by
entry of pollutant into underground
source of drinking water
SDWA 1431 order to address
imminent and substantial
endangerment caused by entry of
pollutant into public water system
CERCLA 104 removal action to address
release that may present imminent and
substantial endangerment, subject to the
“petroleum exclusion”
CERCLA 106 order to address imminent
and substantial endangerment, subject to
the “petroleum exclusion”
CAA 303 action to address
imminent and substantial
endangerment of public health or
welfare, or the environment from air
emissions or pollution
RCRA 7003 action to address solid
waste handling that may present
imminent and substantial endangerment
to health or the environment
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CWA 504 action to address imminent
and substantial endangerment to
health, welfare or livelihood caused by
discharge from “pollution source”
CWA/OPA 311 action to address imminent
and substantial threat to public health or
welfare from discharges of oil or hazardous
substances to navigable waters
Find Out More About the UIC Program and
Keep Current on the HF Study
• EPA Underground Injection Control Website:
http://water.epa.gov/type/groundwater/uic/index.cfm
• EPA Hydraulic Fracturing Website:
http://water.epa.gov/type/groundwater/uic/class2/hydraulicfracturing/index.cfm
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Questions?
EPA REGION 7 - Water, Wetlands and Pesticides Division
Drinking Water Management Branch
UIC Program (WWPD/DRWM)
901 North 5th Street
Kansas City, Kansas 66101
Attention: Kurt Hildebrandt
Phone: (913) 551-7413
Fax: (913) 551-9413
e-mail: [email protected]
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