Hydraulic Fracturing and the Environment

Report
John F. Peiserich
Perkins & Trotter, PLLC
[email protected]
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The Clean Water Act regulates surface water discharges and storm-water runoff.
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The Clean Air Act sets rules for air emissions from engines, gas processing equipment
and other sources associated with drilling and production activities.
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The Safe Drinking Water Act regulates the disposal of fluid waste deep underground.
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The National Environmental Policy Act requires permits and environmental impact
assessments for drilling on federal lands.
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The Occupational Safety and Health Act sets standards to help keep workers safe. These
include requiring Material Safety Data Sheets be maintained and readily available onsite
for chemicals used at that location.
The Emergency Planning & Community Right-to-Know Act requires storage of regulated
chemicals in certain quantities to be reported annually to local and state emergency
responders.
The National Pipeline Safety Act sets standards for pipeline construction, operation and
maintenance administered by U.S. Department of Transportation.
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Arkansas Department of Environmental Quality
Arkansas Oil & Gas Commission
Arkansas Natural Resources Commission –
permitting of water use
* The U.S. Army Corps of Engineers administers
404 permitting which is predominately related to
potential impacts to surface water but requires
an ADEQ water quality certification.
 Physical:
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Well Casing Program
Cement Bond Log
Mechanical Integrity
Testing
Annulus Pressure
Monitoring
 Regulations:
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Federal Rules and
Regulations
Routinely Updated State
Rules and Regulations
Constituent Name Generic Name
Common Use
1,2,4
Trimethylbenzene
Alcohol, C12-16,
Ethoxylated
Aldehyde
Aromatic
Hydrocarbon
Alcohols,
Ethoxylated
Aldehyde
Paint, Mold Making Kit (Arts and Crafts), Unleaded Gasoline
Ammonium
Chloride
Ammonium
Phosphate
Crystalline Silica,
Quartz
Ethanol
Ethoxylated Fatty
Acid
Fatty Acid Tall Oil
Blend
Heavy Aromatic
Petroleum Naphtha
Industrial Cleaning Solution, Tire Repair, Agricultural Insecticide
HydrocarbonPetroleum Distillate
Yes
Hydrochloric
Acid
Inorganic Acid Table Olives, Unripened Cheese, Cottage Cheese
Yes
Hydrotreated Light
Petroleum Distillate
Isopropanol
Methanol
Oil Wood Stain, Air Freshener, Surface Cleaner Aerosol
Hydrocarbon –
Petroleum Distillate
Alcohol
Tape Head Cleaner, Hops Extract used for Beer, Air Freshener
Alcohol
Furniture Refinisher, Liquid Hand Soap, Windshield Washer Concentrate,
Hops Extract
Ketone
Paint Thinner, Wood Stain, Metal Adhesive, Automotive High Heat Paint
Yes
Polycyclic Aromatic Mothballs, Agricultural Insecticide, Heating Fuel Oil
Hydrocarbon
Ethoxylated Amine Toilet Bowl Cleaner
Yes
Methyl Isobutyl
Ketone
Naphthalene
Polyethoxylated
Fatty Amine Salt
Quaternary
Ammonium Salt
Sodium Chloride
Hazardous as Appears
on MSDS
Yes
Car Wash Liquid, Laundry Stain Remover, Air Freshener
No
Yes
Inorganic Salt
Metal Cutting Fluid, Non-Alcoholic Beverages, Ice Cream, Candy, Baked
Goods, Chewing Gum, Condiments and Meats
Hand Wash, Shampoo, Breakfast Cereal
Inorganic salt
Milk Products
No
Silica
Cat Litter, Tile Mortar, Arts & Crafts Ceramic Glaze
Yes
Alcohol
Ethoxylated Fatty
Acid
Tall Oil Fatty Acid
Ginseng, Deodorizer, Dish Soap, Cologne, Makeup (Mascara), Mouthwash
Household Multipurpose Cleaner, Laboratory Hand Cleaner
Yes
No
Car Polish, Industrial Hand Cleaner
No
Quaternary
Ammonium Salt
Inorganic Salt
Yes
Yes
Yes
No
No
Industrial and Commercial Water Acidity Neutralizing Solution
Yes
Macaroni and Noodle Products, Canned Corn, Tomato Concentrate, Frozen
No
As defined by OSHA Standard 1910.1200 (the OSHA Haz-com standard),
a hazardous chemical is one which is a physical hazard or a health hazard.
Health hazard means a chemical for which there is statistically significant
evidence based on at least one study conducted in accordance with established
scientific principles that acute or chronic health effects may occur in exposed
employees. The term "health hazard" includes chemicals which
are carcinogens, toxic or highly toxic agents, reproductive
toxins, irritants, corrosives, sensitizers,
hepatotoxins, nephrotoxins, neurotoxins, agents which act on the
hematopoietic system, and agents which damage the lungs, skin, eyes, or
mucous membranes.
Physical hazard means a chemical for which there is scientifically valid evidence
that it is a combustible liquid, a compressed gas, explosive, flammable,
an organic peroxide, an oxidizer, pyrophoric, unstable (reactive) or waterreactive.
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Jackson said natural gas creates less air pollution than other
fossil fuels “so increasing America’s natural gas production is a
good thing.”
She said Congress told the EPA to study the relationship between
fracking and drinking water. “We are doing that, with input from
technical experts, the public and industry,” she said.
“In the meantime, EPA will step in to protect local residents if a
driller jeopardizes clean water and the state government does
not act.”
Under questioning from a Pennsylvania Republican, Jackson said
she was “not aware of any proven case where the fracking
process itself” had affected water.
UPDATE – April 2012 – Jackson says “in no case have we made a
definitive determination that the fracing process has caused
chemicals to enter groundwater.” This is after Pavillion, WY.
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It is responsible for creating 2.8 million American jobs.
It is forecast to add 1 million U.S. manufacturing jobs over the next 15 years.
It has led to an annual increase in U.S. household disposable income of
$926.
Shale gas alone is forecast to contribute $933 billion revenues to federal,
state and local government coffers over the next 25 years, including helping
pay for schools, law enforcement and other essential municipal priorities.
It is the transportation fuel of choice of American cities large and small—as
they seek to save money and promote clean air through their bus fleets.
It has helped reduce U.S. power sector carbon emissions to levels not seen in
20 years as communities embrace this energy as a cleaner electricity choice.
It allowed the top 100 U.S. power producers to reduce by one-third
emissions of sulfur dioxide and smog-forming nitrogen oxide—in just a
two-year period.
And, as a transportation fuel it is allowing city bus fleets, large company
fleets (AT&T, UPS, Verizon, Waste Management, et al) to rely on an American
fuel that costs on average 40% less than diesel or gasoline.
North Little Rock and Mayor Hays have brought PUBLIC CNG to Central
Arkansas at $1.44 per gasoline gallon equivalent!
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It appears historic operations are the most likely
cause of potential groundwater and drinking
water issues. The O&G Industry risk of potential
water issues is no different from any other
industry that manages fluids.
The development of new technologies, improved
drilling and completion techniques, and “green”
completion fluids all add layers of protection for
water issues.
Public outreach is a necessary component of any
industrial activity and one that needs substantial
additional effort in the O&G Industry.

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