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Hydraulic Fracturing Operations

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Publishers at ScrivenerMartin Scrivener([email protected])

Phillip Carmical ([email protected])

Hydraulic Fracturing Operations

Nicholas P. Cheremisinoff , Ph.D. and Anton Davletshin

Edited byM. Dayal

Handbook of Environmental Management Practices

Copyright © 2015 by Scrivener Publishing LLC. All rights reserved.

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v

Contents

Preface xiAcknowledgements xixAuthor and Editor Biographies xxi

1 Hydraulic Fracturing Overview 11.1 Technology Overview 11.2 Benefi ts, Environmental Deterents, Hurdles and

Public Safety 61.2.1 Key Drivers 61.2.2 Environmental Deterrents 101.2.3 Hurdles and Public Safety 20

1.3 U.S. Resources and Standing 271.4 Worldwide Levels of Activity 361.5 Th e Role of Water 50

1.5.1 Water Acquisition 501.5.2 Chemical Mixing 511.5.3 Well Injection 52

2 Oil and Gas Regulations 532.1 U.S. Environmental Regulations 53

2.1.1 Resource Conservation and Recovery Act (RCRA) 532.1.2 Clean Water Act (CWA) 542.1.3 Oil Pollution Prevention (Spill Prevention,

Control and Countermeasures Regulations) 542.1.4 Oil Pollution Act (OPA) 552.1.5 Safe Drinking Water Act (SDWA) 552.1.6 Clean Air Act (CAA) 552.1.7 Emergency Planning and Community

Right-to-Know Act (EPCRA) 562.1.8 Comprehensive Environmental Response

Compensation, and Liability Act (CERCLA or Superfund) 56

2.1.9 Toxic Substances Control Act (TSCA) 57

vi Contents

2.2 Historical Evolution of Regulations Aff ecting Oil and Gas 592.3 RCRA Exemptions 662.4 Permitting Rules 73

2.4.1 California Rules 752.4.1.1 Restrictions 812.4.1.2 Conditions 81

3 Management of Chemicals 853.1 Memorandum of Agreement Between the

U.S. EPA and Industry 853.2 Chemicals Used 863.3 Safe Handling and Emergency Response to

Spills and Fires 923.4 Storage Tanks 1273.5 Risk Management 1333.6 Establishing a Spill Prevention, Control and

Countermeasures Plan 1413.6.1 Roles and Responsibilities 1453.6.2 Standard Procedures for Any Spill 1463.6.3 Training 150

4 Water Quality Standards and Wastewater 1534.1 Overview 1534.2 Water Quality Criteria, Standards, Parameters, and Limits 1554.3 Wastewater Characterization 1564.4 Wastewater Management Alternatives 1874.5 Water Treatment Technologies 193

4.5.1 Separators 1974.5.1.1 API Separators 197

4.5.2 Other Types of Separators 2074.5.3 Dissolved Gas Flotation 2094.5.4 Activated Carbon 2164.5.5 Nut Shell Filters 2284.5.6 Organi-Clay Adsorbants 2344.5.7 Chemical Oxidation 254

4.5.7.1 Chemistry 2544.5.8 UV Disinfection 2754.5.9 Biological Processes 280

Contents vii

4.5.10 Membrane Filtration 3004.5.11 RO and Nanofi ltration 3034.5.12 Air Stripping 3094.5.13 Chemical Precipitation 3234.5.14 Th ickeners 3394.5.15 Settling Ponds/Sedimentation 3484.5.16 Dissolved Air Flotation (DAF) 3514.5.17 Ion Exchange 3534.5.18 Crystallization 3604.5.19 Advanced Integrated Systems 378

4.6 Deep Well Injection of Wastes 3874.7 Overall Assessment of Wastewater Management

Alternatives 393

5 Water Utilization, Management, and Treatment 4015.1 Introduction 4015.2 Water Use by the Oil and Gas Energy Sector 4025.3 Overview of Water Management Practices 403

5.3.1 Characteristics of Hydraulic Fracturing Flowback Water 404

5.3.2 Characteristics of Produced Water 4075.3.3 Water and Mass Balances 409

5.4 Wastewater Treatment Technologies 4115.4.1 Infl uent Conditions 4125.4.2 Technology Evaluation 4135.4.3 Treatment End Points 4145.4.4 Regulatory Compliance 415

5.5 Alternatives to Conventional Wastewater Treatment 4165.5.1 Saltwater Disposal Well Solutions 4165.5.2 Ponding and Land Disposal 4175.5.3 Treatment for Recycle/Reuse 418

5.6 Project Management 4195.6.1 Planning and Implementing a New System 419

5.6.1.1 Phase I: Engineering Feasibility Study 4205.6.1.2 Phase II: Engineering Design 4215.6.1.3 Phase III: Procurement, Fabrication,

Construction, and Start-up 4225.6.2 Battery Limits and Interfaces 423

5.6.3 Mobile, Transportable, and Fixed Base Treatment Systems 424

5.6.4 Contract and Pricing 4245.6.5 Morphing Site Conditions 425

5.7 Economics of Wastewater Treatment 4265.7.1 Traditional Engineering Cost Estimating 4265.7.2 Accounting for Contingencies and Risk 4275.7.3 Current Pricing for Water Management Services 429

5.8 State-of-the-Art Water Management Project 4305.9 Special Challenges in the Oil and Gas Energy Sector 433

5.9.1 Overcoming an Image 4335.9.2 Morphing into a Recycle/Reuse Mode 4345.9.3 Concluding Remarks 435

References 435

6 Well Construction and Integrity 4376.1 Overview 4376.2 API Good Practices for Well Design and Construction 4406.3 Integrity Failure 446

6.3.1 Blow-Out Preventers 4616.4 Abandonment and Closure 4656.5 Best Practices for Site Operations 469References 474

7 Managing Air Pollution Discharges 4777.1 Th e Problem 4777.2 Methodology of Air Pollution Control 4837.3 Remote Sensing and Monitoring 4867.4 Leak Detection and Repair 493

7.4.1 Method 21 General Procedure 5027.4.2 Auditing Practices 503

7.5 Use of Flares 5097.5.1 Overview and Changing Practices 5097.5.2 Terminology 5107.5.3 Combustion Principles 5127.5.4 Ignition 5197.5.5 Flammability and Flammable Mixtures 5207.5.6 Gas Mixtures 525

viii Contents

7.5.7 Practical Applications 5267.5.8 MARAMA Guidelines for Calculating

Flare Emissions 5857.5.8.1 Vent Gas Air Pollutant Equation

Emission Factors 5857.5.8.2 Natural Gas Air Pollutant Equation

Emission Factors 5867.5.9 Propane and Butane Air Pollutant

Equation Emission Factors 5867.5.10 TCEQ New Source Review (NSR)

Emission Calculations 5897.5.11 AP-42, Compilation of Air Pollutant

Emission Factors 5927.6 Fugitive Dust Discharges 596

7.6.1 Particle Attributes and Potential Health Eff ects 5997.6.2 Estimating Dust Discharges 6027.6.3 Managing Dust Emissions 6127.6.4 Dust Monitoring 635

7.7 Compressor Stations 6407.8 Dehydrators 679

7.8.1 Recommended References 703

8 Macro Considerations of Environmental and Public Health Risks 7058.1 Overview 7058.2 Th e Challenges of Managing Water Resources 7078.3 Th e Challenges of Managing Air Quality 7168.4 Th e Challenges of Managing Greenhouse Gas Emissions 7298.5 Th e Challenges of Managing Man-Made Seismicity 737

Index 743

Contents ix

xi

Preface

Hydraulic fracturing, commonly referred to as fracking, is a technique used by the oil and gas industry to mine hydrocarbons trapped deep beneath the Earth’s surface. Th e principles underlying the technology are not new. Fracking was fi rst applied at the commercial level in the United States as early as 1947, and over the decades it has been applied in various countries including Canada, the United Kingdom, and Russia. Th e principle author worked with engineering teams up to 40 years ago in evaluating ways to improve oil and gas recovery from this practice. By and large fracking was not an economically competitive process and had limited applications until the last decade. Several factors altered the importance of this technology; among them signifi cant technological innovations in drilling practices with impressive high tech tools for exploration, well construction and integrity, and gas recovery along with the discoveries of massive natural gas reserves in the United States and other parts of the world. Th ese factors have cata-pulted the application of the technology to what is best described as the gold rush of the 21st century, with exploration and natural gas plays proceed-ing at a pace that seemingly is unrivaled by any recent historical industrial endeavor. Th is activity has invoked widespread criticism from concerned citizens and environmental groups in almost every nation across the globe.

Mass media education over environmental concerns for the applica-tion of the technology were touched off by and large by the documentary Gasland, a 2010 American fi lm which focuses on communities in the United States impacted by natural gas drilling and, specifi cally, the method of horizontal drilling into shale formations. Th e fi lm explores how commu-nities are being negatively aff ected where a natural gas drilling boom has been underway over the past decade. But this documentary alone is but one media form that has raised a general public outcry against the oil and gas industry sector’s application of the technology. Th e National Oceanic and Atmospheric Administration (NOAA) has reported on high rates of meth-ane leakage from natural gas fi elds and stated that if these are replicated, air

xii Preface

discharges would vitiate the climate benefi t of natural gas, even when used as an alternative to coal. Numerous studies have pointed to potential health risks to communities within close proximity of hydraulic fracturing opera-tions due to air pollution, both from fugitive dust emissions resulting from the construction stages of well drilling sites and from discharges of volatile organic vapors from well production and large-scale fl are gas practices. Other studies have raised concerns over the depletion and competition for groundwater resources, as the technology requires vast amounts of water. Concerns have also been raised over possible negative impacts to ground-water quality because of the reliance on a broad range of chemicals used for fracturing operations and the potential for well casing failures. While the chemicals used constitute a small percentage of the volume of total fracking fl uid required for a well, high water demands containing toxic chemical ingredients present signifi cant challenges in groundwater quality protection. Further concerns have been voiced concerning challenges in dealing with solid waste forms which include large quantities of salts, low-level radioactive wastes, and toxic heavy metals.

In the United States there seems to be almost hesitation on the part of the federal government to adequately address the risks of the technol-ogy. In March 2010, EPA announced its intention to conduct a study on the risks to groundwater in response to a request from the U.S. Congress. Since then, the Agency has held a series of public meetings aimed at receiving input from states, industry, environmental and public health groups, and individual citizens. EPA’s study was reviewed by the Science Advisory Board (SAB), an independent panel of scientists, to ensure the agency conducted the research using a scientifi cally sound approach. But it was not until 2011, that the EPA announced its fi nal research plan on hydraulic fracturing. Th e EPA’s fi nal study plan is intended to examine the full cycle of water in hydraulic fracturing, from the acquisition of the water, through the mixing of chemicals and actual fracturing, to the post-fractur-ing stage, including the management of fl ow-back and produced or used water as well as its ultimate treatment and disposal. Th e initial research results and study fi ndings were released to the public in 2012, but these fi nd-ings were inconclusive. It has been announced that the fi nal report will be delivered in 2014, but as of the writing of this volume, no formal evaluation had been published. Since 2011, the EPA has been reviewing their study on the eff ects of hydraulic fracturing but only on possible groundwater con-tamination near drilling sites in Wyoming. Up to this point in time, the EPA still hasn’t been able to conclusively determine that the chemicals they are detecting in groundwater are the result of hydraulic fracturing — which may explain why the Agency announced plans to abandon the study and instead

Preface xiii

returned the regulatory responsibilities back to the state of Wyoming.Further concerns lie with enforcement. Inspection and enforcement

of state and federal rules aimed at groundwater protection and land use planning are seemingly not being uniformly applied in the United States. Some states, as noted in this handbook, lack the infrastructure and man-power resources to properly inspect well site operations needed to verify well integrity and to ensure that best practices are being applied to chemi-cal and air pollution management. Such uneven and ambiguous enforce-ment actions on the part of state environmental regulators, leaves concerns and open-ended questions as to whether the accelerated pace of natural gas plays across North America are fully warranted. Th is raises further concerns for other countries where natural gas exploration is poised to expand. Th e U.S. has announced that as a matter of national policy frack-ing technologies will be shared with China, and clearly with the events in Ukraine and the geopolitical struggle that will draw that nation into the fold of NATO, fracking is likely have a sizable footprint in the future. Th ese countries lack enforcement infrastructure and basic instruments that are required to protect both the environment and public health.

Th ere is evidence to support that fracking practices are environmen-tally damaging and may pose signifi cant health risks to the general public through multiple pathways; however, one may make the same observa-tion for steelmaking, copper smelting, coal mining, coke-chemical plants, wood treating and many other industry sectors. Th ere are both poor and good industry practices, the latter which can mitigate or reduce risks sub-stantially; but they need to be practiced and there needs to be enforcement, and not simply voluntary adoption. Th ere needs to be commitment on the part of the oil and gas industry to invest into and adopt best practices and leading technologies for pollution management. In other industry sectors that are mature, there are well-developed controls with many decades of experience. Th is does not appear to be the case for water pollution man-agement; nor can it be said that air pollution is being managed aggres-sively with well-established practices and technologies that are applied in other industry sectors. Th is is not to say that technologies are not within reach and that the oil and gas industry is sitting idly. One would expect that advanced water treatment technologies, some already at semi-commercial stages, will play a more dominant role over the next several years. One may expect a combination of existing and newer technologies being applied to managing groundwater quality issues. But as noted in this volume, a more cohesive approach is needed to address air pollution.

More comprehensive consideration is needed by industry and regulators on the increased footprint of air pollution and its potential negative impacts

xiv Preface

on communities. In this regard, there are arguments on both sides of the fence concerning air quality management. It is widely recognized that the largest sources of air pollution and greenhouse gases are coal burning power plants. A typical (500 megawatt) coal plant burns about 1.4 million tons of coal each year. As of 2012, there are 572 operational coal plants in the U.S. with an average capacity of 547 megawatts. Coal-burning power plants constitute the greatest source of carbon dioxide (CO2) emissions, a primary cause of global warming. In 2011, utility coal plants in the United States emitted a total of 1.7 billion tons of CO2. A typical coal plant generates as much as 3.5 million tons of CO2 per year. Coal burning is a leading cause of smog, acid rain, and toxic air pollution. Pollutants that are released include:

• Sulfur dioxide (SO2) - Which takes a major toll on public health, including by contributing to the formation of small acid forming particulates that can penetrate into human lungs and be absorbed by the bloodstream. SO2 is also the leading cause of acid rain, which damages crops, forests, and soils, and acidifi es lakes and streams. A typical coal plant that is retrofi tted with modern emissions controls, including fl ue gas desulfurization can emit as much as 7,000 tons of SO2 per year.

• Nitrogen oxides (NOx) – Which is a leading cause ground level ozone, or smog, can burn lung tissue, exacerbate asthma, and make humans more susceptible to chronic respiratory diseases. A typical coal plant with emissions con-trols, including best available technology like selective cata-lytic reduction technology, emits 3,300 tons of NOx per year.

• Particulate matter – Sometimes referred to as soot or fl y ash, causes chronic bronchitis, aggravated asthma, and pre-mature death, as well as haze obstructing visibility. A typical uncontrolled plant can emit as much as 500 tons of small airborne particles each year.

• Mercury –For which coal plants are responsible for more than half of the U.S. emissions, is a toxic heavy metal that causes brain damage and heart problems. A typical uncon-trolled coal plants emits approximately 170 pounds of mer-cury each year. Less than 10% of the coal burning plants in the US rely on the best available technologies to control mer-cury discharges to air.

• Other harmful pollutants emitted annually from a typical, uncontrolled coal plant include lead, various toxic heavy

metals, and trace amounts of uranium, carbon monoxide, volatile organic compounds (VOC).

In a recent article, Chinese scientists have warned that the “country’s toxic air pollution is now so bad that it resembles a nuclear winter, slowing photosynthesis in plants – and potentially wreaking havoc on the coun-try’s food supply.” Beijing’s concentration of PM 2.5 particles – those small enough to penetrate deep into the lungs and enter the bloodstream – have been reported in the hundreds of micrograms per cubic meter, in contrast to the World Health Organization’s recommended safe level of 25 micro-grams per cubic meter. Th e worsening air pollution of that country has already exacted a signifi cant economic toll, grounding fl ights, closing high-ways and discouraging tourism. Much of China’s worsening air pollution may be linked to coal burning plants.

As a rough point of comparison, burning coal emits 206 pounds of car-bon dioxide per million British thermal units compared with 117 pounds per million Btu for natural gas, with profound reductions and elimination of the many chemicals associated with the air pollution from coal burning power plants. Th ese facts point towards the most profound reasons for sup-porting the fracking revolution – or do they? Clearly, over time, the shift to natural gas from coal and petroleum will reduce our environmental foot-print on Mother Earth, but there are other considerations. Investments into infrastructure needed to transition to a natural gas energy source on a scale that would benefi t global carbon footprint reduction are formidable. While U.S. energy experts point towards the U.S. as being posed to become a net energy exporter because of fracking, site is lost over the fact that there is lim-ited infrastructure such as few LNG plants that can capitalize on world mar-kets. LNG plants represent investments on the order of billions of dollars for a single facility and further raise additional concerns for public safety.

An accelerated transition to cleaner fuels seems unlikely in many parts of the world. While NATO has made bold statements on reducing dependency on Russian gas, a movement towards concrete commitment in major infra-structure investments has not been forthcoming. Th e large infrastructure investments that are needed for pipelines and LNG plants as well as trans-port fl eets and unloading stations to reach global markets are in various stages of planning, but seem to fall short of committed fi nancing for actual projects. Th ese needed investments, their detailed plans and environmental impact statements have yet to be formulated and carefully vetted for both

Preface xv

(see http://www.theguardian.com/world/2014/feb/25/china-toxic-air-pollution-nuclear-winter-scientists)

fi nancial and human risks. Th is is exemplifi ed by the fact that in some U.S. states where fracking operations are being conducted, more than 30% of the recovered gas has been reported to be fl ared (fl aring is the practice of burn-ing waste gases, subjecting communities to higher levels of air pollution).

Additional concerns addressed in this volume focus on the manner in which industry monitors and reports air pollution discharges. Air pollu-tion discharges are quantifi ed for reporting purposes based on calculation through the application of emission factors. Emission factors are ‘indus-try’ reported mass discharges expressed on a per unit value of production basis. Emission factors represent long-term averages of typical operations or pieces of equipment. Th ese factors do not take into consideration the age of controls, the condition of pollution controls, the degree of preven-tive maintenance applied by the operator to its controls and many other factors which may impact on control effi ciency. Furthermore, because emission factors are averages, they do not necessarily account for site-spe-cifi c operations, nor do they take into consideration the eff ects of transient operating conditions such as start-ups, shutdowns, malfunctions, surges, and various operational abnormalities which may result in high pollution discharge episodes. It may be argued that a fl awed methodology is relied on for quantifying air pollution discharges, whereby calculated aggregate estimates of pollution are accepted as being more precise than the applica-tion of real time measurements and control. Th ese calculation practices when coupled with air pollution modeling tools that are fi rst and foremost intended to meet statutory obligations for permits tend to lack formal pro-tocols for performing human health risk evaluations. Th ese represent areas of concern that should give lawmakers, industry and citizens impetus to take the time to step back to consider:

• placing greater resources and emphasis on regional and local planning for gas plays,

• investing into better pollution control technologies, • committing higher government allocations to support more

aggressive inspections and monitoring, • assigning higher levels of accountability by industry, • incorporating risk assessment tools into the permit process,

and • in closing loopholes in existing statutes in order to strengthen

environmental standards.

To quote Albert Einstein – “Concern for man himself and his fate must always form the chief interest of all technical endeavor. Never forget this in

xvi Preface

the midst of your diagrams and equations.” Einstein’s remarks emphasize the need to look before leaping.

Th e reader should not walk away with the impression that fracking is a technology that should not be invested into. To the contrary, it off ers the enormous potential for reducing the carbon footprint that is universally recognized by scientists around the world as causing harm to humans and Mother Earth. However, environmental management of this technology and practices employed need to be at the forefront.

Th is handbook was assembled for two reasons. First, it was felt that there are misunderstandings about the hydraulic fracturing technology among the general public. Part of this stems from disconnect between the language of engineers and that of laypersons. From that standpoint, there is attempt to explain the environmental issues and also to relay the fact that while the technology poses signifi cant environmental threats, there are both controls and good industry practices that that can manage a num-ber of the pollution concerns, but certainly not all. Without uniform and rigorous application of good industry practices coupled with the oversight of enforcement the public is placed at an indeterminate level of risk from the current gas play activities.

Th e second reason for assembling the handbook is to provide a road-map to the best practices and emerging technologies for pollution manage-ment. To this end, many chapters are written with practicing engineers and industry specialists in mind.

Th ere are eight chapters that span a range of topics addressing the basics of hydraulic fracturing operations, chemical management, U.S. environ-mental regulations, current and emerging technologies for water treatment, risk aversion, and air pollution control and management. Consideration has been given to the international scientifi c literature as well good industry practices promoted by authoritative bodies like the American Petroleum Institute, the American Institute of Chemical Engineers, and other recog-nized scientifi c and trade industry organizations. Although various com-panies and brand names are cited in this volume, the reader should not consider statements to refl ect any form of endorsement. Th e information presented in this handbook should be considered as survey oriented and not suitable for scale-up, design and operational purposes.

In addition to the contributors and individuals that assisted in the prep-aration of this volume, a special thank you is extended to the Publisher for its fi ne production of this volume.

Nicholas P. Cheremisinoff , Ph.D.Charles Town, West Virginia

Preface xvii

xix

Acknowledgements

Randy D. Horsak is a contributing author to this volume. Mr. Horsak is a scientist and registered Professional Engineer and Founder of the Marcellus Shale Water Group, LLC, with more than 40 years of experience in environmental science and engineering, including water and wastewa-ter treatment. He has managed and directed environmental projects in a variety of areas, including water and wastewater sampling and analysis, bench-scale and fi eld pilot studies, engineering economic evaluations, con-ceptual design of water and wastewater treatment systems involving the treatment of raw sewage, industrial waste, chemical-contaminated water, and pathogen-contaminated water. He has evaluated a wide array of tech-nologies: electro-coagulation, fi ltration, reverse osmosis, ultra-violet light purifi cation, ozonation, chlorination, carbon block fi ltration, and other systems. Mr. Horsak has authored more than 50 professional publications and serves as an expert witness in environmental science, engineering, and forensics. (3TM Consulting, LLC, Marcellus Shale Water Group, LLC, PO Box 941735, Houston, Texas USA 77094; (281) 752-6700; [email protected]; [email protected]).

Gary Bush is the President of Western FracVac, located in Edmonton, Alberta, Canada. Western FracVap provided corporate descriptions and information on the company’s technology for fracking fl uid water treat-ment applications.

Jay Radchenko is a Graphics and Research Specialist at No-Pollution Enterprises. He has contributed to this volume with the preparation of a number of the line drawings and various artwork.

xxi

Author and Editor Biographies

Nicholas P. Cheremisinoff is a chemical engineer with more than 40 years of industry, R&D and international business experience. He has worked extensively in the environmental management and pollution prevention fi elds, while also representing and consulting for private sector companies on new technologies for power generation, clean fuels and advanced water treatment technologies. He is a Principal of No Pollution Enterprises. He has led and implemented various technical assignments in parts of Russia, eastern Ukraine, the Balkans, Korea, in parts of the Middle East, and other regions of the world for such organizations as the U.S. Agency for International Development, the U.S. Trade & Development Agency, the World Bank Organization, and the private sector. Over his career he has served as a standard of care industry expert on a number of litigation mat-ters. As a contributor to the industrial press, he has authored, co-authored or edited more than 160 technical reference books concerning chemical engineering technologies and industry practices aimed at sound envi-ronmental management, safe work practices and public protection from harmful chemicals. He is cited in U.S. Congressional records concern-ing emerging environmental legislations, and is a graduate of Clarkson University (formally Clarkson College of Technology) where all three of his degrees - BSc, MSc, and Ph.D. were conferred.

Anton R. Davletshin is Program Manager at No Pollution Enterprises, a fi rm specializing in standard of care assessments. Anton oversees sampling and research programs, and conducts historical environmental impact assessments that aid in forensic reconstruction of legacy pollution prob-lems. His expertise also extends to application of air dispersion simula-tions using the EPA-approved AERMOD program used in the evaluation of community impacts from point and area sources of emissions from within industrial complexes. He is a FLIR certifi ed infrared thermogra-phy scientist, and oversees teams performing inspection of industrial

sites. A graduate of Virginia Polytechnic Institute, he holds a degree in Construction Management.

Mohit Dayal is a Senior Analyst and Project Manager for No Pollution Enterprises. Mr. Dayal is a 2008 graduate of Virginia Polytechnic Institute and holds a degree in Political Science focusing on Legal Studies. His expertise includes performing industrial data documentation and analysis, technical report analysis and data validation, as well as assisting scientifi c research and editing of publications.

xxii Author and Editor Biographies

1

1.1 Technology Overview

Oil and gas are naturally occurring hydrocarbons sought aft er by all of mankind because of their energy value and ability to manufacture an almost infi nite number of chemically derived products. Two elements, hydrogen and carbon, make up a hydrocarbon. Because hydrogen and car-bon have a strong attraction for each other, they form many compounds. Th e oil industry processes and refi nes crude hydrocarbons recovered from the Earth to create hydrocarbon products including: natural gas, lique-fi ed petroleum gas (LPG, or hydrogas), gasoline, kerosene, diesel fuel, and a vast array of synthetic materials such as nylon, plastics and polymers. Crude oil and natural gas occur in tiny openings of buried layers of rock. Occasionally, the crude hydrocarbons literally ooze to the surface in the form of a seep, or spring; but more oft en, rock layers trap the hydrocarbons thousands of feet below the surface. To harvest the trapped hydrocarbons to the surface, mankind drills wells.

1Hydraulic Fracturing Overview

2 Hydraulic Fracturing Operations

Th e simplest hydrocarbon is methane (CH4). It has one atom of carbon (C) and four atoms of hydrogen (H). Methane is a gas, under standard con-ditions of pressure and temperature. Standard pressure is the pressure the atmosphere exerts at sea level, about 14.7 psia (101 kPa). Standard tempera-ture is 60°F (15.6°C). Methane is the primary component in natural gas. Natural gas occurs in buried rock layers usually mixed with other hydrocar-bon gases and liquids. It may also contain non-hydrocarbon gases and liq-uids such as helium, carbon dioxide, nitrogen, water, and hydrogen sulfi de. Hydrogen sulfi de is toxic and corrosive – it has a detectible sour or rotten-egg odor, even in low concentrations. Natural gas that contains hydrogen sulfi de is called sour gas. Aft er natural gas is produced or recovered, a gas processing facility removes impurities so consumers can use the gas.

Hydraulic fracturing is a technique used by the oil and gas industry to mine hydrocarbons trapped deep beneath the Earth’s surface. Hydraulic fracturing, also known as “fracking” or fracturing is an industry-wide practice that has received signifi cant attention and increased scrutiny from the media and environmental community. Fracturing involves the injec-tion of water, sand and chemicals under pressure into prospective rock for-mations to stimulate oil and natural gas production. In recent years there has been a dramatic rise in unconventional natural gas and oil production largely attributable to the application of fracturing technology. Th e basic technology is comprised of the following. Vertical well bores are drilled thousands of feet into the earth, through sediment layers, the water table, and shale rock formations with the objective of reaching oil and gas depos-its. Drilling operations are then angled horizontally, where a cement casing is installed and is intended to serve as a conduit for the massive volume of water, fracking fl uid, chemicals and sand needed to fracture the rock and shale. In some cases, prior to the injection of fl uids, it is necessary to employ small explosives in order to open up the bedrock. Th e fractures allow the gas and oil to be removed from the formerly impervious rock formations.

Fracking has technically been in existence for many decades, however, the scale and type of drilling now taking place (i.e., deep fracking) is a new form of drilling and was fi rst used in the Barnett shale of Texas in 1999. Figure 1.1 illustrates the basic principles of the technology.

Th e science and engineering behind the use of horizontal wells is very much an evolving technology. Horizontal wells are viewed by the oil and gas industry as off ering benefi ts that improve the production performance for certain types of producing formations. Horizontal wells allow operators to develop resources with signifi cantly fewer wells than may be required with vertical wells – operators can drill multiple horizontal wells from a

Hydraulic Fracturing Overview 3

single surface location, thereby, reducing the cumulative surface footprint and impact of the development operation. On the other hand, horizon-tal wells are signifi cantly more expensive to drill and maintain. In some areas, the cost of a horizontal well may be 2–3 times the cost of a vertical well. Horizontal wells are typically drilled vertically to a “kick-off ” point where the drill bit is gradually re-oriented from vertical to horizontal. Figure 1.2 is a schematic, which illustrates a vertical and horizontal well for comparison.

In horizontal wells, an “open-hole” completion is an alternative to setting the casing through the producing formation to the total depth of the well. In this case, the bottom of the production casing is installed at the top of the productive formation or open-hole section of the well. In this alternative, the producing portion of the well is the horizon-tal portion of the hole and it is entirely in the producing formation. In some instances, a short section of steel casing that runs up into the production casing, but not back to the surface, may be installed. Alternatively, a slotted or pre-perforated steel casing may be installed in the open-hole portion. These alternatives are generally referred to by the industry as a “production liner,” and are typically not cemented into place. In the case of an open-hole completion, tail cement is extended above the top of the confining formation (the formation that limits the vertical growth of the fracture).

Figure 1.1 Illustration of the basic fracking process.

Fracking Fluid

Shallow Aquifier

Deep Aquifier

Aquiclude

Pre-ExistingFault

InducedSeismicity

Gas-BearingFormation

Casing

HydraulicFractures

Methane

Aquiclude

Wastewater Ponds


Th e term reservoir refers to the subsurface hydrocarbon bearing for-mation. An important term applied in hydraulic fracturing is perforating. A perforation is the hole that is created between the casing or liner into the reservoir. Th is hole allows communication to the inside of the produc-tion casing, and is the hole through which oil or gas is produced. By far the most common perforating method utilizes jet-perforating guns that are loaded with specialized shaped explosive charges. Figure 1.3 illustrates the perforation process. Th e shaped charge is detonated and a jet of hot, high-pressure gas vaporizes the steel pipe, cement, and formation in its path. Th e result is an isolated tunnel that connects the inside of the produc-tion casing to the formation. Th e cement isolates these channels or tunnels. Th e producing zone itself is isolated outside the production casing by the cement above and below the zone.

Hydraulic fracturing is not a new technology – rather its origins go back to as early as the late 1940s as a well stimulation technique. Ultra-low per-meability formations such as fi ne sand and shale tend to have fi ne grains or limited porosity and few interconnected pores (low permeability). Th e term permeability refers to the ability for a fl uid to fl ow through a porous rock. In order for natural gas or oil to be produced from low permeability reservoirs, individual molecules of fl uid must fi nd their way through a tor-tuous path to the well. Hydraulic fracturing facilitates the process because without it too little oil and/or gas would be recoverable and the cost to drill and complete the well would be impractical based on the rate of recovery.

Th e process of hydraulic fracturing increases the exposed area of the producing formation, thus creating a high conductivity path that extends from the wellbore through a targeted hydrocarbon bearing formation over a signifi cant distance – subsequently, hydrocarbons and other fl uids can

Figure 1.2 Illustrates horizontal and vertical wells.


fl ow more readily from the formation rock, into the fracture, and ultimately to the wellbore. Hydraulic fracturing treatments rely on state-of-the-art soft ware programs and are an integral part of the design and construction of the well. Pretreatment quality control and testing are considered integral actions in producing wells.

During fracking, fl uid is pumped into the production casing, through the perforations (or open hole), and into the targeted formation at pres-sures high enough to cause the rock within the targeted formation to fracture. Th is is referred to as “breaking down” the formation. As high-pressure fl uid injection continues, this fracture can continue to grow, or propagate. Th e rate at which fl uid is pumped must be fast enough that the pressure necessary to propagate the fracture is maintained. Th is pressure is referred to as the propagation pressure or extension pressure. As the fracture continues to propagate, a proppant (e.g., sand) is added to the fl uid. When the pumping is stopped, and the excess pressure is removed, the fracture attempts to close. Th e proppant serves the purpose of keeping the fracture open, allowing fl uids to then fl ow more readily through this higher perme-ability fracture.

Some of the fracturing fl uid may leave the fracture and enter the tar-geted formation adjacent to the created fracture (i.e. untreated forma-tion). Th is phenomenon is known as fl uid leak-off . Th is fl uid fl ows into the micropores of the formation or into existing natural fractures in the forma-tion or into small fractures opened and propagated into the formation by the pressure in the induced fracture. Th e fracture tends to propagate along the path of least resistance. Since this technology has been practiced for many years, experience allows predictable characteristics or physical prop-erties regarding the path of least resistance for horizontally and vertically formed fractures.

In executing hydraulic fracturing operations, a fl uid must be pumped into the well’s production casing at high pressure. It is necessary that

Figure 1.3 Illustrates the process of perforation.

DetonationCord

PerforatingGun

Cement

JetCharge Casing Formation


production casing has been installed and cemented and that it is capable of withstanding the pressure that it will be subjected to during hydraulic frac-ture operations. Th e production casing in some applications is not exposed to high pressure except during hydraulic fracturing. In these cases, a high-pressure “frac string” may be used to pump the fl uids into the well to iso-late the production casing from the high treatment pressure. Once the hydraulic fracturing operations are complete, the frac string is removed.

Hydraulic fracturing operations employ a host of specialized equipment and materials. Th e required equipment includes storage tanks, proppant transport equipment, blending equipment, pumping equipment, and ancil-lary equipment such as hoses, piping, valves, and manifolds. Hydraulic fracturing service companies also provide specialized monitoring and con-trol equipment that is required in order to carry out a successful execution. During the fracture treatment, data are being collected from the various units, and sent to monitoring equipment – various data collected include fl uid rate coming from the storage tanks, slurry rate being delivered to the high-pressure pumps, wellhead treatment pressure, density of the slurry, sand concentration, chemical rate, etc.

1.2 Benefi ts, Environmental Deterents, Hurdles and Public Safety

1.2.1 Key DriversKey drivers for fracking are energy independence, jobs and the possibil-ity of the U.S. becoming a major LNG (liquefi ed natural gas) exporter. Th ese are obvious from changes in market forces over the past decade. Shale gas production in North America has caused a collapse of natural gas market forces over expectations that the U.S. could become a major exporter of LNG. North American natural gas prices collapsed from over $10 per million British thermal units (MMBtu) in 2008, to under $3/ MMBtu at various times during 2012. On the other hand, gas prices in Asia and Europe remain strong, thus creating huge spreads above U.S. prices. Th e large price spreads between the U.S. and other regions of the world have enticed foreign buyers to seek sources of lower cost gas – thus North American supplies are quite attractive. Obviously, North American producers are eager to capture higher prices off ered in overseas markets. Th ese drivers have prompted U.S. LNG project developers to submit plans for multiple LNG export projects to the U.S. Department of Energy (DOE) for approval.


Deloitte MarketPoint1 published a global market study in which they applied a model to assess gas prices and quantities simultaneously across multiple markets over a 30-year time horizon based on microeconomic theories. Th ey examined multiple market scenarios, analyzing the impact of 6 Bcfd of U.S. LNG exports shipped to either Asia or Europe. Th e 6 Bcfd of exports is not a projection of the volumes that might be economic to export, but rather an assumption to enable evaluation of the possible impacts that might arise. Th ey then compared the results of each export case to a reference case with no U.S. LNG exports to determine potential price impacts and supply displacements. Th eir published fi ndings reported the following:

• One scenario supports U.S. LNG exports hastening the transition away from oil price indexation of gas supply contracts. Th ey note that decoupling from oil-indexed prices is already occurring in some European markets and potentially could happen in Asian markets, pointing to the projected growth in Australian LNG as a factor. Th ey state that if Asian markets decouple from oil-indexed prices, their prices could drop sharply over the next several years. Since supplies for U.S. LNG exports are expected to be pegged to U.S. gas prices, rather than oil prices, the incre-mental volumes could result in global gas markets transi-tioning more rapidly to prices set by “gas-on-gas” market competition.

• Deloitte reports that prices are projected to “decrease fairly signifi cantly in regions importing U.S. LNG, but only mar-ginally increase in the U.S.”

• U.S. LNG exports are projected to narrow the price diff er-ence between the U.S. and export markets. Th ey conclude that the market “will likely limit the volume of economically viable U.S. LNG exports.” Th eir observation is that as prices in the U.S. fi rm and prices in export markets soft en, the mar-gins between the U.S. and global markets will narrow and limit the LNG export volumes even without government intervention.

1 Exporting the American Renaissance: Global Impacts of LNG Exports from the United States, Report by the Deloitte Center for Energy Solutions and Deloitte Market Point LLC, 2013, www.deloittemarketpoint.com.


• U.S. LNG exports are projected to provide an economic ben-efi t to gas importing countries. As the price impact in the U.S. is projected to be fairly minimal, the global impact could be more than what the relative size of 6 Bcfd of exports might indicate. Because of the embedded take-or-pay volumes in long-term gas supply contracts and limited regional pro-duction in many parts of the world, U.S. LNG exports could reduce global prices and cost of supplies for gas importers.

• Not surprising, their study notes that gas-exporting coun-tries could suff er a decline in trade revenue due to price ero-sion and/or supply displacement. Th e entry of new supply would benefi ts consumers, but negatively impacts suppliers through price reductions and/or direct displacement of their export volumes. Th ey note also that even if gas supply in a region is not directly displaced by U.S. LNG exports, its pro-ducers might suff er decline in revenues due to lower prices aff ecting the region.

• Gas exporting countries could face increased pressure to adopt market-based gas prices in lieu of oil-indexed prices. As the world’s largest gas exporter by both volume and reve-nue and a high cost gas provider into Europe, Russia appears to be particularly vulnerable, especially if U.S. LNG exports are shipped to Europe.

• U.S. LNG exports could also displace some oil consump-tion through increased gas-fi red electric power generation. Deloitte reports the potential for oil displacement in electric generation may be as high as 5 million barrels per day glob-ally. Th e availability of competitively priced gas could incen-tivize displacement of oil-fi red power generation, which would also provide environmental benefi ts through lower carbon emissions.

API has published a pamphlet titled Freeing Up Energy: Hydraulic Fracturing - Unlocking America’s Natural Gas Resources (July 19, 2010, www.api.org). Th e following information summarizes the API’s position on the application of the technology.

API notes that the clean burning natural gas is critical to U.S. manufac-turing jobs, to farmers for fertilizer, to households for heating and cook-ing, to businesses for electricity and fuel for transportation needs, and to society to help address climate change concerns because of its low carbon-content. In short, natural gas is viewed as a green source of energy.


According to the API, hydraulic fracturing is a proven technology used safely for more than 60 years in more than a million wells. While this state-ment is true, the early technologies that have been applied by the petro-leum industry may be argued as being highly polluting to groundwater and relied on toxic chemicals such as kerosene and bunker oil. Nonetheless, API’s general statement of the technology’s origin stretching back six decades is accurate. Th e fi rst use to the technology in the U.S. stretches back to 1947. Th e API points out that since hydraulic fracturing was devel-oped in the 1940s, it has helped produce more than 600 trillion cubic feet of natural gas and 7 billion barrels of oil.

According to the API, hydraulic fracturing is so important that “with-out it, we would lose 45 percent of domestic natural gas production and 17 percent of our oil production within fi ve years.” API’s statement how-ever, is based on an industry study2, which was written in support of the technology, is not a critical assessment, and ignores renewable and other energy sources.

Th e API notes that the technology off ers the advantage of harvesting “abundant, clean-burning, domestic, reliable supplies of natural gas” which should translate into more aff ordable and more stable prices. It notes that this means that once net natural gas importers, like New York and Pennsylvania, could instead become natural gas exporters; and that energy intensive manufacturing companies, which had been moving overseas for cheaper energy, can remain domestic. Conceptually these arguments support the likelihood of higher employment. In support of these argu-ments, API notes that the development of the Marcellus Shale play has the potential to be the second largest natural gas fi eld in the world. API notes a study from 2009, which points to the development of this resource add-ing over 44,000 new jobs in Pennsylvania, $389 million in state and local tax revenue, over $1 billion in federal tax revenue, and nearly $4 billion in value-added to the state’s economy.3 Th e API notes4 that in West Virginia it created over 13,000 new jobs, and contributed over $220 million in federal, state, and local tax revenue and $939 million in value added to the state’s

2 Global Insight, “Measuring the Economic and Energy Impacts of Proposals to Regulate Hydraulic Fracturing,” 2009.3 Timothy J. Considine, Robert Watson, Seth Blumsack, “Th e Economic Impacts of the Pennsylvania Marcellus Shale Natural Gas Play: An Update,” Pennsylvania State University, May 24, 2010.4 Timothy J. Considine, “Th e Economic Impacts of the Marcellus Shale: Implications for New York, Pennsylvania, and West Virginia,” Natural Resources Economics, Inc., July 14, 2010.


economy. According to the API and the industry sponsored studies it cites, over the next decade, the development of Marcellus shale could generate nearly 300,000 new jobs, over $6 billion in federal, state, and local tax rev-enue and nearly $25 billion in value added to the economy by 2020.

Th e API reports that there are a “comprehensive set of federal, state, and local laws” which addresses every aspect of exploration and production operations, including well design, location, spacing, operation, water and waste management and disposal, air emissions, wildlife protection, surface impacts, and health and safety. It notes that in “addition to government oversight, new industry standards advance operations and practices” off er added levels of protection, and that the industry has created a number of guidance documents and other initiatives relating to hydraulic fractur-ing, including recommended practices for environmental protection for onshore oil and natural gas production and leases, well construction and well integrity, water use management, and surface environmental consid-erations. Some of these claims are challenged in this volume.

Th e Deloitte study along with the API literature present the case for shale gas development on a large and accelerated scale. On the other hand, there are many factors to consider beyond pricing and global market cap-ture and forces. Environmental and health and safety impacts as well as huge investments needed for storage and supply represent major concerns and hurdles.

1.2.2 Environmental DeterrentsTh e application of fracking technology to the extraction of natural gas is highly controversial, with many critics arguing that the pace of the appli-cation of the technology is too rapid and has not taken into consider-ation potential negative environmental impacts. Th e rapid deployment of the technology is demonstrated by the fact that natural gas reserves have grown between 2005 and 2010 by as much as 30 percent. Over the last few years the U.S. has increased onshore natural gas production by more than 20 percent. Th ere is substantial evidence in support of rising environ-mental concerns in the following areas:

• Contamination of groundwater• Methane and VOC pollution and its impact on climate

change• Air pollution impacts• Human exposure to toxic chemicals• Blowouts due to gas explosion


• Waste disposal• Large volume water use in water-defi cient regions• Fracking-induced earthquakes• Workplace safety• Natural infrastructure degradation

Statutory restrictions that have been established are both highly sup-portive of industrial expansion of gas plays and there is ample evidence in support of the observation that there is inadequate enforcement of envi-ronmental regulations. One study5 reports the numbers of fracking site inspections and available regulatory staff by state; see Table 1.1. Th ese data support the conclusion that state regulatory agencies are grossly under-staff ed to perform well site and facility operations evenly. As noted in the study – “it is reasonable to assume that an inspector who conducted fewer than 500 inspections did so in a much more thorough manner than an inspector who conducted double or triple that number. However, this may not be entirely accurate as those carrying out fewer inspections may have had to inspect more drilling, cementing, stimulation, and plugging opera-tions, which are likely to take more time than an inspection of a producing well site… the diff erence between having to conduct several hundred versus more than 1,000 inspections is quite dramatic, and shows that inspectors in

5 Breaking All the Rules: Th e Crisis in Oil & Gas Regulatory Enforcement, Earthworks, Washington, D.C., Sept. 2012.

Table 1.1 State-by-state comparison of inspection staff and activity in 2010.

State No. Inspectors No. Inspections Inspections per Inspector

Colorado 15 16,228 1,082

New Mexico 12 20,780 1,732

New York 16 2,460 154

Ohio 21 10,472 499

Pennsylvania 65 15,368 236

Texas 88 121,123 1,376

Source: Breaking All the Rules: Th e Crisis in Oil & Gas Regulatory Enforcement, Earthworks, Washington, D.C., Sept. 2012


states like Colorado, Texas and New Mexico have much greater inspection burdens than their counterparts in New York, Pennsylvania and Ohio.”

In contrast, the API points to an authoritative study conducted by the Groundwater Protection Counsel (GWPC).6 Th e U.S. Department of Energy participated in this study, which lends it considerable credibility. API notes that when the GWPC studied the environmental risk of hydrau-lic fracturing, “they found one complaint in the more than 10,000 coalbed methane wells reviewed. It noted further that the EPA initiated a study7 of coalbed methane hydraulic fracturing environmental risks and released its completed study in June 2004, noting no signifi cant environmental risks when proper hydraulic fracturing practices are followed.

Th e GWPC noted that the state regulation of oil and natural gas explora-tion and production activities are approved under state laws that typically include a prohibition against causing harm to the environment. Rightly so, they note that this premise is at the heart of the regulatory process. Th e GWPC noted that the regulation of oil and gas fi eld activities is managed best at the state level where regional and local conditions are understood and where regulations can be tailored to fi t the needs of the local environ-ment. Hence, the experience, knowledge and information necessary to reg-ulate eff ectively most commonly rests with state regulatory agencies. But this study fails to be convincing that adequate inspection and enforcement actually exists. Th e GWPC notes that state agencies use programmatic tools and documents to apply state laws including regulations, formal and informal guidance, fi eld rules, and Best Management Practices (BMPs), and that states are equipped to conduct fi eld inspections, enforcement/oversight, and witnessing of specifi c operations like well construction, test-ing and plugging; but again the study does not address the adequacy of the inspection and enforcement capabilities. Rather, the study “evaluates the language of state oil and gas regulations as they relate to the direct protec-tion of water resources. It is not an evaluation of state programs.”

Th e GWPC did review the following areas:

• permitting• well construction

6 Ground Water Protection Council, “State Oil and Gas Regulations Designed to Protect Water Resources,” May 27, 2009.7 Environmental Protection Agency, “Evaluation of Impacts to Underground Sources of Drinking Water by Hydraulic Fracturing of Coalbed Methane Reservoirs; National Study Final Report,” PEA 816-F-04-17, June 2004.


• hydraulic fracturing• temporary abandonment• well plugging• tanks• pits• waste handling and spills

Within each area specifi c sub-areas were included to broaden the scope of the GWPC’s review. For example, in the area of pits, a review was con-ducted of sub-areas such as pit liners, siting, construction, use, duration and closure. Th e selection of the twenty-seven states for this study was based upon the last full-year list (2007) of producing states compiled by the U.S. Energy Information Administration. In the area of well construction, state regulations were evaluated to determine whether the setting of sur-face casing below groundwater zones was required, whether cement circu-lation on surface casing was also required, and whether the state utilized recognized cement standards. It is in part the focus of the present volume to summarize a number of these best management practices.

Many of the industry statements seem reassuring, but very few are sup-ported by strong factual evidence. Let us take a moment to look a little more closely at the benefi ts and why the technology has been so con-troversial to many. One of the obvious impacts of the shale oil and gas boom in the U.S. is that it has shift ed the balance in global energy mar-kets, giving the U.S. new leverage as an exporter, despite the Middle East retaining a pivotal role. Th e rise of shale-based hydrocarbons has meant a crucial change for the U.S. which may possibly change the U.S. from being world’s leading importer of oil to a net exporter over the next few years. Indeed within a decade industry analysts and government offi cials have gone from projecting that the United States was in danger of running out of gas to reporting that the U.S. now has gas supplies that may well fuel the county over the next century. Th ere has been an eightfold increase in shale gas production over the last ten years alone. According to the Energy Information Administration, shale gas will account for nearly half of the natural gas produced in the U.S. by 2035. Th is large and rapid expansion has and is creating an enormous industrial and unavoidable environmen-tal footprint.

Th ere are indeed of billions of dollars in revenues associated with the fracking frenzy, with the oil & gas industry touting hundreds of thousands of new jobs. Economic impacts are already apparent – within the last 5 years U.S. crude oil production has risen 32 percent. USDOE statistics for 2012 alone shows that domestic oil production increased as much as


14 percent from the previous year, to 6.4 million barrels a day. One source8 reports that according to the International Energy Agency the United States could become the number one producer of oil by 2017, surpassing the cur-rent leaders Saudi Arabia and Russia. Over the last decade, the oil and gas industry has drilled thousands of new wells in the Rocky Mountain region and in the South and has expanded operations in the eastern region of the country as well in areas such as the Marcellus Shale play, which stretches from West Virginia into western New York.

But all of these realized and projected benefi ts carry a heavy toll for the environment and the health of citizens. While there appear to be reasonable technologies and good industry practices to manage groundwater and air pollution, there is clear evidence of failure to provide adequate safeguards and oversight to protect communities from harm by the rapid expansion of fossil fuel production using hydraulic fracturing. Th is concern is likely to be even more pronounced in other countries like China and parts of Eastern Europe as well as Mexico as the technology takes hold in regions where regulatory infrastructure and enforcement instruments are poor at best.

In the United States as well as other countries there appears to be an ill-defi ned policy towards the implementation of hydraulic fracturing. Th is lack places the world public at the mercy of industry and the geopolitical interests. Areas where there seem to be ill-defi ned policies:

1. Placing restrictions on development in sensitive lands, includ-ing critical watersheds. Th ere need to be rational restrictions which simply prohibit hydraulic fracturing in areas which are sensitive ecosystems for reasons which should be obvi-ous to even the most ardent industry supporter.

2. Establishing and enforcing strict clean air standards that ensure methane leaks and other VOC discharges are sig-nifi cantly below one percent of production with a commit-ment to reducing global warming pollution and providing industry incentives for investing into green technologies and practices to reduce air pollution discharges. Th e oil indus-try has a dismal record of controlling leaks and fugitive air pollution discharges. A report prepared for the U.S. House of Representatives9 documented that oil refi neries vastly

8 http://phys.org/news/2012-12-fracking-shift s-global-energy.html.9 U.S. House of Representatives, Nov. 10, 1999 report for Rep. H. A. Waxman, Oil Refi neries Fail to Report millions of Pounds of Harmful Emissions.


underreport leaks from valves to federal and state regula-tors and that these unreported fugitive air discharges from oil refi neries add millions of pounds of harmful pollutants to the atmosphere each year, including over 80 million pounds of volatile organic compounds (VOCs) and over 15 million pounds of toxic pollutants. Th e report documents the failure of oil refi neries to control fugitive air pollution discharges from equipment leaks, such as valves, storage tanks, and other industrial equipment. Th e industry’s lack of attention to controlling fugitive air discharges from refi neries is all the more reason why strict clean air standards are a necessity for controlling the air discharges from many thousands of hydraulic fracturing well operations.

3. Policies aimed at mandating the use of best available tech-nologies for well drilling and construction standards by requiring the strongest well siting, casing and cementing and other drilling best practices. Th e industry claims that it does this already in numerous oil and gas publications; however, studies (discussed later in this volume) show that well failures are much more common than the industry sec-tor has admitted to. A zero tolerance for well failures would require industry stakeholders to adopt the best practices and technologies, not take risks, and not cut corners.

4. Loopholes in the Clean Air Act, Clean Water and Safe Drinking Water Act, and the Resource Conservation and Recovery Act enable less than adequate protection of the landscape, air, and water from pollution. Th ese loopholes need to be abolished and consistent terminology applied to oil and gas waste based on the same criteria and standards as other types of hazardous waste. Th e oil industry has lobbied the U.S. Congress quite eff ectively thereby allowing exemp-tions for oil drilling wastes to be defi ned as non-hazardous from a regulatory standpoint. Th is is contrary to scientifi c understanding of the properties of petroleum wastes, which support the presence of benzene, PAHs and various carcino-gens. Th e closing of loopholes needs to be further strength-ened by robust inspection and enforcement programs, and a full disclosure and reporting of all chemical ingredients used for hydraulic fracturing operations.

5. Existing policies require strengthening and rewriting to enable communities to protect themselves and their future


by restricting fracking through comprehensive land devel-opment zoning and planning. Th e National Environmental Policy Act (NEPA) is a federal piece of legislation in the United States that was passed in 1969. Its intent was to make sure that any infrastructure investment be carefully planned before deployment of resources. In short, it was the fi rst time that the U.S. established a formalized policy towards the need for preparing environmental impact state-ments whereby the public, government and industry are to be aff orded an opportunity to look before leaping into a land development program. But NEPA seems to be almost for-gotten, or at least considerably watered down, with elements almost ignored in the race towards rapid commercializa-tion by the oil and gas industry. Th is is never more apparent than by the fact that fracking practices place an enormous toll and competition on local groundwater resources, ignor-ing long term groundwater recharging issues and turning a blind eye to the competition for agriculture, community life support and other industry needs for groundwater sources. Compounding this is a seemingly blind rush to rapid com-mercialization without giving consideration and planning to wastewater and solid waste management issues that are cre-ated from the application of hydraulic fracturing.

6. Despite much rhetoric, the U.S. has little credibility for hav-ing a formal policy to curtail global warming. Th e Obama administration has been quick to off er sharing and deploy-ing fracking technology in China without consideration or concern given to the lack of environmental laws and enforcement instruments in that country or any other coun-try it has interfaced with or imposed its will upon. Th rough programs funded through the U.S. Agency for International Development it has now turned its eye to the Ukraine, which has among the largest gas reserves in Europe and perhaps the weakest environmental enforcement programs. Clearly, technologically advanced countries like the United States have an obligation to establish and implement policies that sustain our Earth and prevent the citizens of other nations from being harmed. As a nation we have policies that restrict the sharing of certain technologies with other countries when we perceive that those nations follow poor practices or pose threats to world stability. Th ese policies seem largely


self-centered and there is an apparent lack of commitment towards protecting human health in other countries.

7. Policies concerning public safety need strengthening with greater degrees of accountability for companies that take high risks and cut corners. Th is is especially important in lieu of the fact that as many as 40 major LNG plant proj-ects have been proposed to the U.S.DOE not to mention the thousands of drilling site operations taking place across the U.S. Th e oil and gas industry has had some horrifi c indus-trial accidents in recent years, which have resulted in deaths and enormous economic losses to neighboring businesses and communities. Examples are:• On March 23, 2005 the BP Texas City Refi nery had a cata-

strophic explosion. Texas City refi nery is located 40 miles from Houston in Texas. About 1600 people work at the refi nery plus contractors. It is one of the largest refi neries in the USA, processing 460,000 barrels of crude oil/day, around 3% of gasoline U.S. supplies. A series of explosions occurred at this refi nery during the restarting of a hydro-carbon isomerization unit. Fift een workers were killed and 180 others were injured. Many of the victims were in or around work trailers located near an atmospheric vent stack. Th e explosions occurred when a distillation tower fl ooded with hydrocarbons and was over-pressur-ized, causing a geyser-like release from the vent stack. Th e Chemical Safety Board noted a poor safety culture in its investigation. Th e refi nery leadership applied pressure to increase production. It was fond that production and budget compliance were rewarded above everything else. In addition, there was a very high turnover rate of the leader-ship team. Th is resulted in a lack of ownership for issues that did not have immediate payouts. Maintenance and operat-ing procedures were inadequate, safety studies were years overdue, and hazard analysis was poor. Site leadership let the standards slip and didn’t prioritize process safety.

• Th e Deepwater Horizon oil spill (also referred to as the BP oil spill, the BP oil disaster, the Gulf of Mexico oil spill, and the Macondo blowout) began on 20 April 2010 in the Gulf of Mexico on the BP-operated Macondao Prospect. Th is incident claimed eleven lives and is considered the largest accidental marine oil spill in the history of the


petroleum industry. Following the explosion and sinking of the Deepwater Horizon oil rig, a sea-fl oor oil gusher fl owed for 87 days, until it was capped on 15 July 2010. Th e US Government estimated the total discharge at 4.9 mil-lion barrels (210 million US gal). Aft er several failed eff orts to contain the fl ow, the well was declared sealed on 19 September 2010; however there are various reports that indicate the well site continues to leak. A massive response ensued to protect beaches, wetlands and estuaries from the spreading oil utilizing skimmer ships, fl oating booms, con-trolled burns and 1.84 million US gallons of oil dispersant. Due to the months-long spill, along with adverse eff ects from the response and cleanup activities, extensive dam-age to marine and wildlife habitats and fi shing and tourism industries were reported. In Louisiana, 4.6 million pounds of oily material was removed from the beaches in 2013, over double the amount collected in 2012. Oil continued to be found as far from the Macondo site as the waters off the Florida Panhandle and Tampa Bay, where scientists say the oil and dispersant mixture is embedded in the sand. In 2013 it was reported that dolphins and other marine life contin-ued to die in record numbers with infant dolphins dying at six times the normal rate. A study released in 2014 reported that tuna and amberjack that were exposed to oil from the spill developed deformities of the heart and other organs that would be expected to be fatal or at least life shortening. Another study found that cardiotoxicity is widespread in animal life exposed to the spill. Investigations exposed the causes of the explosion. Th e U.S. government’s September 2011 report pointed to defective cement on the well, fault-ing mostly BP, but also the rig operator and contractor. Earlier in 2011, a White House Commission blamed BP and its partners for a series of cost-cutting decisions and an insuffi cient safety system, but also concluded that the spill resulted from “systemic” root causes and “absent sig-nifi cant reform in both industry practices and govern-ment policies, might well recur”.10 In 2012, BP and the U.S.

10 Obama oil spill commission’s fi nal report blames disaster on cost-cutting by BP and partners”. Th e Daily Telegraph (London). 5 January 2011. Retrieved 5 November 2011.


Department of Justice settled federal criminal charges with BP pleading guilty to 11 counts of manslaughter, two mis-demeanors, and a felony count of lying to Congress. BP also agreed to four years of government monitoring of its safety practices and ethics, and the Environmental Protection Agency announced that BP would be temporarily banned from new contracts with the U.S. government. BP and the Department of Justice agreed to a record-setting $4.525 bil-lion in fi nes and other payments but further legal proceed-ings not expected to conclude until 2014 are ongoing to determine payouts and fi nes under the Clean Water Act and the Natural Resources Damage Assessment.

• Th e Buncefi eld fi re was a major confl agration caused by a series of explosions on the 11th of December 2005 at the Hertfordshire Oil Storage Terminal, an oil stor-age facility in England. Th e terminal was the fi fth larg-est oil-products storage depot in the United Kingdom, with a capacity of about 60,000,000 gallons of fuel. Th e terminal is owned by TOTAL UK Limited (60%) and Texaco (40%). Th e fi rst explosion occurred near tank 912, which led to further explosions that eventually over-whelmed 20 large storage tanks. Th e cause of the explo-sion seems to have been a fuel-air explosion of unusually high strength. Th e British Geological Survey monitored the event, which measured 2.4 on the Richter scale. News reports described the incident as the biggest of its kind in peacetime Europe. Th e fl ames had been extinguished by the aft ernoon of 13 December 2005. However, one storage tank re-ignited that evening, which the fi re fi ght-ers let it burn rather than attempt to extinguish it again. Th e Health Protection Agency and the Major Incident Investigation Board provided advice to prevent incidents such as these in the future. Th e primary need is for safety measures to be in place to prevent the fuel from escap-ing out of the tanks in which it is stored. Added safety measures are needed for when fuel does escape, mainly to prevent it from forming a fl ammable vapor and stop-ping pollutants from poisoning the environment.

Th ese incidents don’t lend high support for the industry’s safety track record. Indeed there has been public outcry that the levels of fi nes and


penalties for such incidents have not been commensurate with the loss of life and damage caused to natural resources, businesses and properties resulting from poor industry practices.

1.2.3 Hurdles and Public SafetyData from 2003 shows that the U.S. imported about 2.3 percent (507 BCF) of its natural gas usage as LNG. Th at fi gure rose to nearly 3 percent (652 BCF) in 2004, according to the U.S. Dept. of Energy’s Energy Information Administration (EIA).11 In 2004, LNG imports constituted about 15% of total natural gas imports from all sources, the vast majority being gas piped from Canada. Five LNG facilities currently operate in the U.S., in Massachusetts, Maryland, Georgia, off the Louisiana shore, (the new Excelerate fl oating terminal in the Gulf of Mexico), and a smaller facil-ity in Puerto Rico used primarily to supply a power plant. Total import capacity is increasing to close to 1 T (Trillion) CF annually. LNG regasifi ca-tion facilities can be either off shore or onshore and can use one of several technologies to regasify the liquid gas. Th ere are proposals for 40 or more import facilities to serve the U.S. market, with 58 terminals proposed in North America overall. Currently, there are 20 LNG plant projects under consideration by the U.S.DOE.

Many of these proposed LNG plant projects are likely not going to mate-rialize in the near term, considering that each one of these world-scale LNG plants will require a multi-billion dollar investment to build. Given the almost mind boggling levels of needed capital for developing U.S. LNG export infrastructure and uncertainties in overseas market forces, why should shale gas plays continue at the current accelerated pace? Th e author has no answer for this, and can only allude to some concerns beyond those related to the need and justifi cation for such investments.

LNG is produced by cooling natural gas and purifying it to a desired methane content. Th e typical methane content is approximately 95% for the conventional LNG produced at a peak shaving plant. Th e term ‘peak shaving’ refers to the liquefaction of natural gas by utility companies dur-ing periods of low gas demand (summer) with subsequent regasifi cation during peak demand (winter). It is relatively easy to remove the non-methane constituents of natural gas during liquefaction. Th erefore, it has been possible for LNG suppliers to provide a highly purifi ed form of LNG

11 www.eia.doe.gov/neic/a-z/gasa-z.htm.


known as Refrigerated Liquid Methane (RLM), which is approximately 99% methane.

Th e primary advantage of LNG compared to CNG is that it can be stored at a relatively low pressure (20 to 150 psi) at about one-third the volume and one-third the weight of an equivalent CNG (compressed natural gas) storage tank system. Th e primary disadvantage is the need to deal with the storage and handling of a cryogenic (-260°F) fl uid through the entire process of bulk transport and transfer to fl eet storage. Th is raises concerns for worker and public safety.

While the end product of the use of CNG and LNG for vehicular appli-cations for Example is essentially the same, the general properties aff ecting safety are diff erent. On the one hand, LNG is a more refi ned and consistent product with none of the problems associated with the corrosive eff ects on tank storage associated with water vapor and other contaminants. But, the cryogenic temperature makes it challenging to impossible to add an odorant. Th erefore, with no natural odor of its own, there is no way for personnel or the public to detect leaks unless the leak is suffi ciently large to create a visible condensation cloud or localized frost formation. It is criti-cal that methane gas detectors be placed in any area where LNG is being transferred or stored.

Th e cryogenic temperature required for LNG systems creates a num-ber of safety considerations for bulk transfer and storage; among the most prominent – LNG is a fuel that requires intensive monitoring and control because of the constant heating of the fuel which takes place due to the extreme temperature diff erential between ambient and LNG fuel tempera-tures. Even with highly insulated tanks, there will always be a continuous buildup of internal pressure and a need to eventually use the fuel vapor or safely vent it to the atmosphere. When transferring LNG, extreme care has to be taken to cool down the transfer lines in order to avoid excessive amounts of vapor from being formed.

Constant vaporization of the fuel, unless it is a highly purifi ed form of LNG, i.e., RLM is a signifi cant concern. Th e methane in the fuel will boil off before other hydrocarbon components such as propane and butane will. Th is means that if LNG is stored over an extensive period of time with-out withdrawal and replenishment the methane content will continuously decrease and the actual physical characteristics of the fuel will change. Th is is referred to by industry jargon as “weathering” of the fuel. Recognize that methane is a powerful greenhouse gas.

A further consideration is that under low temperatures, many materials of construction undergo changes in their strength characteristics making them potentially unsafe for their intended use. Materials such as carbon


steel lose ductility at low temperature, and materials such as rubber and some plastics have a drastically reduced ductility and impact strength such that they will shatter when dropped. Materials of construction consider-ations for LNG plants do not represent new hurdles, but they require very careful engineering. Th ere are various codes that have been developed by the NFPA (National Fire Protection Association) and under the Uniform Fire Code. For example, the NFPA published NFPA 59A – Standard for Production, Storage, and Handling of Liquefi ed Natural Gas.

LNG may either be liquefi ed on-site or it can be delivered to fl eet stor-age using a standard 10,000 gallon LNG tanker truck. Generally the largest fl eet operators would fi nd on-site liquefaction to be more advantageous. Typical LNG storage vessels, including those used on the tanker truck, have the following components:

• Inner pressure vessel made from nickel steel or aluminum alloys exhibiting high strength characteristics under cryo-genic temperatures.

• Several inches of insulation are provided in a vacuum envi-ronment between the outer jacket and the inner pressure vessel. Stationary tanks tend to use fi nely ground perlite powder, while portable tanks oft en use aluminized mylar super-insulation.

• Th e outer vessel is generally made of carbon steel and not normally exposed to the cryogenic temperatures.

• Control equipment usually consists of loading and unload-ing equipment (piping, valves, gages, pump, etc.) and safety equipment (pressure relief valve, burst disk, gas detectors, safety shut off valves, etc.).

Double walled construction of the LNG tanker truck is inherently robust. Th e transport of LNG is safe from the perspective of fuel spills resulting from a tank rupture during an accident. A rupture of the outer vessel would cause the loss of insulation and result in an increased venting of LNG vapor. However, this tends to be a minor concern compared to the prospect of an LNG spill.

An explosion of an LNG container is considered by the industry to be a low probability event that is possible only if the pressure relief equipment or system fails completely or if there is some combination of an unusually high vaporization rate (due to loss of insulation) and some obstruction of the venting and pressure relief system preventing adequate vapor fl ow from the inner pressure vessel with a resultant pressure build up. If the pressure


builds up to the point where the vessel bursts, the resulting explosion is known as a BLEVE (boiling liquid expanding vapor explosion) with the container pieces propelled outward at a very high velocity. Industry experts argue that this is an unlikely event due to the extensive requirements for pressure relief including pressure relief valves and burst discs that are built into the design codes. Th e author could not identify any case studies or reports in the literature describing a BLEVE occurring with LNG.

In the event that the LNG vessel is ruptured in a transport accident and the LNG is spilled, there is high probability of a fi re because a fl ammable natural gas vapor/air mixture will be formed immediately in the vicinity of the LNG pool. Under this scenario, there is a high probability of igni-tion sources that can supply the needed energy for fi re/explosion – e.g., electrical sparking, hot surfaces, or possibly a fuel fi re created from the tanker truck engine fuel or other vehicles near the spill zone. Th e vapor cloud from an LNG pool will be denser than the ambient air; therefore, it will tend to fl ow along the ground surface, dispersed by any prevailing winds.

When spilled along the ground or any other warm surface, LNG tends to quickly boil and vaporize. A high volume spill will cause a pool of LNG to accumulate whereupon the boiling rate will decrease from an initial high value to a low value as the ground under the pool cools. It is generally recognized that the heat release rate from an LNG pool fi re will be roughly 2/3rds greater than that of a gasoline pool fi re of equivalent size.

Th ere are signifi cant concerns for fi re hazards during the transfer of LNG to fl eet storage. Th e transfer of LNG from a tanker truck to fl eet stor-age is a complex process, requiring active coordination/participation of both the tanker truck driver and a representative of the fl eet operator. Th e basic steps are as follows:

• Aft er the truck is chocked and the engine is shut off , a grounding cable is attached to the truck to ground any elec-trostatic discharge.

• A fl exible liquid transfer hose is attached to the tanker and purged with LNG to remove all air.

• A fl eet operator representative will open the storage vessel liquid fi ll line and the driver will open the trailer’s main liq-uid valve.

• Th e driver will control the pressure in the trailer tank via a pressure building line where LNG is vaporized and returned to the tank to maintain a pressure diff erential of at least 15 psi between the tanker and the storage vessel.


• Th e driver will use mechanical means to maintain a tight connection at the hose coupler to compensate for diff eren-tial expansion.

Th e safety features that are typical of truck storage transfer of LNG include equipment design such as trailer liquid valves that are interlocked with the truck brake system to prevent fuel transfer before the truck is properly secured; remote-controlled, redundant liquid valves; storage vessel alarms to prevent overfi ll; and long drain lines for safety-directing vented LNG vapor.

Th e complexity of the fuel transfer arrangement creates the potential for leaks and spills through human error and equipment failure. One of the particular concerns is that the fuel transfer equipment goes through a continuous cycle of

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