Thursday, September 16, 2010

Hydraulic Fracturing Comments Sent to EPA

To Whom It May Concern:

My primary concerns and comments on this matter are as follows:
1. It is my professional opinion that is it not necessary to regulate the fracturing process under the UIC program, but I believe it would be advisable to track the location and development of these oil and natural gas wells as a sister program or a component of the UIC program. This is especially true for states like New York and Pennsylvania that did adopt primacy for the UIC program and it is EPA obligation to implement the UIC program.
2. The development and operation of oil and gas production needs to be done in a manner that does not conflict with the UIC program. If not properly tracked, monitored, and governed- deep oil and gas wells with horizontal drilling has the potential to adversely influence or affect the operation of existing or future injection wells or cause movement of contaminated water, i.e., water with a TDS greater than 10,000 mg/L, into the USDW waters.
Therefore – without the involvement of EPA – Oil and Gas Development in NY and PA may be done in a manner that is not consistent with the UIC program. This involvement does not need to be a new regulatory process, but mostly like a cooperative agreement or interagency agreement or memorandum of understanding.
Even though chemicals are added to the “frac” water – the state program should be encouraged to require the use of “green” frac chemicals and practices that have a lower impact on the environment. With respect to fracturing, it is my professional opinion the primary concern would be the induced movement of deep biogenic or thermogenic gas or connate water from the deeper portions of the geological structure into the USDW water. Therefore, we need to have protection in place so the development process does not facilitate the movement of water that has been trapped in the formation for 400 million years into the USDW water.
From my perspective and assuming the use of diesel, BTEX compounds, aromatic hydrocarbons, and other toxic chemicals are prohibited in the fracing process - the primary concern is not the relatively low levels of organics in frac water, but the elevated levels of sodium, chloride, barium, strontium, gross alpha, lithium, iron, manganese, and sulfur compounds or gases that may come from the Marcellus Shale or other formations between the shale and USDW. This includes the migration of flammable gases and other noxious gases because of fracking pressure or poorly constructed/cemented wells.
3. The industry is creating a boring and stabilized hole that has the potential of becoming, after the gas is withdrawn, a regulated injection well – even if the goal of the injection is to enhance oil and gas recovery or to carbon sequester. From the start – the wells cement and casing requirements should be constructed to meet or exceed the standards required for Class I injection wells.
4 Without tracking the installation, pressurization, use and redevelopment of each well, tracking the movement and quality of the fluids, and tracking the abandonment of these wells – these wells have the potential for having both short-term and long-term consequences.
In the short-term, these well could cause or induce a push of contaminated water, i.e., water with a purity of less the 99%, or biogenic gas or interfere with UIC wells permitted by EPA.
In the long-term, these gas and oil wells have the potential for adversely affecting existing injecting wells, siting new injection wells, adversely affecting the utilization and siting of carbon sequestration systems, and the drilling and development process has the potential to adversely affect the Underground Sources of Drinking Water (USDW). The definition of USDW is defined as an "aquifer or its portion which supplies any public water system, or contains less that 10,000 milligrams per liter total dissolved solids and is not an exempt aquifer."
5.Because the deep oil and gas wells have the potential for interfering with existing or future UIC program wells, the drilling, construction, and development process for these oil and gas wells needs to be consistent with the goals of the UIC program and should not interfere with the UIC program. Therefore, in states like PA – the EPA should take a more proactive role in at least tracking and being informed about the oil and gas wells to ensure that the PA State Oil and Gas Regulations are consistent with the goals of the EPA Managed UIC program in PA. This involvement does not need to be a new regulatory process, but mostly like a cooperative agreement or interagency agreement or memorandum of understanding.

6. My specific suggestions (Interim Measures – Assuming no moratorium) :

a. EPA and individual states should review state Oil and Gas Regulations to ensure the regulations are consistent with the goals and objectives of the Federal UIC program and the regulations represent the Best Industry Practices to protect the health, safety, and welfare of the community and environment.
b. During the permitting process, the process should document if there are any injection wells or saline seeps within an area being developed or leased for natural gas or oil development, plus a distance of at least 2500 feet from the production zone. The 2500 feet distance was recommended because it has been reported that hydraulic fracturing can initially induce fracturing a distance of at least 1000 - 1500 feet from the pressurization point (therefore a 1000 foot buffer has been added) and the sand is used as a proppant can create a 300 to 500 feet (Producing Zone).
See Attached report- World Watch Institute- July 2010.
Therefore – the available data indicates that hydraulic fracturing should not induced saline water or gas migration, but gas is migrating
I do not believe gas is migrating because of fracing, but because of poor drilling and cementing practices. This conclusion does not mean that we need to ignore the problem – we need to fix the problem so this leakage does not interfere with the UIC program and does not induce contamination of the USDW.
c.Chemicals, Water Tracking, Waste Tracking – The chemical types and volumes injected into the well during the drilling and development need to be disclosed in the well completion report, a cradle to grave tracking system of waste and produced water volumes is required, and chemical analysis of the production water used include a complete listing of regulated chemicals, chemicals used in the development process, and chemicals that have established drinking water limits (plus chemicals that have been added to the EPA Candidate List) . This industry should not be exempt from the Toxic Release Reporting Process. This needs to be completed because sometime in the future, it may be necessary to identify the source of a contamination event or situation. In order to evaluate and identify the source of contamination – we need the data. If you do not collect the data – it will not be possible to scientifically or legally prove a cause-effect relationship.
d. Monitoring- For each production well site – a monitoring program is needed. This program is needed because it is not known what the true depth and thickness of the Underground Sources of Drinking Water (USDW) and there are basically no private well construction standards within Pennsylvania.
The predrilling monitoring should include the following components:
1. Monitoring a radial distance of at least 2500 feet from a production well, plus up to 1000 feet from a horizontal leg for the well. This monitoring needs to include existing private wells, springs, and streams, plus the monitoring should include the installation of multiple deep monitoring wells that isolate the deepest portion of the USDW in the region. Baseline monitoring needs to include a comprehensive listing of cations/anions, VOCs, SOCs, radiological, and other unregulated chemicals.
2. Monitoring should be conducted prior to drilling and then conducted 6 months and 1 year after completion and then immediately prior to and after any subsequent re-pressurization/ re-fracturing of the wellbore.
e. Public Outreach – the public should be informed and it should be encouraged that a copy of the permit be maintained at a local state office or office for a local township or municipality.

f. The EPA, other federal agencies, states, and the industry should fund a detailed investigation of the production and development process. The goal of this investigation should include baseline environmental testing prior to drilling, monitoring during the drilling and development process, and post production monitoring at representative terrestrial sites in the Unites States. This study should not result in the implementation of a drilling and gas development moratorium.

e. Memorandum of understanding with Teeth – Recommend Building from this original MOU and putting together a document with a downside.

The EPA, PA and other states, and Natural Gas Companies and Development Companies should not be voluntary and should prohibit the use of toxic chemicals and require the use of Best Industry Practices and at a Minimum Recommended Industry Standards fro Natural Gas and oil development. If a company is found not to follow these practices – they should be prohibited from conducting business in a given state or commonwealth.
7. Specific Recommendations on EPA Study

a.EPA whould work in partnership with State Agency, Industry, and local Universities to select sites throughout the US and NEPA to complete a detailed investigation of natural gas development. The study should be a cradle to grave investigation that evaluates the various types of drilling, development techniques, and fracturing processes.
Sites selection should be based on a combination of geological site conditions and location to urban corridors and high profile/ environmental areas. The investigation should not just be a comparison of vertical and horizontal drilling – but vertical, horizontal drilling using individual vertical wells with one horizontal leg, and a single vertical well with multiple horizontal leg (“tree design”).
b.The study should include the comprehensive evaluation of a site prior to gas development- air soil and water and a general biological diversity study. This would include the detailed mapping and understanding the quality and movement of shallow and deep USDW waters and the water quality and hydraulic pressures of the formation water to a depth that extends beyond the Marcellus Shale, habitat studies, and air monitoring. The habitat studies should use control areas that include areas that have been cleared for other activities.
c. The study should include the comprehensive evaluation of the site during the construction and development process. The baseline monitoring will need to extent at least 2500 feet from the vertical boring and than up to 1000 feet from a horizontal leg. The monitoring should be adequate enough to actually document the extent of fracture development during pressurization and the actual width of the production zone.
Personal Note- I do not conduct any consulting for gas companies. I do assist in conducting baseline testing for citizens.
Respectfully submitted

Mr. Brian Oram, PG
B.F. Environmental Consultants Inc
15 Hillcrest Drive
Dallas, PA 18612
570-335-1947 – cell phone

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