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Hydraulic Fracturing and the Environment The Science and Facts of Responsible Development

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Hydraulic Fracturing and the Environment  The Science and Facts of Responsible Development Powered By Docstoc
					 Hydraulic Fracturing and
   the Environment: The
     Science and Facts of
Responsible Development


                   John F. Peiserich
             Perkins & Trotter, PLLC
     jpeiserich@perkinstrotter.com
What is the timeline?
How are you protected?

•   The Clean Water Act regulates surface water discharges and storm-water runoff.

•   The Clean Air Act sets rules for air emissions from engines, gas processing equipment
    and other sources associated with drilling and production activities.

•   The Safe Drinking Water Act regulates the disposal of fluid waste deep underground.

•   The National Environmental Policy Act requires permits and environmental impact
    assessments for drilling on federal lands.

•   The Occupational Safety and Health Act sets standards to help keep workers safe.
    These include requiring Material Safety Data Sheets be maintained and readily available
    onsite for chemicals used at that location.

•   The Emergency Planning & Community Right-to-Know Act requires storage of
    regulated chemicals in certain quantities to be reported annually to local and state
    emergency responders.

•   The National Pipeline Safety Act sets standards for pipeline construction, operation and
    maintenance administered by U.S. Department of Transportation.
Additional State* Protections
 Arkansas Department of Environmental Quality
 Arkansas Oil & Gas Commission
 Arkansas Natural Resources Commission –
  permitting of water use



* The U.S. Army Corps of Engineers administers
  404 permitting which is predominately related to
  potential impacts to surface water but requires
  an ADEQ water quality certification.
Protecting Everyone’s Water

                        Physical:
                          •   Well Casing Program
                          •   Cement Bond Log
                          •   Mechanical Integrity
                              Testing
                          •   Annulus Pressure
                              Monitoring


                        Regulations:
                          •   Federal Rules and
                              Regulations
                          •   Routinely Updated State
                              Rules and Regulations
Typical Fluid Constituents
Constituent Name Generic Name                Common Use                                                              Hazardous as Appears
                                                                                                                           on MSDS
1,2,4                  Aromatic              Paint, Mold Making Kit (Arts and Crafts), Unleaded Gasoline                     Yes
Trimethylbenzene       Hydrocarbon
Alcohol, C12-16,       Alcohols,             Car Wash Liquid, Laundry Stain Remover, Air Freshener                           No
Ethoxylated            Ethoxylated
Aldehyde               Aldehyde              Metal Cutting Fluid, Non-Alcoholic Beverages, Ice Cream, Candy, Baked           Yes
                                             Goods, Chewing Gum, Condiments and Meats
Ammonium               Inorganic Salt        Hand Wash, Shampoo, Breakfast Cereal                                            Yes
Chloride
Ammonium               Inorganic salt        Milk Products                                                                   No
Phosphate
Crystalline Silica,    Silica                Cat Litter, Tile Mortar, Arts & Crafts Ceramic Glaze                            Yes
Quartz
Ethanol                Alcohol               Ginseng, Deodorizer, Dish Soap, Cologne, Makeup (Mascara), Mouthwash            Yes
Ethoxylated Fatty      Ethoxylated Fatty     Household Multipurpose Cleaner, Laboratory Hand Cleaner                         No
Acid                   Acid
Fatty Acid Tall Oil    Tall Oil Fatty Acid   Car Polish, Industrial Hand Cleaner                                             No
Blend
Heavy Aromatic         Hydrocarbon-         Industrial Cleaning Solution, Tire Repair, Agricultural Insecticide              Yes
Petroleum Naphtha      Petroleum Distillate
Hydrochloric           Inorganic Acid Table Olives, Unripened Cheese, Cottage Cheese                                        Yes
Acid
Hydrotreated Light     Hydrocarbon –        Oil Wood Stain, Air Freshener, Surface Cleaner Aerosol                           Yes
Petroleum Distillate   Petroleum Distillate
Isopropanol            Alcohol              Tape Head Cleaner, Hops Extract used for Beer, Air Freshener                     Yes
Methanol               Alcohol              Furniture Refinisher, Liquid Hand Soap, Windshield Washer Concentrate,           Yes
                                            Hops Extract
Methyl Isobutyl        Ketone               Paint Thinner, Wood Stain, Metal Adhesive, Automotive High Heat Paint            No
Ketone
Naphthalene            Polycyclic Aromatic Mothballs, Agricultural Insecticide, Heating Fuel Oil                             Yes
                       Hydrocarbon
Polyethoxylated        Ethoxylated Amine Toilet Bowl Cleaner                                                                 No
Fatty Amine Salt
Quaternary             Quaternary            Industrial and Commercial Water Acidity Neutralizing Solution                   Yes
Ammonium Salt          Ammonium Salt
Sodium Chloride        Inorganic Salt        Macaroni and Noodle Products, Canned Corn, Tomato Concentrate, Frozen           No
MSDS Hazardous?
As defined by OSHA Standard 1910.1200 (the OSHA Haz-com standard),
a hazardous  chemical  is one which is a physical hazard or a health hazard.

Health hazard  means a chemical for which there is statistically significant
evidence based on at least one study conducted in accordance with established
scientific principles that acute or chronic health effects may occur in exposed
employees. The term "health hazard" includes chemicals which
are carcinogens, toxic or highly toxic agents, reproductive
toxins, irritants, corrosives, sensitizers,
hepatotoxins, nephrotoxins, neurotoxins, agents which act on the
hematopoietic system, and agents which damage the lungs, skin, eyes, or
mucous membranes.
Physical hazard  means a chemical for which there is scientifically valid evidence
that it is a combustible liquid, a compressed gas, explosive, flammable,
an organic peroxide, an oxidizer, pyrophoric, unstable (reactive) or water-
reactive.
Some of My Favorite Hazardous
Materials - at Least those with
Guar Gum
A Few of My Favorite Carcinogens
– Things We Like to Eat
EPA Administrator Jackson’s
Congressional Testimony on May
25, 2011
 Jackson said natural gas creates less air pollution than other
  fossil fuels “so increasing America’s natural gas production is a
  good thing.”
 She said Congress told the EPA to study the relationship between
  fracking and drinking water. “We are doing that, with input from
  technical experts, the public and industry,” she said.
 “In the meantime, EPA will step in to protect local residents if
  a driller jeopardizes clean water and the state government
  does not act.”
 Under questioning from a Pennsylvania Republican, Jackson said
  she was “not aware of any proven case where the fracking
  process itself” had affected water .

 UPDATE – April 2012 – Jackson says “in no case have we made a
  definitive determination that the fracing process has caused
  chemicals to enter groundwater.” This is after Pavillion, WY.
A “Greening” O&G Industry
Economic Benefits from Natural
Gas Production including
Arkansas
   It is responsible for creating 2.8 million American jobs.
   It is forecast to add 1 million U.S. manufacturing jobs over the next 15 years.
   It has led to an annual increase in U.S. household disposable income of $926.
   Shale gas alone is forecast to contribute $933 billion revenues to federal,
    state and local government coffers over the next 25 years, including helping
    pay for schools, law enforcement and other essential municipal priorities.
   It is the transportation fuel of choice of American cities large and small—as
    they seek to save money and promote clean air through their bus fleets.
   It has helped reduce U.S. power sector carbon emissions to levels not seen in
    20 years as communities embrace this energy as a cleaner electricity choice.
   It allowed the top 100 U.S. power producers to reduce by one-third
    emissions of sulfur dioxide and smog-forming nitrogen oxide—in just a two-
    year period.
   And, as a transportation fuel it is allowing city bus fleets, large company
    fleets (AT&T, UPS, Verizon, Waste Management, et al) to rely on an American
    fuel that costs on average 40% less than diesel or gasoline.
   North Little Rock and Mayor Hays have brought PUBLIC CNG to Central
    Arkansas at $1.44 per gasoline gallon equivalent !
What Should the Industry
Consider?
 It appears historic operations are the most likely
  cause of potential groundwater and drinking
  water issues. The O&G Industry risk of potential
  water issues is no different from any other
  industry that manages fluids.
 The development of new technologies, improved
  drilling and completion techniques, and “green”
  completion fluids all add layers of protection for
  water issues.
 Public outreach is a necessary component of any
  industrial activity and one that needs substantial
  additional effort in the O&G Industry.

				
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posted:1/20/2014
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