HF Chemicals Reporting: Summary of FracFocus Analysis · HF Chemicals Reporting: Summary of...

HF Chemicals Reporting: Summary of FracFocus Analysis

Groundwater Protection CouncilSeptember 29, 2015 Oklahoma City

Kate Konschnik and Archana Dayalu

FracFocus Data

28 states require some HF disclosure

23 states and the federal BLM require or recommend disclosure directly to FracFocus

FracFocus provides well-by-well pdfreporting.

As of May 2015, FracFocus also provides aggregated well data for download.

FracFocus Data

FracFocus Data:RegistryUpload (Header) Data

Equivalent SQL Header Data

JobStartDate

JobEndDate

StateName

CountyName

APINumber

OperatorName

WellName

Longitude

Latitude

Projection

FederalWell

TVD

TotalBaseWaterVolume

TotalBaseNonWaterVolume

Additional Header Data

OriginalSubmitTimeStamp StateNumber

SubmitTimeStamp CountyNumber

Amended WellType

FFVersion pKey

PDF Form Header Data

* Header Fields Added During Our Analysis *

pKeyRegistryUpload search_id_form

submit_time_fracday LatitudeClean

StateNameFromCoords LongitudeClean

StateAbbFromCoords ProjectionClean

CountyNameFromCoords StateOK

CountyCodeFromCoords

StateNameFromAPI

FracFocus Data: Purpose and Ingredients Data

Equivalent SQL Purpose Data

TradeName

Supplier

Purpose

Equivalent SQL Ingredients Data

IngredientName

CASNumber

PercentHighAdditive

PercentHFJob

IngredientComment

Additional SQL Ingredients Data

IngredientMSDS MassIngredient

ThirdPartyCalc pKey* Purpose Fields Added During Our Analysis *

SupplierClean

Systems_Approach

pKeyPurpose

Additional SQL Purpose Data

pKey

* Ingredients Fields Added During Our Analysis *

CASNumberClean

IngredientNameClean

CASLabel

WithheldFlag

pKeyIngredients

FracFocus Data

Our original dataset: 97,964 forms.

After removing duplicates, earlier disclosures:

- 96,449 forms, submitted

- March 9, 2011 – April 13, 2015 in

- 23 states, including

- 21 with HF disclosure laws during the study period.

EPA FF 1.0 Study – forms submitted between January 11, 2011 – February 28, 2013, in 20 states.

FracFocus Data

After removing 149 additional forms for state location discrepancy, our data set contained:

96,300 forms, describing frac jobs at

92,844 wells, including

53,073 FF 2.0 forms, which described

1,979,128 rows of chemical information

EPA Study – 38,000 FF 1.0 forms

Snapshot of Data

Snapshot of Data:Approximate distribution of forms,

through Feb 2015*

Disclosures per county

01 - 1011 - 100101 - 500501 - 10001001 - 5857

*Note 1: Alaska counties are not displayed in this map. *Note 2: Distribution assumes user input county codes are accurate, which is not necessarily true.

Snapshot of Data – Top Inputs after Water, Sand

Inquiry 1: Location Data Entry Error

FF 1.0 Data – 22% error in State Names

FF 2.0 Data – 0% error in State Names

- Why? Field automatically populated in 2.0.

State discrepancies in well coordinates and API state code, for 0.2% of forms (149).

- All but 5 were FF 1.0 forms.

- Why? API input broken out into 3 parts in 2.0.


API: 05029061090000 (Colorado)Coordinates:Pacific Ocean

API: 42283334270000 (Texas)Coordinates:Mexico (close to USA border)

API: 47097037680000 (West Virginia)Coordinates:Pennsylvania

API: 04213326330000 (California)Coordinates:Texas

Location Error Examples – State API does not match user-input coordinates(Images © Google Maps 2015)


County discrepancies in well coordinates and API state code: 3.9%

- FF 1.0 data: 5.0%

- FF 2.0 data: 2.9%

Why? API input broken out into 3 parts in 2.0.

Inquiry 2: CAS # Data Entry Error

Almost 80% of CAS #s were valid, identifying 983 unique chemical substances.

- About 0.75% (14,881 entries) had data errors.

EPA FF 1.0 study: 65% of CAS #s were valid, identifying 692 chemical substances.

- Why? FF 2.0 warned if check digit did not pass verification.

- Some data scraping errors

Inquiries 1 and 2: Data Entry Errors Recommendations /Lessons

Automatic field entries, prompts, can flags can reduce data error

FF 2.0 began using these tools:- Separate boxes for each numeric series in an API or CAS #- Notification of a discrepancy between location data points- Warning if CAS # check digit does not pass verification

FF 3.0 will expand on these tools:- Error message if CAS# check digit does not pass verification- Drop-down menus of substances

Inquiry 3: Timeliness

Effect of reporting deadlines

- Before, operators took a weighted average of 83 days to file a form with FracFocus.

- After, operators took a weighted average of 33 days to file a form.

Generally low compliance rates until states announce intent to enforce (ex. Colorado “late rate” dropped from 36.1% to 5.2%).


State Laws: Companies must report within …

Day 1 16 31 46 61 76 91 106 121

Drilling HF WC

LA

AL, AK, MS, WY

AR, MT, SD, TX

NM

CA, IL, NE, NV, OK, PA, UT

60 days of WC

90 days of WC

120 days of spud - KS

20 days of WC

30 days of HF

30 days of WC

45 days of WC

60 days of HF

CO, ND, OH

WV


Hard to track deadlines, applicability

Date clock starts may not be reported to FF (spud date, completion end date).

FF 1.0, 2.0 forms did not report submission date.

States with pre-fracturing disclosure rules see lower compliance rates (38.3%) with post-fracturing disclosure deadlines than states without pre-fracturing rules (50.7%).

Inquiry 3: Timeliness Recommendations/Lessons

Indications a state takes a requirement or deadline seriously seems to have a strong effect on the regulated community

Education on deadlines, reasons could help.

Relevant dates for deadlines should be public. FF 3.0 will publish submission date.

Inquiry 4: Data Withholding

Median percentage of ingredients withheld per formError bars represent 25th and 75th percentiles.


Median percentage of ingredients withheld for proprietary reasons per formError bars represent 25th and 75th percentiles.


Proprietary

Confidential

Trade Secret

N/A

41%

28%

18%

12%

Justification of Non-Disclosure


Justification of Non-Disclosure


EPA: 11% withholding rate in forms filed before February 28, 2013.

GWPC: 16.7% withholding rate in forms filed June – December 31, 2013.

Harvard: 16.6% withholding rate in forms filed January 1, 2014 - April 13, 2015.

(NOTE: These rates exclude N/A designations.)

Inquiry 4: Data Withholding Recommendations /Lessons

Different state procedures do not drive differences in disclosure rates.

States that permit withholding for non-trade secret proprietary reasons do not see higher rates of withholding.

Re-allocation of justification occurs based on state law.

Education on standards needed.

Inquiry 5: Systems Approach

Company # of Regular Records

WH Rate

# of SA Records

WH Rate (Difference)

2-sided p-value

95% CI

Schlumberger 47,991 10.7% 127,799 2.9% (7.8%) <0.001 8.1% -7.6%

Baker Hughes 169,229 17.8% 12,432 3.9% (13.9%) <0.0001 14.3% -13.5%

Halliburton 232,618 12.1% 315 17.8% (5.6%) <0.0001 9.8% -1.4%

Multi-Chem 20,727 21% 845 43% (22%) <0.0001 25.2% -18.9%

Inquiry 5: Systems Approach

141,391 unique systems approach (SA) records, representing 7.1% of the data set.

Systems approach reporting reduced withholding rates by four-fold (14.4% to 3.3%)

Overall, lower rates of withholding by these firms than across all forms.

Inquiry 5: Systems ApproachRecommendations/Lessons

Systems Approach reduces withholding rates

More research needed to determine if smaller firms would use systems approach or withhold fewer records as a result

States should retain authority to ask for product-by-product chemical information, in case of release, or for other reasons.

Questions?

Kate Konschnik, Director

Harvard Environmental Policy Initiative

[email protected]

Archana Dayalu

Harvard SEAS

[email protected]

mailto:[email protected]

mailto:[email protected]

HF Chemicals Reporting: Summary of FracFocus Analysis · HF Chemicals Reporting: Summary of...

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