The Urgent Case for a Ban on Fracking

8/11/2019 The Urgent Case for a Ban on Fracking

1/35


2/35

Food & Water Watch works to ensure the food and water we consume is safe, accessible and sustainablyproduced. So we can all enjoy and trust in what we eat and drink, we help people take charge of where their food

shared resources under public control.

foodandwaterwatch.org.

Los Angeles, California

Suite 255

Los Angeles, CA 90034

(323) 843-8450

Oakland, California

1814 Franklin Street

Suite 1100

Oakland, CA 94612

(510) 922-0720

Colorado

1740 High Street

(720) 449-7505

Florida

1044 NE 15th

Fort Lauderdale, FL 33304

(954) 372-1881

Illinois

Suite 401

Chicago, IL 60642

(773) 796-6088

Iowa

Suite 818

Des Moines, IA 50309

(515) 344-4834

Maine

533 Congress Street

Portland, ME 04101

(207) 619-5845

Maryland

3121 St. Paul Street

Baltimore, MD 21218

(410) 394-7650

Michigan

Suite 136

Detroit, MI 48201-2654

(313) 486-1356

New Jersey

100 Bayard Street

Suite 202

New Brunswick, NJ 08901

(732) 839-0860

New Mexico

7804 Pan American

East Freeway NE #2

(505) 633-7366

New York

68 Jay Street

Suite 713

Brooklyn, NY 11201

(718) 943-9085

North Carolina

801 Gilbert Street

Suite 204

Durham, NC 27701

(919) 794-6380

Ohio

103 William H. Taft Road

Cincinnati, OH 45219

(513) 394-6257

Oregon

917 SW Oak Street

Suite 404

Portland, OR 97205

(971) 266-4528

Pennsylvania

232 S. 4thStreet

Suite 1F

Philadelphia, PA 19106

(267) 428-1903

1616 P Street, NW

Suite 300

Washington, DC 20036

(202) 683-2500

About Food & Water Watch

Copyright September 2014 by Food & Water Watch.All rights reserved.

This report can be viewed or downloaded at foodandwaterwatch.org.


3/35

The Urgent Case for a Ban on Fracking

I

n many ways, racking is he environmenal issue o our ime. Is an issue

ha ouches on every aspec o our lives he waer we drink, he air we

breahe, he healh o our communiies and i is also impacing he global

climae on which we all depend. I pis he larges corporae ineress big oiland gas companies and he poliical leaders who suppor hem agains people

and he environmen in a long-erm sruggle or survival. I is an issue ha has

capivaed he hears and minds o hundreds o housands o people across

he Unied Saes and across he globe. And i is an area in which, despie he

massive resources o he Frackopoly he cabal o oil and gas ineress promoing his pracice we as

a movemen are making remendous srides as our collecive power coninues o grow.

Food & Waer Wach is proud o work shoulder o shoulder wih communiies across he counry and

across he world in his effor. Wih mouning evidence abou he harms o racking and he immediacy

o he impending climae crisis, his repor lays ou he urgen case or a ban on racking.

In 2009, we became alarmed abou he hrea ha hydraulic racuring (racking) posed o our waer

resources. Communiies around he counry were already raising he alarm abou he ill effecs ha

racking was having, rom increased ruck raffic o spills and even ap waer ha could be li on ire

hanks o mehane leaks rom racking wells ino waer sources.

Meanwhile, many naional environmenal groups were ouing naural gas as a bridge uel a beter

means o producing energy rom ossil uels han coal, a source ha everyone knew we had o move

away rom urgenly o reduce he carbon emissions ha were heaing he plane a a dangerous rae.

Communiies ha were already eeling he effecs o he echnology, or ha were ighing he coming

wave o racking, el berayed ha he place hey lived could become one o he sacriicial zones wih

many environmenaliss blessing. Over he nex ew years, scieniic evidence would moun ha no

only is racking no climae riendly, bu i has he poenial o unleash massive amouns o mehaneha will conribue o climae disaser.

So we began our work on racking wih Not So Fast, Natural Gas, our repor ha raised serious ques-

ions abou racking saey and he naural gas rush being promoed by indusry and governmen. Tha

repor, released in 2010, called or a series o regulaory reorms, bu he evidence coninued o moun.

The nex year, afer looking a even greaer evidence o he inheren problems wih racking, and real-

izing how inadequaely he saes were regulaing he oil and gas indusry and enorcing hose regula-

ions, Food & Waer Wach became he irs naional organizaion o call or a complee ban on racking,

and we released he repor The Case for a Ban on Gas Fracking.

Since he release o ha repor in 2011, more han 150 addiional sudies have been conduced on a range

o issues rom waer polluion o climae change, air polluion o earhquakes reinorcing he caseha racking is simply oo unsae o pursue. In he ace o such sudies, and ollowing he lead o grass-

roos organizaions ha have been a he oreron o his movemen, a consensus is emerging among

hose working agains racking ha a ban is he only soluion. No only are ederal and sae officials no

regulaing he pracice o racking, i is so dangerous and he poenial so grea ha i canno be regu-

laed, even i here were he poliical will. This is why Americans Agains Fracking, a naional coaliion

ha Food & Waer Wach iniiaed in 2012, has coninued o atrac suppor. The coaliion now has over

275 organizaions a he naional, sae and local levels unied in calling or a ban on racking and relaed

aciviies.

Letter from Wenonah HauterExecutive Director, Food & Water Watch


4/35

ii Food & Water Watch foodandwaterwatch.org

As his repor lays ou, here is mouning evidence ha racking is inherenly unsae. Evidence builds

ha racking conaminaes waer, pollues air, hreaens public healh, causes earhquakes, harms local

economies and decreases propery values.

And mos criically or he survival o he plane, racking exacerbaes and acceleraes climae change.

We are acing a climae crisis ha is already having devasaing impacs and ha is projeced o escalae

o caasrophic levels i we do no ac now. Presiden Barack Obama came ino office ouing racked gas

as a bridge uel, ye mouning evidence suggess ha raher han serving as a bridge o a renewable

energy uure, is a bridge o a climae crisis.While he environmenal, public healh and ood movemens have looked a mouning evidence and

rejeced racked gas and oil, Presiden Obama and his adminisraion have aggressively promoed

naural gas and domesic oil as a criical par o he Unied Saes energy uure. Presiden Obama

repeaedly ous domesic gas producion and has said ha we should srenghen our posiion as he

op naural gas producer [I] no only can provide sae, cheap power, bu i can also help reduce our

carbon emissions. His Energy Secreary Ernes Moniz has close indusry ies and has claimed ha he

has no seen any evidence o racking per se conaminaing groundwaer and ha he issues in erms

o he environmenal ooprin o hydraulic racuring are manageable.

Obamas Inerior Secreary Sally Jewell has bragged abou racking wells in her prior career in he

indusry and has, despie radical changes in how racking is done, called i a echnique [ha] hasbeen around or decades, and even implied ha direcional drilling and racking can resul in a sofer

ooprin on he land. And he person charged wih proecing communiies waer, Environmenal

Proecion Agency Adminisraor Gina McCarhy, has claimed Theres nohing inherenly dangerous

in racking ha sound engineering pracices can accomplish, all while he EPA has ignored or buried

indings ha racking has conaminaed waer in Texas, Wyoming and Pennsylvania. Mos recenly,

he adminisraion and several legislaors have been pushing expors o liqueied naural gas abroad o

counries where i will ech he highes price, soking already massive oil and gas indusry prois a he

expense o our rural communiies, our waer and our climae.

This suppor or racking a he highes levels has caused unnecessary conusion and creaed poliical

space or oherwise-concerned environmenally leaning governors o pursue racking. In Caliornia,

Governor Jerry Brown has been supporing racking despie his saed desire o igh climae change. In

Maryland, Governor Marin OMalley has pursued a more cauious approach, bu sill has spoken avor-

ably abou uure producion and recenly reerred o naural gas as a bridge uel. In New York, Governor

Andrew Cuomo has no lifed a popular de factosaewide moraorium on racking due o signiican

public pressure, bu has also no moved o adop a permanen ban. Ciing Presiden Obamas suppor or

racking, he indusry has criicized Cuomo.

Despie wha Presiden Obama and his adminisraion claim, here have now been over 150 sudies on

racking and is impacs ha raise concerns abou he risks and dangers o racking and highligh how

litle we know abou is long-erm effecs on healh and our limied reshwaer supplies. Is ime or

Presiden Obama and oher decision makers o look a he acs and hink abou heir legacy. How do

hey wan o be remembered? Wha do hey wan he world o look like 20, 50 and 100 years rom now?

We irs made he case or a ban on racking in 2011, bu his new repor shows ha here is an urgen

case or a ban. The evidence is in, and i is clear and overwhelming. Fracking is inherenly unsae, canno

be regulaed and should be banned. Insead, we should ransiion aggressively o a renewable and

efficien energy sysem.


5/35

The Urgent Case for a Ban on Fracking 1

Executive Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2

Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3

Water and Land Impacts . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5

Water consumption . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5

Impacts on surface waters, forests and soils . . . . . . . . . . . . . . . . . . . . . . . . . . 6

Aquifer contamination . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8

Mehane and oher hydrocarbon gases . . . . . . . . . . . . . . . . . . . . . . . . . . 8

Hydrocarbon gases in aquiers as a sign o more problems o come . . . . . . . . . . 10

Earthquakes, Lightning Strikes and Exploding Trains . . . . . . . . . . . . . . . . . . 13

Air and Climate Impacts. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15

Silica dust. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .15

Byproducts from combustion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .15

The pollutants that oil and gas companies bring to the surface . . . . . . . . . . . . . . . . 16

Emissions are larger han officials esimae . . . . . . . . . . . . . . . . . . . . . . . . 17

Naural gas dependence causes more global warming han hough. . . . . . . . . . .18

Public Health, Economic and Social Impacts . . . . . . . . . . . . . . . . . . . . . . . 20

Ban Fracking and Usher in a Safe and Sustainable Energy Future . . . . . . . . . . . 22

TABLE OF CONTENTS


6/35

2 Food & Water Watch foodandwaterwatch.org

Executive SummaryRegarding he uure o he U.S. energy sysem, he erm

racking has come o mean more han jus he speciic

process o injecing large volumes o various mixes o

waer, sand and chemicals deep underground, a exreme

pressure, o creae racures in argeed rock ormaions

all so ighly held oil and gas migh low.

We now use he erm racking o represen all ha hisspeciic process o hydraulic racuring enails. Allowing

more racking means ha oil and gas companies will

coninue o:

Fragment forests and mar landscapeswih new

roads, well sies, wase pis and pipelines;

Compete with farmers for local water supplies

while consuming millions o gallons o waer or each

racked well;

Produce massive volumes of toxic and even

radioactive waste, he disposal o which is causingearhquakes and puting a risk drinking waer

resources;

Cause thousands of accidents, leaks and spills

each year ha hreaen public healh and saey and

pu a risk rivers, sreams, shallow aquiers and arms;

Pump hazardous pollutants into the air, a he

expense o local communiies, amilies and arms;

Turn homes into explosive hazardsby conami-

naing waer wells wih mehane and oher lammable

gases; Put vital aquifers at risk for generationsby

creaing new pahways or he poenial low o

conaminans over he coming years and decades;

Destabilize the climate on which we all depend

wih emissions o carbon dioxide and mehane and by

locking in uure climae polluion wih new oil and

gas inrasrucure projecs; and

Disrupt local communities, wih broad physical

and menal healh consequences, increased demand

on emergency and oher social services, damage o

public roads, declines in propery value, increased

crime, and losses el in esablished secors o local

economies.

In 2011, Food & Waer Wach called or a ban on racking

because o he signiican risks and harms ha accom-

pany he pracice. Now, over hree years laer, numerous

peer-reviewed sudies published in scieniic, legal and

policy journals have expanded wha is known and clari-

ied wha remains unknown abou he environmenal,

public healh and socioeconomic impacs ha sem rom

racking. In his repor, Food & Waer Wach reviews he

science and renews is call or a ban.

We ind ha he open quesions amoun o unaccepable

risk, and ha he harms are cerain. Sringen regulaions,

even i pu in place and even i adequaely enorced, would

no make racking sae. Municipal bans, moraoria and

zoning laws are being passed o ry o proec communi-

ies across he counry, bu ederal and sae level acion is

necessary o reverse he spread o racking.

The only pah o a susainable economic uure is o

rebuild he U.S. energy sysem and local economies

around sae energy soluions: efficiency, conservaionand renewable resources. Fracking akes us in he wrong

direcion.

PHOTO BY HENDRIK VOS


7/35


IntroductionHydraulic racuring allows oil and gas companies o arge

underground layers o rock ha hold oil and gas, bu ha

do no readily allow he oil and gas o low up a well.

Drilling hrough hese rock ormaions, hen injecing a

blend o waer, sand and chemicals a exreme pressure,

creaes racures propped open by he sand, exposing

oherwise ighly held oil and gas and allowing i o low.

In response o declines in convenional producion, and o

he lack o access o many inernaional sources o oil and

gas,1companies are now racking in he Unied Saes on

an unprecedened scale. (See Box 1.) Acids are also being

injeced, paricularly in Caliornia and perhaps increasingly

in Florida, o ea away new pahways or oil and gas o

low, wih or wihou creaing new racures.2

The oil and gas indusry enjoys avored saus under

he law and an enrenched posiion in U.S. poliics,

economics and insiuions. This creaes an ineria ha

imperils curren and uure generaions, and endangers our

economy, as we ace he consequences o global warming

and he legacy o he indusrys polluion.

The curren saus quo a he ederal level, and in many

saes, is o encourage as much drilling and racking or

oil and gas as possible. Increased poliical and legislaive

gridlock in Washingon, D.C. has helped o mainain his

saus quo.14Those wih large sakes in oil and gas produc-

ion a angle o oil and gas companies, engineering and

consrucion irms, environmenal consulancies, rade

associaions, public relaions and markeing irms, inancialinsiuions and large individual invesors sand o proi

rom his saus quo.

Revolving doors and srucural ies beween he indusry

and sae and ederal agencies,15academic research groups

ha ac as saellie indusry labs and hink anks,16and

indusry conrol o access o daa and sies,17as well as

echnical experise,18all illusrae he exen o he oil and

gas indusrys capure o U.S. energy policy. The oil and

gas indusrys inluence is releced in he exempions ha

i enjoys in key provisions o all o he landmark environ-menal laws, including he Clean Air Ac, he Sae Drinking

Waer Ac, he Clean Waer Ac and laws regulaing

hazardous wases.19

Over a rillion dollars in sunk coss in inrasrucure

avors he saus quo o dependence on he oil and gas

indusry, serving as a barrier o he remaking o he U.S.

energy sysem.20The oil and gas indusry receives abou $4

billion each year in direc axpayer-unded subsidies.21The

Box 1 The scale of frackingTo hydraulically fracture a modern onshore oil or gas well,

batches of hundreds of thousands of gallons of water,

tons of sand and thousands of gallons of chemicals get

injected repeatedly, typically in tens of stages along a

mile-plus long, several-inches-wide tunnel, or borehole,

that runs laterally through a targeted rock formation

thousands of feet below ground. Oil and gas companiesare now doing this more than 10,000 times each year

in the United States to extract so-called shale gas, tight

gas and tight oil.3

that the companies inject, to eat away pathways for oil

fracking is largely unknown, but the practice is clearly on

the rise and a focus of the oil and gas industry.4

In 2012, the U.S. Energy Information Administration

estimated that bringing the projected amounts of techni-

cally recoverable as if recovering something lost

shale gas and tight oil into production would requiredrilling and fracking over 630,000 new onshore wells.5If

this happens, many thousands of the wells envisioned

are likely to have cementing and casing issues from the

outset, and all of them will age and degrade over subse-

quent years and decades, putting at risk underground

sources of drinking water.6Given that initial fractures

release just a small fraction of the oil or gas held in

targeted source rocks, industry will also seek to re-frac-

ture many thousands of these wells to try to reverse the

typically rapid declines in production as they age.7

A 2013 analysis from the Wall Street Journalfound that

over 15 million Americans are living within one mile

of a well drilled after the year 2000, when large-scale

hydraulic fracturing operations began.8Many more live

alongside other polluting infrastructure that supports

oil and gas production, including processing plants,

-

nities have passed actions in opposition to drilling,

fracking and supporting infrastructure.9

Oil and gas companies have piled up over $100 billion in

debt, in large part to support drilling and fracking and

related infrastructure.10Data from the major publicly

listed oil and gas companies show that from 2008 to2012, collective capital spending increased by about 32

percent, while, at the same time, oil production fell by

about 9 percent.11Evidently the industry is banking that

increased drilling and fracking into the future, coupled

with increased oil and natural gas exports, will translate

rise.12Industrys bubble will burst, not least because

societys systematic dependence on fossil fuels is posing

an existential threat by destabilizing our climate.13


8/35


Sierra Club and Oil Change Inernaional recenly calcu-

laed ha subsidies o he ossil uel indusry in 2009 and

2010 amouned o a 59 o 1 reurn on he money ha he

indusry spen hose years on lobbying and on inancing

poliical campaigns.22

In his repor, Food & Waer Wach summarizes recen

scieniic lieraure on he waer polluion, landscape

changes, air polluion, climae polluion and wase

disposal problems brough on by drilling and racking or

oil and gas. These impacs are due in large par o he

oxic naure and pervasive spread o he chemical pollu-

ans ha he indusry brings o he surace. (See Box

2.) Recen research urher reveals how hese and oher

impacs collecively damage public healh and disrup

communiies.

Box 2 The pollutants that the oil and gas industry brings to the surfaceNatural gas, natural gas liquids, crude oil, drilling muds and produced water are innocuous-sounding terms that

conceal the nature of all that the oil and gas industry brings to the surface.

-

carbons is called crude oil when the bulk of the hydrogen and carbon atoms that make up the mix are bound together

in large molecules, and the mix is liquid when it reaches the surface.23The term natural gas liquids refers to a variety of

2

6

3

8), butanes

4

10) and other lightweight hydrocarbon chains that happen to be somewhat wet to the touch at moderate temper-

atures and pressures.24The term natural gas is used broadly to refer to various gases that are made up primarily of

4),25a potent greenhouse gas26and a primary driver of global warming.27But drilling and fracking bringsmuch more to the surface than just these hydrocarbons.

chemical compositions vary in time and vary from well to well, but are otherwise not well characterized.28

Many of the hydrocarbons brought to the surface are hazardous pollutants, including volatile organic compounds

aromatic hydrocarbons.29

with ancient salt waters, or brines.30

sodium31 32), and radioactive material

33

Finally, oil and gas companies bring to the surface various amounts of the chemicals used in fracking, and byproducts

from reactions involving these chemicals.34Given trade-secret protections in federal and state laws, and otherwise

often even to the company doing the injecting.35

36

hydrochloric acids are also commonly used to clear out new pathways for oil and gas

37

With the exception of the fracking chemicals and the byproducts of any fracking

chemical reactions, all of the above chemical pollutants had long been safely seques-

tered and immobilized, deep underground. Now, drilling and fracking brings these

pollutants to the surface at baseline levels that risk human health and environmental

damage through water, soil, air and climate pollution. Then there are the greater-than-

baseline levels of contamination: the accidents, leaks, spills and explosions that are

that they can be cleaned up.

The liquids, sludge and solids that remain from what the industry does not leak into

the air, spill on the ground, burn or otherwise use, are adding up to create waste

disposal problems. This pollution is part and parcel of the current all-of-the-above

approach to U.S. energy policy. All of the above pollutants need to stay underground.

Mud pit on a Bakken shaledrilling site.


9/35


Pu simply, widespread drilling and racking or oil and

gas is inherenly unsae and erribly shorsighed. This

repor explains why i is ime or a ban. The oil and gas

indusrys corruping inluence on policy and govern-

men hreaens o coninue he harm, and o coninue o

supplan proven and sae soluions or meeing energy

needs.

Water and Land ImpactsThe oil and gas indusrys capure o U.S. energy policy

has colored several high-proile invesigaions o aquier

conaminaion in he afermah o drilling and racking,

namely in Pavillion, Wyoming, in Dimock, Pennsylvania,

and in Parker Couny, Texas.

In December 2011, he U.S. Environmenal Proecion

Agency (EPA) published a draf scieniic repor on

groundwaer conaminaion in Pavillion, Wyoming, saing

ha wase pis likely conaminaed shallow groundwaer38

and ha daa on chemicals deeced in a deeper moni-oring well indicaes likely impac o ground waer ha

can be explained by hydraulic racuring.39The draf

repor called or more monioring o wells o make he

indings o he repor more deiniive.40In he ace o

exreme pressure rom he indusry and rom indusry

advocaes in Congress, however, he EPA decided in

2013 o abandon inalizing he repor.41Insead, he EPA

deerred i o he Sae o Wyoming, which will rely on he

company implicaed in he case o und a new invesiga-

ion.42While he EPA claims ha i sill sands behind

is work and daa,43

he rerea was widely repored as avicory or he indusry.44

In 2012, he EPA similarly rereaed rom is invesigaion

o waer conaminaion cases in Dimock, Pennsylvania,45

which he saes environmenal agency had deermined

were due o drilling aciviies.46The EPA had ound

conaminans in several o he waer wells in quesion, bu

simply saed ha he residens have now or will have

heir own reamen sysems ha can reduce concenra-

ions o hose hazardous subsances o accepable levels

a he ap.47The EPA ailed o evaluae he reasons or

he conaminaion, again leaving he public wih he alse

impression ha affeced residens claims o conamina-

ion had no meri.48

In December 2014, he EPA will issue a draf o a muli-

year sudy on he poenial impacs o racking on

drinking waer resources. In his sudy, he agency is

relying heavily on volunary cooperaion rom he oil

and gas indusry or daa and experise. This reliance on

indusry parly explains he EPAs rerea on he hird

high-proile case o conaminaion linked o drilling and

racking, in Parker Couny, Texas.49According o he EPAs

Inspecor General, a primary reason ha he agency

wihdrew is emergency order agains he company doinghe drilling and racking was ha he company agreed

o paricipae in he EPAs ongoing sudy.50This episode,

in paricular, highlighs how he indusrys conrol over

daa and experise shapes he science and invesigaions

carried ou on behal o he public.

The residens o Parker Couny, Dimock and Pavillion

wen o he EPA because hey did no eel ha heir

respecive saes were being responsive o heir concerns.

Texas, Pennsylvania and Wyoming each have long hiso-

ries o promoing oil and gas developmen, in he name o

prevening wase o oil and gas reserves,51and are paryo inersae resoluions o encourage shale gas exracion

and expansion o naural gas inrasrucure.52The EPAs

unwillingness o complee invesigaions o hese hree

landmark cases o drinking waer conaminaion means

ha he affeced residens have nowhere else o urn.

Generally, he risks and impacs o waer resources

include he indusrys compeiion or waer, land and

surace waer polluion, and aquier conaminaion.53

Water consumptionAffordable access o clean waer is a public healh issue,

and a human righ. Public waer sysems already ace

major challenges ha will be exacerbaed by global

warming, in he orm o locally severe droughs, exreme

sorms and oherwise alered rainall, snowall and

snowmel paterns.54Over a cenury o climae pollu-

ion semming rom he oil and gas indusry conribues

signiicanly o his warming.55

Land is cleared for drilling and fracking in Pennsylvania.


10/35


Now, wih widespread drilling and racking, he oil and

gas indusry is no jus adding more climae polluion, i

is adding signiican demand or resh waer in already

waer-sressed regions o he counry. Even worse, i is

leaving a legacy o waer polluion and landscape disur-

bance.

Waer use per well varies by region, bu companies

ypically require abou 5 million gallons o waer o drilland rack a single shale gas or igh oil well. 56Some

horizonal wells in he Eagle Ford shale play in Texas have

been racked wih more han 13 million gallons each.57

Esimaes vary as o how much injeced luid reurns,

rom beween 5 and 50 percen.58In he Marcellus region,

beween he irs sage o racking and he ime he

new well is pu ino producion, he liquid ha lows up

he well amouns o only abou 5 percen o he volume

injeced.59Thus, almos all o he waer used in racking

luids is no available or reuse, and is underground

indeiniely.Oil and gas advocaes claim ha heir waer use is low

relaive o overall waer use, bu saisics ha average

over large regions are decepive. Frackings use o waer

can be inensive, happening all in a local hospo or

drilling and racking and all a once or each new well.

Cold-waer sreams in norhern Pennsylvania, where

Marcellus shale developmen is concenraed, have rela-

ively small low raes,60ye wihdrawals or racking have

been primarily rom surace waers, wih wihdrawals

rom public waer sysems indusrys second choice.61

Regulaors anicipae increased use o groundwaer in he

region over he coming years i he pace o drilling and

racking coninues.62

A 2014 repor by Ceres looked a indusry-repored daa

on 39,294 oil and gas wells racked beween January 2011

and May 2013, and deermined ha 39 percen were in

regions wih high waer sress and 8 percen were in

regions wih exremely high waer sress.63Waer sress

is a measure o waer compeiion in a region, and regions

wih high waer sress are hose where oal waer wih-

drawals (no jus or racking) make up 40 o 80 percen o

he oal waer available or wihdrawal, while exremelyhigh waer sress means ha more han 80 percen o

available waer is being wihdrawn.64The repor also

deermined ha over 36 percen o he oil and gas wells

included in he sudy were in regions ha will experience

groundwaer depleion.65

To rack he Barnet Shale in Texas, oil and gas companies

used groundwaer and surace waer in equal measure

unil 2006, and increased he use o surace waer o abou

70 o 80 percen o oal waer use rom 2007 o 2010,

bu have since increased groundwaer wihdrawals.66

Thegroundwaer wihdrawals are primarily rom he Triniy

aquier, which is among he mos depleed aquiers in he

sae.67

A paricular concern is he exen o which oil and gas

companies are compeing wih armers or access o

limied reshwaer resources. In 2012, a a Colorado

aucion o waer righs, oil and gas companies were he

op bidders, driving up waer prices or he saes armers

many o which were enduring severe drough condiions.68

In New Mexico, some armers affeced by severe drough

condiions are, in lieu o arming, selling heir righs o

irrigaion waer o oil and gas companies.69

This compeiion wih, or ourigh displacemen o, agri-

culural waer use will only increase i unconvenional oil

and gas developmen coninues o expand in counies ha

already ace waer sress, and ha are likely o experience

even larger waer supply problems as a consequence o

climae change.

Impacts on surface waters, forests and soils

The consrucion o new well sies and supporing inra-srucure are jus he irs sage in he indusrys harm o

surace waers, oress and soils. Each Marcellus Shale gas

well pad sis on abou hree acres o cleared land, and or

each sie anoher six acres is cleared o build supporing

access roads, pipelines and oher ossil uel inrasruc-

ure.70The indusrys consrucion projecs increase he

amoun o sedimen ha lows ino rivers and sreams,

causing ecological harm ha is compounded by excessive

waer wihdrawals.71Water tanks lined up in preparation for fracking.


11/35


Foress and agriculural lands provide waershed-scale

ilraion as rainwaer and snowmel low ino rivers and

recharge aquiers.72Widespread shale developmen in he

Marcellus region is expeced o cover hundreds o hou-

sands o acres wih suraces ha are impervious o rains,

signiicanly disruping his ilraion.73New indusry

sies, pipelines and roads also expose more ores o more

clearing, changing he balance o wildlie, harming ores

healh and hus urher affecing waersheds and ground-waer recharge.74Air polluans, including ozone, can also

harm oress and agriculural lands ha are downwind o

oil and gas operaions.75

Waer qualiy in rivers, sreams and shallow aquiers, and

soil qualiy on agriculural lands, are urher hreaened

by spills o racking chemicals and o oxic oil and gas

indusry wases, as well as by inenional spreading o he

wases, or example, o de-ice roads given he sals in he

wases.76A recen sudy near acive drilling and racking

operaions in Colorado ound elevaed levels o knownand suspeced endocrine disrupors in surace waers and

shallow groundwaers, consisen wih wha would be

expeced rom spills o he chemicals used by he indusry

in racking luids.77

The oil and gas indusrys wases primarily he lefovers

o whas brough o he surace conain corrosive sals,

radioacive maerial, oxic meals, hydrocarbons, and

racking chemicals, as oulined in Box 2 (page 4). Each

year housands o leaks, blowous and spills rom he oil

and gas indusry involve hese wases, as well as various

racking chemicals ye o be injeced, and/or produced oil

and naural gas liquids. (See Box 3.)

In a shining example o he oil and gas indusrys capure

o regulaory policy, he indusrys hazardous wases rom

drilling and racking are exemped rom ederal regula-

ions on hazardous wase, simply by virue o having been

generaed by he oil and gas indusry.78I wases wih

similar characerisics were o be generaed by anoher

indusry, hey would be deemed hazardous.79

The liquid wases ha do no ge spilled are ypically

sen o indusrial reamen aciliies, processed or reuse

or injeced back underground ino disposal wells.87In

Pennsylvania, abou hal o he lowback wase is sen o

indusrial reamen aciliies, abou one hird is reused

and increasing amouns are injeced back underground

ino disposal wells, commonly afer being sen o Ohio or

Wes Virginia.88In Texas, Oklahoma and Norh Dakoa,

he dominan pracice is o dispose o liquid wases by

injecing hem back underground.89In Caliornia, regula-

ors have recenly haled he wase injecions a numerous

wells ou o concern ha he wases are being injeced

direcly ino aquiers.90

Treamen a indusrial wase aciliies is imperec,

allowing conaminans o low hrough ino rivers and

sreams. In 2013, scieniss repored ess on sedimen

rom he bed o Blacklick Creek, in Pennsylvania, a

he poin where effluen lowed ino he creek rom an

indusrial reamen plan wih a hisory o acceping oil

and gas indusry wases.91The sedimen conained grealy

enhanced levels o radioacive maerial, wih radiaion

a 200 imes he level ound in background sedimens.92

No only does his pu a risk hose who ea ish ha rely

on he ood chain rom his sream, bu i illusraes ha

reamen is no necessarily effecive. Baseline levels o

polluion, wih some larger polluion evens, are inheren

o drilling and racking or oil and gas.

Box 3 Accidents and spillsare business as usual

In 2008, ProPublicaexamined local and state govern-

than 1,000 cases of leaks and spills at oil and gas

industry sites.80According to the Denver Post, the oil

and gas industry has reported about 2,500 spills in

percent having contaminated surface water and 17

percent having contaminated groundwater.81In North

Dakota in 2011, the oil and gas industry also reported

over 1,000 spills.82An analysis by Energy & Environ-

mentlooked at available data and counted over 6,000

spills and other mishaps in 2012 alone from oil and

gas industry operations throughout the United States,

83A

subsequent analysis found at least 7,662 spills, blow-

outs, leaks and other mishaps in 2013 in 15 top states

for onshore oil and gas activity.84In Pennsylvania, theDepartment of Environmental Protection has recorded

209 incidents in which the oil and gas industry either

85

All of these estimates are conservative, given that they

-

cult to identify. A PhD thesis in Petroleum Engineering,

completed in May 2014 at Louisiana State University,

explains that underground blowouts may just appear

to occur less frequently than those that reach the

86


12/35


To he exen ha reamen is effecive, i concenraes

he conaminans and hus generaes solid wase. Toxic

hydrocarbons, heavy meals and radioacive maerial also

become concenraed in sludge a he botoms o wase

pis and in sludge and scale deposis wihin equipmen,

such as wihin pipes and anks.93Radiaion rom hese

concenraed wases, or rom he rock cutings brough o

he surace during drilling, is seting off deecors a he

gaes o landills.94Massive quaniies o low-level radioac-

ive wases pass hrough hese deecors, wheher opera-

ional or no, and ge dumped in landills,95i hey are no

irs spilled beside a road on he way o a landill.96The

indusrys radioacive solid wases are also being illegally

dumped.97

Under a previous governor, Norh Carolinas Deparmen

o Environmen and Naural Resources warned ha layerso cutings could resul in plugging o he landill and o

evenual spills o luid, known as landill leachae, ha is

enriched wih diverse conaminans, including he radio-

acive maerial.98Given ha he hal-lie o radium-226 is

1,600 years, such spills would ain he surrounding soil

and waershed or cenuries.99

Surace-waer conaminaion also resuls when conven-

ional wasewaer reamen aciliies ha are no

equipped o rea racking wasewaer noneheless receive

i. The conaminans can pass righ hrough hese acili-ies and be discharged ino rivers, causing problems or

waer sysems downsream, as well as or aquaic lie.100

When downsream waer uiliies disinec river waer

wih elevaed levels o chloride or bromide wo sals

ha characerize racking wasewaers101 he resuling

chemical reacions can orm harmul byproducs ha are

linked o cancer and birh deecs and ye are difficul o

remove once presen in drinking waer supplies.102

Raher han simply no allow surace disposal, he EPA

is drafing rules ha would require pre-reamen o

shale gas wasewaers beore hese wases could be sen

o convenional reamen aciliies ha serve public

waer sysems.103And since racking is also occurring in

non-shale ormaions, guidelines or only shale orma-

ions are inadequae. However, as is he case wih rounds

o wasewaer recycling and indusrial reamen, his

sole pre-reamen concenraes he oxins, creaing newdisposal problems.

Aquifer contaminationIn addiion o conaminaing armland and waersheds,104

plumes rom leaks and spills o liquids a he surace can

seep down ino soil and can conaminae shallow aquiers,

as a signiican racion o spills have done in Colorado.105

Bu aquiers also ace unseen hreas rom below, boh

immediae and over he long erm.

Disproporionaely high levels o arsenic, as well assronium, selenium and barium, have been ideniied in

groundwaer in areas o he Barnet Shale region in Texas

ha have seen more oil and gas aciviy.106The presence

o hese conaminans was believed o be due o heir

increased mobiliy, as a consequence o eiher nearby

waer wihdrawals or mechanical disurbances, such as

vibraions inroduced during drilling and racking.107

In a handul o incidens, oil and gas companies have

injeced racking luids or oil and gas indusry wases

very close o, i no direcly ino, underground sources

o drinking waer.108Beyond hese cases o direc

conaminaion, a nework o differen pahways can allow

conaminans o indirecly seep ino and conaminae

groundwaer rom below, in he afermah o drilling and

racking.109The pahways include new racures creaed by

hydraulic racuring, exising naural racures and auls,

and openings along wells wih compromised consrucion,

or inegriy.110

Methane and other hydrocarbon gases

A sudy published in 2000 esimaed ha ens o hou-

sands o oil and gas wells in Norh America were leakinggas, including ino he amosphere and ino shallow

aquiers.111

In 2011, scieniss observed ha mehane concenraions

in samples rom waer wells locaed in regions o acive

Marcellus and Uica shale gas developmen were 17 imes

higher, on average, compared o samples rom waer

wells in regions wihou drilling and racking aciviy.112


13/35


The auhors concluded ha leaky well casings were he

mos likely cause.113In 2013, several o he same scien-

iss sudied 141 wells in Pennsylvania and ound higher

mehane concenraions by a acor o six on average

in waer wells locaed less han abou 3,200 ee (i.e.,

1 kilomeer) rom a naural gas well, compared o waer

wells locaed arher away rom any naural gas well.114

While mehane isel may no be oxic, is presence inaquiers indicaes he presence o oher hydrocarbons ha

are oxic. (See Box 2, page 4.) When a mix o hydrocarbon

gas eners unvenilaed spaces hrough conaminaed

waer wells, i can cause suffocaion and even resul in

explosions.115Mehane ha conaminaes aquiers may

also, hrough geochemical reacions or oher mechanisms,

increase levels o arsenic and oher harmul oxins in

waer brough o he surace.116

Ulimaely, he mehane and oher hydrocarbons may or

may no originae rom he rock ormaion being argeed,

bu he resul is he same: he mehane and oher hydro-carbons are presen a increased levels as a consequence

o drilling and racking. There are many well-sudied

reasons why, and he scale o he problem derives rom

he scale o widespread drilling.

Abou 2.6 million onshore oil and gas wells have been

drilled in he Unied Saes since 1949,117and abou 1.1

million o hese are acively producing.118More han 20

years ago, he EPA esimaed ha abou 200,000 o he

over 1 million abandoned oil and gas wells in he counry

were inadequaely plugged, meaning ha hey providepahways or hydrocarbon gases, i no oher luids,

o low up o he surace or o underground sources o

drinking waer.119

Addiionally, over 30,000 wells have been drilled or he

purpose o disposing o oil and gas indusry wases, via

injecion.120A gray area lies in how he indusry akes

brines brough o he surace and hen pumps hem back

underground ino wells o improve he low o oil ou o

adjacen wells; here are more han 110,000 o hese injec-

ion wells or enhanced oil recovery.121

Consruced o concree and seel, all o he above wells

age and degrade over ime.122Moreover, rom he begin-

ning o heir consrucion, a signiican racion o oil

and gas wells several percen have well inegriy

problems, meaning ha injeced luids, hydrocarbons

and ancien brines may no be conained wihin he

inner ubing, or casing, o he well.123 Once ouside o his

casing, hese conaminans give rise o polluion when

hey escape o he surace or move ino underground

sources o drinking waer ha were drilled hrough in

order o consruc a well.124

Due o a variey o reasons, including cemen shrinkage

and/or poor bonding, space can orm beween he ouer

shell o cemen and he various rock ormaions hrough

which an oil and gas well passes, creaing a pahway or

he poenial low o conaminans.

125

A PhD hesis in peroleum engineering, compleed in

May 2014, explains ha highly pressurized luids during

hydraulic racuring can direcly cause such separaion,

resuling in underground blowous evens in which

racking luids ravel back along he pah o he well

beween he concree and he rock ormaion, raher han

ino he argeed ormaion.126Compared o blowous ha

spew luids ino he air a well sies, hese blowous are

more difficul o deec, or obvious reasons.127

Fluids may also leak rom oil and gas wells hrough smallracures or channels ha orm wihin he inerior o

he consruced well, eiher wihin he cemen isel or

beween concenric cylinders o cemen and meal pipe,

or casing, used o build he well.128Improper cenering o

casings gives rise o less uniorm lows o cemen during

he consrucion o he well, and his in urn is anoher

acor ha increases he risk o well inegriy ailures.129

Gradual setling over ime due o he exracion o oil and

gas also applies sress ha may evenually break, or crack,

consruced wells, leading o ailure.130

A well head after fracking equipment has beenremoved from the drilling site.


14/35


As he many differen mechanisms o well ailure sugges,

he problem o leaky wells, and ourigh well ailure, is

he opic o a large number o sudies by indusry and

academic scieniss. The botom line, however, is ha

many oil and gas wells leak, and ha he causes o leaks

are difficul o deec and ix, given ha hey occur or

so many differen reasons, subjec o diverse geological

condiions and o diverse indusry pracices.

A major concern is ha, as a given years newly drilled and

racked wells decline in producion and degrade physically,

he percenage ha develop inegriy problems is likely

o increase over ime.131Ye daa on he incidence o well

inegriy problems as wells age are severely limied, no

leas because shale gas and igh oil wells are relaively

new. A 2003 sudy looked a ederal daa on he over

10,000 wells drilled ino he ouer coninenal shel o he

Gul o Mexico a he ime, and ound ha more han 40

percen o hose ha were over 10 years old displayed

susained casing pressure, meaning ha he wells wereno conaining hydrocarbon gas wihin he inner ubing, or

casing, used o channel hydrocarbons up or producion.132

Now, according o a 2014 sudy, iniial daa on shale gas

well inegriy in Pennsylvania do no bode well or he

uure.133In he Marcellus Shale region o Pennsylvania,

shale gas wells have proven o be more prone o well

consrucion impairmens linked o well inegriy

problems, compared o convenional wells, especially in

he norheasern par o he sae, where over 9 percen

o shale gas wells have indicaions o compromised well

inegriy.134

Conaminaion o aquiers rom mehane and oher hydro-carbon gases alone warrans precauion over widespread

drilling and racking. However, anoher major concern is

ha evidence o sray gas conaminaion could be indica-

ive o uure waer qualiy degradaion, similar o ha

observed in some convenional oil and gas ields.135One

reason is ha such conaminaion could be a harbinger o

conaminaion rom he migraion o oher luids, no jus

he relaively buoyan hydrocarbon gases.136

Hydrocarbon gases in aquifers

as a sign of more problems to come

I oil and gas companies drill and rack he hundreds

o housands o new shale gas and igh oil wells envi-

sioned, he legacy o aging, degrading and increasingly

compromised wells will grow subsanially. This legacy

may lead o long-erm, region-wide changes in how luids

mix and move underground over he coming years and

decades. How hese changes migh impac he qualiy o

underground sources o drinking waer remains unknown,

highlighing he enormous risks inheren o widespread

drilling and racking.

Aquiers are immediaely pu a risk when he leadingedge o injeced racking luid propagaes new racures

arher han anicipaed, reaching nearby oil and gas

wells, or injecion wells ha have compromised cemening

and casing.137These rack his, or so-called well-o-well

communicaion evens, someimes give rise o surace

spills,138and hey are occurring or a leas wo reasons.

Firs, predicing he acual lengh o racures is a noori-

ously difficul mahemaical problem, sensiive o param-

eers ha are speciic o he geology surrounding each

individual well, and his sensiiviy leads o some racures

propagaing arher han expeced.139Second, he locaionsand dephs o many housands o he more han 1 million

abandoned oil and gas wells in he Unied Saes are no

known.140

The issue o rack his is oreshadowed in regulaions se

orh by he EPA under he Sae Drinking Waer Ac, and

exposes a complicaed sory abou he oil and gas indus-

rys capure o U.S. regulaory policy. (See Box 4, page 11.


15/35


Box 4 Oil and gas industry injectionsUnder authority from the Safe Drinking Water Act, the U.S. EPAs

141In 1989, the U.S. Government

water via nearby abandoned wells that had integrity problems.142These

were frack hits, without the fractures.

-

burton Loophole, since it was created through legislation crafted behind

143

144

that would require addressing the issue of frack hits, were it not for

this loophole.145The loophole thus explains how the issue of frack hitshas remained beyond regulation, and highlights how the oil and gas

industry, through its capture of U.S. energy policy, has erected barriers to

protecting public health and the environment.

are triggered.146

being to just use a circle with a quarter-mile radius.147Alternatively, applicants for permits can use a calculation based on

148In particular,

149

In 2004, a panel of experts convened by the EPA noted that these options were adopted even though much existing

drinking water] and actual injection rate).150

on operational assumptions made in the early 1980s,151and concluded that enough evidence exists to challenge the

water]... .152

The EPA, despite these strong statements, has kept the simplistic protections in place, having deferred action because

data show that the quarter-mile approach is inadequate.153

Most of these state agencies, as regulators of oil and gas development in their respective states, are party to the Inter-

154so as to prevent physical waste of oil or gas or loss in the ultimate

recovery thereof.155

which has created a platform for the oil and gas industry that gives the illusion of transparency.156

This episode illustrates how longstanding alignments between the oil and gas industry and state governments shape

-

(continued on page 12)

Fluid awaits injection at a fracking site.


16/35


In addiion o he immediae risks o conaminaion rom

rack his, he incidens clearly illusrae how widespread

drilling and racking can change he conneciviy o a

nework o conaminaion pahways on a regional scale.

Several recen sudies have begun o approach he larger

concerns abou long-erm impacs on a regional scale,

highlighing he severely limied scieniic undersanding

o he issue, and underscoring he simple-mindedness o

he curren regulaory approach o oil and gas indusryinjecions. (See Box 4.)

A 2012 sudy used a simpliied mahemaical model o

explore how preerenial pahways or luid low, such as

auls and naural racures, can inluence he ime scale

in which injeced conaminans migh reach underground

sources o drinking waer under a wors-case scenario.163

The model suggesed ha slow conaminaion could

occur wihin a decade.164A second 2012 sudy ound

evidence o a mach beween he geochemical proile o

saliniy in shallow groundwaer in norheas Pennsylvaniaand ha o Marcellus brine, suggesing a preexising

nework o pahways (i.e., unrelaed o racking) beween

he Marcellus Shale and shallow groundwaer.165In

2014, anoher sudy demonsraed a way o reduce he

complexiy o modeling he slow low o conaminans

hrough naural auls,166wih an aim oward modeling

ha approaches a regional scale.167This effor o incor-

porae numerous wells and auls a a regional scale is

preliminary, based on simpliying assumpions abou he

geomery and parameers ha conrol low hrough hese

conaminaion pahways.168

The EPA, as par o is muli-year sudy o he poen-

ial impacs o hydraulic racuring on drinking waer

resources, has conraced researchers o model a handul

o simplisic conaminaion scenarios.169However, he

preliminary models are ar rom being employed o predic

and poenially reduce he likelihood o uure conamina-

ion evens semming rom a single racked well, much

less o address he prospec o conaminaion on a

regional scale ha communiies wih widespread drilling

and racking may ace.170

A he same ime, he oil and gas indusrys capure o

U.S. energy policy is also on display in he resuls o he

conraced research. The scieniss modeling he conami-

naion scenarios or he EPA view using heir novel

compuaional mehods o invesigae he likelihood o

conaminaion as somewha o a side noe, and pu equal

i no greaer emphasis on he poenial uure use o heir

mehods o increase he producion o hydrocarbons rom

hydraulically racured wells.171

ground sources of drinking water from oil and gas

industry injections is based entirely on either an

AoR approach) or, alternatively, on an overly simplistic

calculation using a decades-old mathematical formula

that is divorced from modern geological understandingand modern computational science.

With wells now tunneling horizontally more than two

miles through rock formations and being hydrauli-

cally fractured in tens of stages, and with hundreds

without diesel injected at each stage, much has

changed since the operational assumptions made

in the 1980s that led to the AoR criteria. Yet fracking

injections that do not contain diesel fuels are not even

Loophole, and until recently fracking injections that

do involve diesel fuels have been in regulatory limbo.

predictably problematic. The Environmental Integrity

Project revealed that many companies had edited

their previous submissions to FracFocus.org, thereby

rewriting history and concealing their use of diesel

157

158

While the guidance acknowledges that the simplistic

assumptions for the formula approach do not apply, it

merely recommends that regulators use one of several

159

The guidance is most remarkable in that it still does not

draw on decades of progress in the mathematical and

computational sciences, emphasizing only that such

160

Moreover, the guidance does not mention the modeling

ongoing study of contamination pathways related to

hydraulic fracturing.

In June 2014, in unspoken disapproval of the EPAsguidance on diesel fuels, a GAO report pointed to

new risks to underground sources of drinking water

presented by hydraulic fracturing with diesel fuels

experts to review the risks.161The report also notes that

the surge in the volume and frequency of the oil and

rock formations, leading to surface spills162 events

that are akin to the surface spills from frack hits.

(Oil and gas industry injections

continued from page 11)


17/35


The EPAs recen guidance on he use o diesel uels in

racking luids merely noes ha modeling o acually

calculae he poenial exen o he migraion o injeced

luids ofen requires a signiican body o daa.172This

saemen is a reerence o he ac ha acually deer-

mining when and where conaminaion evens are likely

o occur requires deailed inormaion ha is speciic o

he geology surrounding individual wells across a region,

including he presence o nearby naural auls and rac-ures, induced racures rom racking, and compromised

wells. Ye his inormaion is no always available.

Acually deermining when and where conaminaion

evens are likely o occur would also require knowledge o

he parameers ha conrol low hrough hese poenially

conneced pahways, over long periods o ime. These

parameers are highly uncerain, and vary by locaion.

Ye he oupus o he models are likely sensiive o he

parameers used, and o he assumpions ha hese

parameers embody. For example, assuming ha here isno naural aul providing a poenial pahway or conam-

inaion, when in ac here is one, undamenally changes

he model. The resul is ha crucial inormaion o ensure

proecion is no available.

As one ederal scienis old journaliss a ProPublica,

[]here is no cerainy a all in any o his You have

changed he sysem wih pressure and emperaure and

racuring, so you don know how i will behave.173 The

uncerainy over how he hydrogeological sysem will

respond raises he specer o long-erm aquier conami-

naion as a icking ime bomb, wih grave implicaions

or waer availabiliy, and or local economies, across he

counry. This risk is simply unaccepable.

Earthquakes, Lightning Strikesand Exploding TrainsScieniss now believe ha, by pumping large amouns

o luids underground, he oil and gas indusry is largely

o blame or he signiicanly increased requency o

earhquakes observed in he Unied Saes in recen

years.174

For decades, he cenral and easern Unied Saesconsisenly regisered abou 20 magniude 3.0 or greaer

earhquakes per year.175 In he mid-2000s, his rend broke,

and earhquake requency increased, direcly coinciding

wih he expansion o modern drilling and racking.176

In 2010, 2011 and 2012 combined, here were abou 300

earhquakes o magniude 3.0 or greaer.177In jus he irs

hal o 2014, Oklahoma alone regisered abou 200 magni-

ude 3.0 or greaer earhquakes.178

In a handul o cases, he evidence suggess ha he

speciic process o hydraulic racuring has also induced

earhquakes, mos recenly in Ohio.179Mos o he oil and

gas indusry earhquakes, however, are evidenly occur-

ring when high-volume wases ha are injeced ino UIC

Class II wells lubricae auls, or increase pressure beyond

he srengh o inersecing auls.180A 2014 sudy has

repored evidence ha injecion o oil and gas indusry

wases is riggering earhquakes cenered up o over 20miles away rom he injecion well, in par because o

modern, very high-rae injecion wells.181

A magniude 4.7 earhquake was among he swarm o

1,000 smaller earhquakes all measured in Greenbrier,

Arkansas, in 2010 and 2011, again atribued o injecions

o wases.182Among he oil and gas indusry earhquakes

ha have shaken Oklahoma, none was larger han he

magniude 5.7 earhquake in 2011 ha sruck Prague,

Oklahoma, resuling in injuries o wo people and

he desrucion o 14 homes.183

Now, a 2013 sudy hassuggesed ha large remoe earhquakes ar rom he

Unied Saes may acually be riggering earhquakes

wihin he Unied Saes, including he magniude 5.7

earhquake ha hi Prague, Oklahoma.184Tha is, oil and

gas indusry injecions appear o be bringing auls o

near-criical hresholds, and hen seismic waves rom large

bu remoe earhquakes can hen rigger he movemen o

hese auls.185

Residential damage from the magnitude 5.7 earthquake in

2011 that struck Prague, Oklahoma.


18/35


Ideniying when and where criical hresholds are

nearly reached requires monioring ha can only be

done remoely, and hus imprecisely, given ha auls are

buried deep underground. This phenomenon o criical

hresholds being remoely riggered emphasizes he large

uncerainies ha cloud he quesion o when and where

he nex oil and gas indusry earhquake will srike. Jus

how srong and poenially desrucive and cosly he

indusrys earhquakes migh become also remains anopen quesion.

In some cases, he luids injeced by he oil and gas

indusry have evidenly enered and acivaed previously

unknown auls.186The ac ha here are unknown auls

urher highlighs undamenal limiaions o under-

sanding, and predicing, when and where he nex oil

and gas indusry earhquake will occur. This ac likewise

highlighs ha assumpions abou he nework o waer

conaminaion pahways wihin a neighborhood o a given

injecion well can change.More generally, he seismic waves ha make up earh-

quakes wheher unleashed naurally or induced by he

oil and gas indusrys injecions may exacerbae he

problem o leaky oil and gas indusry wells. The seismic

waves pass hrough a differen dephs a differen speeds,

owing o differences in he densiy (and elasiciy) o

he underlying layers o rock ormaions peneraed by

an oil and gas well. As a consequence, seismic waves do

no uniormly shake he consruced wells, resuling in

physical sresses ha can only increase he likelihood o

cemening or casing ailures.

Oil and gas indusry earhquakes have aken many by

surprise, bu scieniss have long known ha injecions

(and wihdrawals) o luids beneah he surace can induce

earhquakes.187Few, i anyone, however, anicipaed he

recen incidens in Norh Dakoa in which anks holding

oil and gas indusry wases have been sruck by lighning,

resuling in explosions ha spilled conaminans ono

surrounding lands and burned or days.188The sorage

anks are evidenly exploding because, in an effor o

avoid corrosion, he meal anks are lined wih iberglass,

which has much lower conduciviy han meal and hus

overheas.189

Trains carrying igh oil rom drilling and racking in he

Bakken region o Norh Dakoa are also exploding.190

The surge in igh oil producion in Norh Dakoa and

Texas has led o a rapid expansion in he ranspor o

oil by rain o reineries, in par because producion has

oupaced pipeline consrucion.191Energy Secreary Ernes

Moniz has noed ha he oil indusry has acually begun

o preer ransporing oil by rain, or he lexibiliy i

offers.192However, several oil rain explosions mos caa-

srophically in Lac-Mganic, Qebec, which desroyed

several blocks o he own and killed 47 people havebrough he so-called bomb rains o he oreron o

public atenion.193

The our high-proile explosions hus ar in Qebec,

Virginia, Alabama and Norh Dakoa relec ha he oil

conains relaively large amouns o naural gas liquids,

which are highly explosive.194The explosions also relec

ha large quaniies ofen more han 2.5 million gallons

per rain are now being sen very long disances by rail

o reineries, ypically abou 1,000 miles.195

The oil rain explosions have brough he issue o rackingo regions ha are no acively argeed or racking,

including Minnesoa, Washingon, D.C., Alabama and

he Paciic Norhwes.196For example, abou 250 oil

rain cars pass hough downown Seatle each day, and

recenly several o hese cars derailed a low speed,

wihou inciden, serving as a poenial wake-up call or

he ciy.197An analysis o planned projecs or expanding

reinery capaciy in he region ironically including he

conversion o aciliies inended or renewable liquid uels

would add as many as 12 one-mile-long oil rains each

day o he Norhwes railway sysem.198

Taken ogeher, he earhquakes, lighning srikes and

exploding rains are a reminder ha widespread drilling

and racking now means many differen hings o he

communiies ha are affeced in differen ways. Bu

nohing affecs residens o hese communiies living

alongside oil and gas indusry sies more viscerally han

he oil and gas indusrys air polluion, which lows along

wih he indusrys climae polluion.Aftermath of the Lac-Mgantic, Quebec, oil trainderailment in July 2013.


19/35


Air and Climate ImpactsIn essence, drilling and racking gives rise o hree

differen sreams o polluans lowing ino he air: he

clouds o silica dus rom mining or and managing he

sand used in racking luids; he plumes o combusionbyproducs rom engines, lares and explosions; and he

sream o polluans ha he oil and gas indusry boh

brings o he surace and leaks ino he air.

Compromises wih he indusry call or more monioring

o beter undersand precisely wha he risks o oxic

exposures are or everyone living alongside drilling and

racking operaions, bu calls or prolonged monioring

and more sudies jus guaranee urher polluion, and

urher harm. Even assuming ha srong regulaion and

oversigh can be pu in place, and ha negligence, acci-

dens and explosions can be eliminaed, he baseline levelo he indusrys air and climae polluion will guaranee

cerain harm o public healh and will lock in unaccep-

able climae risks. The indusrys air and climae polluion

is bes avoided alogeher wih a ban on racking.

Silica dustClouds o silica dus orm a well sies as sand is managed

and prepared or mixing ino racking luid.199Silica dus

clouds also emanae rom silica mining and processing

sies. As wih he issue o exploding oil rains, silica sand

mining has broadened he reach o rackings impacsbeyond regions argeed or shale gas and igh oil exrac-

ion, wih large amouns o silica mined rom or processed

in Wisconsin, Minnesoa, Illinois and Iowa.200

A recen review o he public healh impacs o drilling

and racking summarizes ha [r]espirable silica can

cause silicosis and lung cancer and has been associaed

wih uberculosis, chronic obsrucive pulmonary disease,

kidney disease, and auoimmune disease.201The Naional

Insiue o Occupaional Saey and Healh measured

silica levels a 11 well sies, as silica sand was being

managed, and ound ha exposures exceeded hresholds

se o proec worker healh, in some cases by a acor o

10.202

Residens living nearby operaions may also ace serious

healh risks. The breahing par o i isn good. You canjus eel i in your hroa, eel i in your nose, explained

an individual living across he sree rom a Wisconsin

sand-washing plan.203Bu he speciic consequences or

hose living nearby sand mines and drilling sies remain

unknown, and largely unsudied.204A school in New

Auburn, Wisconsin, siuaed near our silica sand mines,

has ound silica on air ilers used in he schools air

sysem, suggesing ha low-level exposure in he commu-

niy may be he norm.205

Byproducts from combustionExhaus rom he diesel generaors and large rucksha crowd well sies, and smoke rom laring a well

sies, processing plans, and compressor saions, no o

menion explosions, creae a second sream o oxic air

emissions.

Along wih carbon dioxide rom combusion, hese plumes

conain variable amouns o hazardous air polluans,

including nirogen dioxides, carbon monoxide, pariculae

mater, and volaile organic compounds (VOCs), such as

he hydrocarbons benzene, oluene, ehylbenzene and

xylenes (BTEX) and various polycyclic aromaic hydrocar-

bons (PAHs).206

Hundreds o heavy-duy ruck rips per well are required,

largely o ranspor waer, chemicals, and equipmen, as

well as he wases ha resul rom drilling and racking. 207

Geting he indusry o conver o lees o rucks and

generaors ha burn naural gas would lessen he air

qualiy problems rom diesel exhaus, and he respira-

ory and cardiovascular healh problems associaed wih

such exhaus,208bu no wihou he ill effec o locking in

demand or more drilling and racking.

Smoke rom lares a well sies and processing plans

adds o he baseline levels o engine exhaus in much

less-deined ways, dependen on he efficiency o combus-

ion and he makeup o he wase gases being burned. O

course individual explosions are unoreseen, bu hey have

become an expeced consequence o business as usual,

and hey can lead o oxic smoke billowing or days.209


20/35


The pollutants that oil and gascompanies bring to the surfaceThe hird sream o oil and gas indusry polluion orms

ou o he plumes o well- or sie-speciic mixes o

hydrocarbons and oher air and/or climae polluans, as

discussed in Box 2 (page 4). These are he polluans ha

come rom below ground, and ha are mobilized ino he

air in he afermah o drilling and racking. Now, based

on a handul o sudies in 2013 and 2014, i has become

clear ha he oil and gas indusry emis more air and

climae polluans han officials esimae.

The air and climae polluans ha oil and gas companies

bring o he surace include: mehane and oher VOCs,

such as he BTEX hydrocarbons and oher aromaic

hydrocarbons, including PAHs; hydrogen sulide; radon

derived rom radium presen in argeed rock ormaions;

and any chemicals rom racking suspended in he air as

vapor or aerosol, such as gluaraldehyde, ehylene glycol

and mehanol.210

Varying amouns o hese polluans low rom a vas

array o sources a successive sages wihin he indusry,

including: during drilling, cemening and casing; imme-

diaely afer racking luid injecion; rom sored wases;

rom any accidens, spills and explosions; and rom ine-

icien lares and leaky valves, langes, seals, pneumaic

devices, pipes and oher equipmen used o manage,

process, compress and ranspor he payoff hydrocarbons

he crude oil, naural gas liquids and naural gas. 211

Again, mehane is a poen greenhouse gas and a primarydriver o global warming.212The BTEX air oxics irriae

skin and can cause respiraory and nervous sysem

problems wih shor-erm exposure, and can cause greaer

harm wih long-erm exposure, including cancer.213In he

presence o sunligh, BTEX and oher VOCs also combine

wih combusion byproducs o orm ozone, a respiraory

irrian ha can prove aal or hose wih ashma. 214

PAHs ha all on land and surace waers can accumulae

in he ood chain, poenially resuling in harmul levels

o exposure or humans who consume conaminaed

ish.215Hydrogen sulide is highly poisonous, and oil andgas indusry workers a well sies may be advised o wear

personal moniors equipped wih alarms.216

The chemicals in racking luid, as well as largely

unknown byproducs o chemical reacions during

racking, are mobilized along wih hydrocarbon gases

and oher polluans, and emited ino he air o varying

degrees.217This pus he issue o racking chemical disclo-

sure ino proper perspecive as a signiican bu nonehe-

less singular componen o he indusrys polluion. Full

chemical disclosure would no pu an end o he indusrys

waer and air polluion.

The issue o racking chemical secrecy noneheless

resonaes wih he public, in par because i is an example

o he deerence ha policymakers regularly gran o

oil and gas companies, and because i illusraes how

such deerence holds back scieniic invesigaions o heindusrys impacs on public healh and he environmen.

Indeed, some in he oil and gas indusry have worked wih

he American Legislaive Exchange Commission (ALEC),

and ALEC has in urn helped o see ha sae legislaures

only consider disclosure requiremens ha are accepable

o he indusry.218Even when disclosure is required in

he even o emergencies, as is he case in some saes, a

company can be slow o comply.219

While regulaions vary by sae, rade-secre proecions

graned in he Toxic Subsances Conrol Ac mean ha

racking companies ypically do no have o disclose allhe chemicals hey pump underground.220In ac, in many

cases, oil and gas companies old off-he-shel producs

ino he racking luids ha hey make on-sie, wihou

acually knowing he chemicals conained in hese prod-

ucs.221

I is known ha oil and gas companies have injeced a

wide variey o oxic chemicals o racure wells, and have

injeced many more chemicals or which oxiciies are

no well sudied.222For example, among he chemicals

ideniied, over 100 are known or suspeced endocrinedisrupors.223Numerous known or suspeced carcinogens

also have been used since 2005 as addiives in hydraulic

racuring luids.224Many o he known chemicals used are

volaile, meaning ha hey escape readily ino he air.225

Very litle is known abou healh risks posed by mixures

o all he chemicals brough o he surace, and he exen

o chemical reacions ha orm dangerous byproducs.226


21/35


Beyond inadequae requiremens or disclosure o racking

chemicals, here are many oher undamenal challenges

o quaniying he oil and gas indusrys releases or each

o he above polluans.

The challenges begin wih he number and diversiy o

sources, and how he consellaion o sources changes

over ime as he oil and gas indusry operaes, arges newareas and adops new pracices.227Geological differences

rom well o well, and differen sages wihin he oil and

gas sysem rom producion o disribuion give rise

o differences in he chemical composiions o wha ges

released ino he air.228The low rae and chemical compo-

siion o he plumes rom a single source can also change

over ime, under normal operaions,229and can increase

quickly, and unexpecedly, as a consequence o equipmen

ailures.

These acors make he size and chemical composiions

o he plumes in he hird sream o emissions variable, or

well- and sie-speciic. Imporanly, undersanding o he

indusrys emissions is blocked by lack o access o sies

and o daa held by oil and gas companies, presuming

ha hey have daa. As noed already, hese companies

are empowered by rade-secre proecions and by key

exempions graned o he oil and gas indusry under he

landmark environmenal laws. A PhD hesis compleed in

2014 reveals anoher obsacle o ull inormaion: sources

no couned a all, such as abandoned oil and gas wells

leaking mehane and oher hydrocarbon gases.230

Agains hese challenges, he EPA esimaes emissions

using a botom-up approach, beginning wih an invenory

o all o he differen indusry aciviies underaken in a

given year.231The EPA hen uses largely daed esimaes o

average emissions o each aciviy o arrive a an esimae

o oal emissions rom he oil and naural gas sysems.232

This approach relies heavily on volunary sel-reporing

rom he indusry.233

In 2013, he EPA Inspecor General ound many oil and

gas indusry emission acors o be o low or unknown

qualiy due o insufficien daa, leading o a resul ha

likely underesimaes acual crieria polluan emissions

rom oil and gas producion sources.234For example, here

are no emission acors or air oxics and VOCs emanaing

rom wase pis, rom produced waer anks, rom seps in

he well compleion process including he speciic process

o racking, and rom pneumaic devices, or pressure

valves.235

Daa on he acual levels o various hydrocarbons in

he amosphere, aken rom aircraf lighs and/or rom

surace monioring locaions, make possible an alerna-

ive, op-down approach o esimaing indusry emissions.

Using amospheric chemisry, scieniss ake hese daa

and hen combine hem wih daa on wind paterns o

esimae, working backward, wha he dynamic sreams

o mehane and oher hydrocarbons were ha lowed

ogeher over an oil and gas play and gave rise o he

hydrocarbon levels ha were measured.236

Scieniss using his aircraf measuremen approach in

Uah, Colorado and Pennsylvania sugges ha much more

mehane and oher air polluans are lowing rom oil and

gas sies han botom-up esimaes based on daed emis-

sion acors and indusry sel-reporing.237

Flying over an oil and gas ield in Uah one day in

February 2012, Karion e al. measured very large levels o

mehane he equivalen o beween 6.2 percen and 11.7

percen o naural gas producion ha monh, assuming

ha he day was represenaive o daily emissions ha

monh.238In April 2014, Caulon e al. published a sudy

o mehane emissions during he drilling sage a well

sies in Pennsylvania and ound several super-emiters,

each releasing 100 o 1,000 imes he EPAs esimae

o emissions during he drilling phase, as uilized in isbotom-up, invenory esimaes.239In May 2014, Pron e

al. looked a mehane emissions in he Denver-Julesberg

basin in Colorado over a wo-day srech in 2012 using

monioring equipmen on owers and on aircraf lown

above he play, and concluded rom he measuremens

ha mehane emissions were close o 3 imes higher han

an hourly emission esimae based on EPAs Greenhouse

Gas Reporing Program daa or 2012.240


22/35


Because o variabiliy rom sie o sie, mehane emis-

sions can be used only as a crude indicaor o emissions

o oher polluans brough o he surace by he oil andgas indusry. Noneheless, hese resuls are consisen

wih he EPA Inspecor Generals conclusion ha curren

invenory esimaes undersae he oil and gas indusry

emissions o air oxics and oher VOCs, no jus mehane.

Imporanly, Pron e al. esimaed ha benzene emis-

sions were abou seven imes larger han he Colorado

invenory esimaes would sugges.241The ac ha

benzene emissions were evidenly no jus approximaely

hree imes larger, consisen wih he inding on mehane

emissions, bu closer o seven imes larger, shows how

simple, generic (i.e., linear) ormulas or inerring non-mehane VOC levels rom mehane levels can mislead.

Simple inerence o non-mehane VOCs rom mehane

can hide poenially crucial and harmul differences

in he composiions o he raw hydrocarbon gases rom

well sies, as well as hide differences in he composiions

o he differen sreams o naural gases managed a

differen sages in he naural gas sysem. In oher words,

ar more harmul gases han have been esimaed may

be lowing rom some wells in some regions, no jus

rom he Denver-Julesberg basin. This highlighs ha

widespread drilling and racking is a large, unconrolled

experimen, and ha he consequences or human healh

remain largely unknown.242

Top-down sudies based on aircraf measuremens only

provide a look a emissions over a shor ime span, and

rom sources wihin relaively small areas o indusry

aciviy. A paper published in December 2013 by Miller

e al. has suggesed ha, naionally, in 2010, leakage o

naural gas rom he oil and gas indusry in he Unied

Saes amouned o he equivalen o over 3 percen o

end-use naural gas consumpion ha year; ha is, he

auhors suggesed ha acual emissions were more han

30 percen higher han he EPAs esimae a he ime.243

In a review published in February 2014, Brand e al.

surveyed he scieniic lieraure on oil and gas indusry

mehane emissions and likewise concluded ha he

botom-up, invenory approach used by he EPA signii-

canly underesimaes naional mehane emissions.244

Natural gas dependence causes

more global warming than thought

Because undersanding o naional mehane emissions

is lacking, he climae impacs o widespread drilling

and racking are a mater o curren debae.245Bu he

overwhelming ocus o his debae on he climae impacs

o using naural gas insead o coal o generae elecriciy

loses sigh o he oil and gas indusrys role as a major

source o climae polluion.

Abou wo hirds o U.S. climae polluion sems rom he

oil and gas indusry, wih a litle under 30 percen sem-

ming rom naural gas producion, processing, ranspor

and use.246However, he esimaes o mehane leakage

used o arrive a hese igures are based on he official

underesimaes discussed above.247 The above igures on

climae polluion semming rom he oil and gas indusry

also hinge on comparisons o he relaive conribuions o

he differen greenhouse gases o global warming.248Now,

according o he consensus science ha is presened in he

mos recen Inergovernmenal Panel on Climae Change(IPCC) assessmen, i is clear ha officials have also been

grealy underesimaing he poency o mehane as an

agen o climae change.249

The IPCC now saes ha, pound or pound, a pulse o

mehane rom he oil and gas indusry raps 36 imes

more hea han a pulse o carbon dioxide, over a 100-year

ime rame, and raps 87 imes more hea over a 20-year

ime rame.250Remarkably, since he irs IPCC assess-

men repor, each subsequen repor in 1996, 2001, 2007

and mos recenly 2013 has increased he esimae o

mehanes global warming poenial, relaive o carbondioxide.251The mos recen increase was he larges,252

raising he quesion o wheher more increases are in

sore as climae science progresses.

Nowihsanding he signiican climae polluion rom he

naural gas sysem, advocaes o naural gas have oued

he uel as a ool or addressing he challenge o global

warming.253Debae over he climae impacs o swiching

o naural gas rom oher ossil uels has become conro-


23/35


versial, in par because i is based on a alse choice: burn

naural gas or burn oher ossil uels. Framing he climae

impac o racking in his way loses sigh o hree crucial

poins.

Firs, mos recenly, racking is being done primarily o

exrac oil. Since he end o Augus 2012, abou 75 percen

or more o drilling rigs have argeed primarily oil, no

naural gas, and abou wo hirds o all he drilling rigsoperaing in he Unied Saes are he sor capable o

drilling horizonally hrough shale and igh rock orma-

ions.254Fracking makes i possible o bring o he surace

and burn much more oil han previously imagined, and

here has never been any preense ha such oil consump-

ion is anyhing bu bad or he climae.255Second,

increased naural gas use in he elecriciy secor does no

jus displace oher ossil uels, i displaces cleaner solu-

ions, such as solar, wind and efficiency.256Third, much o

he coal displaced, insead o saying underground, is jus

being expored and burned in oher counries, offseting,a an inernaional level, he U.S. reducions in carbon

dioxide emissions ha come rom swiching o naural

gas.257The claim ha hese oher counries would jus

burn coal rom elsewhere anyway258relecs he excep-

ionally low sandards or U.S. leadership on he issue o

global warming.

These hree caveas se aside, Food & Waer Wach ook a

close look a he condiions and assumpions under which

using naural gas insead o oher ossil uels migh acu-

ally mean marginally less global warming. Burning naural

gas does produce abou hal as much carbon dioxide

as burning coal, wih less poenial or carbon dioxide

reducions when using naural gas insead o heaing

oil, gasoline or diesel.259However, hese poenial carbon

dioxide reducions are offse by he leakage o mehane

rom he naural gas sysem, and jus how much hey are

offse remains an open and conroversial quesion.260

There are a variey o ways o compare mehane emis-

sions o carbon dioxide emissions, in order o begin o

quaniy he climae impacs o burning naural gasinsead o coal, or heaing oils, or gasoline or diesel.261

Mehane does no persis in he amosphere or as long

as carbon dioxide, so merics used o compare emissions

o he wo greenhouse gases depend on he ime rame

considered.262Focusing on he nex ew decades, a ime

rame in which mehane raps much more hea han

carbon dioxide does, pound or pound,263is necessary or

hree undamenal and pressing reasons.264

The irs reason is ha we ace he risk ha climae

ipping poins will be surpassed in he near erm, meaning

ha naural posiive eedbacks could kick in and lead oirreversible changes.265For example, reduced Arcic ice

coverage means more absorbed sunligh and warming.266

Furher, any warming ha haws ice crysals ha had

rapped mehane will give rise o more mehane emis-

sions, and hus more warming.267Indeed, hawing o

permaros in he Yamal Peninsula in Russia, and he

subsequen release o massive amouns o mehane,

likely explains he ormaion o seemingly botomless

craers in July 2014.268Second, even discouning he risk

o climae ipping poins, he changes o he climae ha

are already expeced o accompany 2 degrees Celsius o

pos-indusrial warming promise o be dangerous and

cosly.269Third, curren climae science warns ha o

have a good chance ha is, signiicanly beter han a

50-50 chance o keeping warming rom going beyond 2

degrees Celsius requires a very rapid ransiion off o all

ossil uels, leaving mos underground.270

Reurning o he quesion o mehane leakage, a 2012

sudy ound ha naural gas leakage ha amouns o

more han abou 3.8 percen o naural gas consump-

ion means ha swiching rom burning coal o burningnaural gas o generae elecriciy would be worse or

he climae or abou 20 years, a wash a 20 years, and

marginally less damaging hereafer.271The auhors

urher deermined ha leakage a abou 7

The Urgent Case for a Ban on Fracking

Documents

Transcript of The Urgent Case for a Ban on Fracking