To Frack or Not to Frack-A Question Not Asked

Challenges in Water Pollution Control Engineering – Bethel - 1963

• Bethel outlines engineering challenges brought on by innovation in knowledge, technology, and financial change:– Familiarity with new methods– Obtaining information form operating personnel– Recognizing the importance of additional design– Maintaining good public relations– Participation in the legal and financial aspects of the new

processes• Fracking – challenges the regulator/engineer on all these

fronts

Water Pollution Issues

Sources of Water Pollution in “Fracking”

• 2-4 Million gallons of water per well – estimates are that annual water use is in range of 70 – 140 Billion gallons (about what 5,000,000 people need annually)

• Out of 2500 chemicals used in fracturing 650 are know to be carcinogenic.

• Produced water – the water that flows back up is 25- 100% of what is injected into the ground – needs to be stored and treated

• Dissolved Methane (biggest component of NG) is a pollutant.

The Good News!

Production from the Barnett Field

Since 1997 More Than 13,500 Wells Completed in the Barnett Shale

But- We’re OK Because This Is Regulated, Right?

• Clean Air Act – most oil and gas production sites are not required to obtain a Title V permit – because their emissions are below the size limit – thus not regulated

• Clean Water Act – exploration, production, processing of oil and gas, process, or treatment operations – exempt (the so called Halliburton Loophole)

• Safe Drinking Water Act – the underground injection of fluids…other than diesel oil…are not considered regulated underground injection for the purposes of this act

• RCRA, CERCLA, EPCRA – all the have some form of exemptions.

Conclusion• Fracking is growing very rapidly and will continue to do so• It is largely unregulated – at the Federal level• Most new techno advances made by industry – regulator needs to run to catch

up• Information is tightly held- “intellectual property” – end result is that regulator

and people need sites don’t know what is being put in the environment• Technical improvement is possible – but not without regulation (supposition on

my part)• Public Relations – poor – see Gasland• The companies are in the forefront of the legal and financial implications of

fracking – regulator needs to catch up• Personal comment – I don’t want to kill the golden goose – I do want to keep it

from drowning in its own waste.