American Oil and Gas Reporter - July 2015 - 43

examples are negligible. "Impacts to
drinking water resources from subsurface
liquid and gas movement may occur if casing or cement are inadequately designed
or constructed, or fail," the agency contends. "There are several examples of these
occurrences in hydraulically fractured
wells that have or may have resulted in impacts to drinking water resources."
However, it acknowledges, such instances "were small compared with the
large number of hydraulically fractured
wells across the country." The report acknowledges that physical separation between groundwater and the horizons commonly targeted in major unconventional
resource plays make the risk of contaminating groundwater remote. "Many hydraulic fracturing operations target deep
formations such as the Marcellus or Haynesville Shale, where the vertical distance
between the base of drinking water resources and the top of the shale formation
may be a mile or greater," the study relates.
"Numerical modeling and microseismic
studies based on a Marcellus Shale-like environment suggest that fractures created
during hydraulic fracturing are unlikely to
extend upward from these deep formations
into shallow drinking water aquifers."
Although many companies post their
fracturing formulae on the FracFocus.org
website, the report also claims there are
limitations to understanding potential
drinking water impacts. "Well operators
claimed at least one chemical as confidential at more than 70 percent of wells reported to FracFocus and analyzed by the
EPA," the study says. "The identity of
these chemicals, and other chemicals in
produced water, are needed to understand
their properties and would also help inform
what chemicals to test for to establish base
line conditions, and to test for in the event
of a suspected drinking water impact."
State Authority
EPA acknowledges that states play the
primary role in regulating most natural gas
and oil development. "EPA's authority is
limited by statutory or regulatory exemptions under the Clean Water Act; Safe
Drinking Water Act; the Comprehensive
Environmental Response, Compensation
and Liability Act; and the Resource Conservation and Recovery Act. Where EPA's
exemptions exist, states may have authority to regulate unconventional oil and gas
extraction activities under their own state
laws."
In New York, that means banning hydraulic fracturing, which Governor Andrew Cuomo did last year (AOGR, January 2015, pg. 219). Press accounts quote
New York Department of Environmental

Conservation spokesman Tom Mailey
saying EPA's report will not prompt the
Cuomo administration to rethink its position. "The EPA's review focused on impacts to water resources related to highvolume hydraulic fracturing, while the
state review was much broader-examining impacts to air, water, public health,
ecosystems, wildlife and community character," Mailey said.
But in her reaction to EPA's draft
study, Texas Railroad Commission Chairwoman Christi Craddick says her agency's
oversight demonstrates how environmental stewardship can coexist with fracturing and its associated activities. "The difference between state and federal regulations is that while feds study the issues,
states act carefully in a timely manner with
science-based information to ensure that
we are properly protecting our environment while not stifling a fast-paced, technologically driven industry," she holds.
"Economic development and environmental safety can and do exist peacefully in Texas, which should be the ultimate
goal for any regulatory body."
COGA's Haley also emphasizes that
state requirements and authorities are
proving sufficient in the Centennial State.
"Fortunately, Colorado already has some
of the most comprehensive groundwater
base line testing rules, and cementing and
casing rules in the country, which further
protect our health and safety," he says.
Colorado also provides the backdrop
for another new report that shows no contamination from oil and gas activity. The
study, which analyzes potential groundwater contamination, was performed by
Colorado State University's Colorado
Water Watch and released almost simultaneously with EPA's draft. Using a
monitoring system composed of a network
of water quality sensors capable of detecting changes in groundwater quality since
February 2014, the analysis collected
hourly data on five well sites in the Denver-Julesberg Basin, transmitted them
into the researchers' database, and analyzed them through event detection software.
Published reports say CSU professor
and CWW team member Ken Carlson
says the analysis found no incidences of
groundwater contamination attributable to
oil and gas, although he acknowledges the
same may not be true of other business activities. "We were in an area without oil
and gas-our control well in this case-and
the salt level went up. We think it was
caused by fertilizer used in agriculture
fields," Carlson is quoted. "It wasn't
necessarily bad, but it was a change." ❒
JULY 2015 43
American Oil and Gas Reporter - July 2015

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