Water and Shale Gas DevelopmentLeveraging the US experience in new shale developments
Global development of shale gas resources hasthe potential to expand significantly outsidethe United States. However, ther...
Contents1	Introduction	                                                                      4    Overview of shale gas li...
3
1IntroductionNatural gas production in the United States has grown significantlyin recent years as improvements in horizon...
In its “2012 Annual Energy Outlook,” theU.S. Energy Information Administration                                            ...
At present, the US shale gas industryis regulated by a patchwork of existing                                          Wate...
recycling. Innovative water management      can represent up to 80 percent of                     Operational performances...
Overview of shale gas life cycle activitiesCivil/site prep                              Completion/frackingForest clearing...
1.1                                                    cubic feet for the United States and              detailed shale ga...
South Africa’s shale gas resourceendowment is interesting as it may                                              Argentina...
Several companies including ExxonMobiland Chevron have begun to drill test                                            Othe...
In FocusShale developments in Argentina, China, Poland andSouth AfricaA key objective of this report is tohighlight the tr...
Many shale operators have startedexploration activities in Argentina.                                                    C...
The shale gas industry has, for the          China CBM has proposed to start              The average depth of shale forma...
With authorizations received, current               transforming the coal-based electricityindustry activities have moved ...
South Africa                                        Shale.40 However, the Karoo Basin                                     ...
17
2Water regulationThe topic of shale gas regulation is dominated by hydraulicfracturing, the key feature of shale gas that ...
2.1                                                                                     State regulations                 ...
Figure 9. Federal and state regulation mapped to the shale gas lifecycle.                               Civil/site prep   ...
Water and Shale Gas Development - Leveraging the US experience in new shale developments
Water and Shale Gas Development - Leveraging the US experience in new shale developments
Water and Shale Gas Development - Leveraging the US experience in new shale developments
Water and Shale Gas Development - Leveraging the US experience in new shale developments
Water and Shale Gas Development - Leveraging the US experience in new shale developments
Water and Shale Gas Development - Leveraging the US experience in new shale developments
Water and Shale Gas Development - Leveraging the US experience in new shale developments
Water and Shale Gas Development - Leveraging the US experience in new shale developments
Water and Shale Gas Development - Leveraging the US experience in new shale developments
Water and Shale Gas Development - Leveraging the US experience in new shale developments
Water and Shale Gas Development - Leveraging the US experience in new shale developments
Water and Shale Gas Development - Leveraging the US experience in new shale developments
Water and Shale Gas Development - Leveraging the US experience in new shale developments
Water and Shale Gas Development - Leveraging the US experience in new shale developments
Water and Shale Gas Development - Leveraging the US experience in new shale developments
Water and Shale Gas Development - Leveraging the US experience in new shale developments
Water and Shale Gas Development - Leveraging the US experience in new shale developments
Water and Shale Gas Development - Leveraging the US experience in new shale developments
Water and Shale Gas Development - Leveraging the US experience in new shale developments
Water and Shale Gas Development - Leveraging the US experience in new shale developments
Water and Shale Gas Development - Leveraging the US experience in new shale developments
Water and Shale Gas Development - Leveraging the US experience in new shale developments
Water and Shale Gas Development - Leveraging the US experience in new shale developments
Water and Shale Gas Development - Leveraging the US experience in new shale developments
Water and Shale Gas Development - Leveraging the US experience in new shale developments
Water and Shale Gas Development - Leveraging the US experience in new shale developments
Water and Shale Gas Development - Leveraging the US experience in new shale developments
Water and Shale Gas Development - Leveraging the US experience in new shale developments
Water and Shale Gas Development - Leveraging the US experience in new shale developments
Water and Shale Gas Development - Leveraging the US experience in new shale developments
Water and Shale Gas Development - Leveraging the US experience in new shale developments
Water and Shale Gas Development - Leveraging the US experience in new shale developments
Water and Shale Gas Development - Leveraging the US experience in new shale developments
Water and Shale Gas Development - Leveraging the US experience in new shale developments
Water and Shale Gas Development - Leveraging the US experience in new shale developments
Water and Shale Gas Development - Leveraging the US experience in new shale developments
Water and Shale Gas Development - Leveraging the US experience in new shale developments
Water and Shale Gas Development - Leveraging the US experience in new shale developments
Water and Shale Gas Development - Leveraging the US experience in new shale developments
Water and Shale Gas Development - Leveraging the US experience in new shale developments
Water and Shale Gas Development - Leveraging the US experience in new shale developments
Water and Shale Gas Development - Leveraging the US experience in new shale developments
Water and Shale Gas Development - Leveraging the US experience in new shale developments
Water and Shale Gas Development - Leveraging the US experience in new shale developments
Water and Shale Gas Development - Leveraging the US experience in new shale developments
Water and Shale Gas Development - Leveraging the US experience in new shale developments
Water and Shale Gas Development - Leveraging the US experience in new shale developments
Water and Shale Gas Development - Leveraging the US experience in new shale developments
Water and Shale Gas Development - Leveraging the US experience in new shale developments
Water and Shale Gas Development - Leveraging the US experience in new shale developments
Water and Shale Gas Development - Leveraging the US experience in new shale developments
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Water and Shale Gas Development - Leveraging the US experience in new shale developments

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A new report by global consulting firm Accenture that looks at the efficient and innovative ways the United States has dealt with water use in shale gas drilling. Accenture offers the U.S. as a model template for other countries who may be considering how (and whether) to frack their own shale deposits.

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Water and Shale Gas Development - Leveraging the US experience in new shale developments

  1. 1. Water and Shale Gas DevelopmentLeveraging the US experience in new shale developments
  2. 2. Global development of shale gas resources hasthe potential to expand significantly outsidethe United States. However, there continue tobe environmental concerns, particularly withrespect to water use. As operators outside theUnited States explore shale gas, there are manylessons that can be taken from the UnitedStates’ experience. This paper highlights areasthat operators of new shale developmentsshould consider. It also includes an analysisof considerations for Argentina, China, Polandand South Africa focusing on water regulation,water use and management, and watermovements during shale gas development.1
  3. 3. Contents1 Introduction 4 Overview of shale gas life cycle activities 81.1 Shale resources outside the United States 9 In Focus: Shale developments in Argentina, China, Poland and South Africa 122 Water regulation 182.1 Regulatory history and the current landscape 192.2 Federal efforts to support regulatory consistency 212.3 Key trends 22 In Focus: Water regulation in Argentina, China, Poland and South Africa 233 Water management 263.1 Water use and production 27 Comparison: Managing produced water: unconventional vs. conventional 303.2 Water management options 31 Primer: Water treatment technologies 333.3 Key trends 34 In Focus: Water use/management in Argentina, China, Poland and South Africa 354 Water movements 424.1 Shale gas development life cycle: logistics requirements 434.2 Significance of water transportation 454.3 Rising to the water transportation challenge 454.4 Key trends 46 In Focus: Water movements in Argentina, China, Poland and South Africa 47 Concept Overview: Basin-wide water logistics management model 495 Lessons learned for new shale developments 52 In Focus: Implications for Argentina, China, Poland and South Africa 576 Implications for operators 60 Overview of the challenges in the shale gas lifecycle 63 2
  4. 4. 3
  5. 5. 1IntroductionNatural gas production in the United States has grown significantlyin recent years as improvements in horizontal drilling and hydraulicfracturing technologies have made it commercially viable to recovergas trapped in tight formations, such as shale and coal. The UnitedStates is now the number one natural gas producer in the worldand, together with Canada, accounts for more than 25 percent ofglobal natural gas production.1 Shale gas will play an ever-increasingrole in this resource base and is projected to increase to 49 percentof total US gas production by 2035, up from 23 percent in 2010,highlighting the significance of shale gas in the US energy mix inthe future. Lower and less volatile prices for natural gas in the pasttwo years reflect these new realities, with benefits for Americanconsumers and the nation’s competitive and strategic interests,including the revitalization of several domestic industries.2 4
  6. 6. In its “2012 Annual Energy Outlook,” theU.S. Energy Information Administration (74.7 trillion cubic feet), and Barnett (43.4 trillion cubic feet). Activity in Water regulation(EIA) referred to the “enormous new plays has increased shale gas This rapid expansion in shale gaspotential” of shale gas, and according production in the United States from production has given rise to concernsto the Institute for Energy Research, 11 billion cubic meters (bcm) in 2000 around the impact of operations inthe United States has enough natural to 140 bcm in 2010.4 Such production areas such as water, road, air quality,gas to meet domestic electricity potential has the ability to change the seismic and greenhouse gas emissionsdemand for 575 years at current fuel nature of the North American energy (GHG). The process of hydraulicdemand for generation levels—enough mix and according to the National fracturing (fracking) in a shale gas wellnatural gas to fuel homes heated Petroleum Council 2011 study, “Prudent requires significant volumes of waterby natural gas in the United States Development: Realizing the Potential and causes additional greenhouse gasfor 857 years and more natural gas of North America’s Abundant Natural emissions compared to conventionalthan Russia, Iran, Qatar, Saudi Arabia Gas and Oil Resources,” the natural gas wells. There is already significantand Turkmenistan combined.3 gas resource base could support supply resistance to shale gas development for five or more decades at current or due to these water and emissionAs Figure 1 illustrates, US shale gas greatly expanded levels of use.5 concerns in many parts of the Unitedreserves are vast and broadly dispersed; States and Western Europe, with Francethe EIA estimates that the lower 48 and Bulgaria imposing nationwidestates have a total of 482 trillion cubic moratoriums on shale gas productionfeet of technically recoverable shale through fracking. The regulation ofgas resources with the largest portions shale gas is an evolving landscapein the Northeast (63 percent), Gulf as the industry has developed soCoast (13 percent), and Southwest rapidly that it has often outpacedregions (10 percent), respectively. The the availability of information forlargest shale gas plays are the Marcellus regulators to develop specific guidance.(141 trillion cubic feet), HaynesvilleFigure 1. US lower 48 states shale gas plays. Niobrara* Montana Thrust Bakken*** Belt Heath** Cody Williston Basin Big Hom Powder River Gammon Hilliard Basin Basin Baxter Mowry Appalachian Mancos Michigan Basin Greater Green Basin Antrim Park Niobrara* River Basin Basin Forest Devonian (Ohio) City Basin Uinta Basin Illinois Marcellus Manning Basin Utica Canyon Piceance Denver San Joaquin Mancos Excello- New Basin Basin Basin Hermosa Mulky Cherokee Platform Albany Monterey- Paradox Basin Pierre Temblor Lewis Woodford San Juan Raton Anadarko Fayetteville Basin Basin Chattanooga Basin Ard Monterey mo Arkoma Basin Black Warrior Palo Duro Bend re Bas Basin Conasauga Santa Maria in Basin Valley & Ridge Ventura, Avalon- Floyd-Neal Province Los Angeles Bone Spring Permian Barnett TX-LA-MS Basins Basin Ft. Worth Salt Basin Barnett- Marfa Basin Tuscaloosa Woodford Basin Eagle Haynesville- Bossier Shale plays Basins Ford Pearsall Current plays * Mixed shale & Western Prospective plays chalk play Gulf ** Mixed shale & Stacked plays Iimestone play Shallowest/youngest *** Mixed shale & Intermediate depth/age tight dolostone- Deepest/oldest siltstone-sandstoneSource: Shale Gas and Oil Plays, Lower 48 States, U.S. Energy Information Administration, www.eia.gov.5
  7. 7. At present, the US shale gas industryis regulated by a patchwork of existing Water use and Regarding contamination incidents, the MIT report stated that “with overoil and gas regulations on drilling management 20,000 shale wells drilled in the last 10and well site activities, combined years, the environmental record of shale One of the most contentious and widelywith environmental regulations on gas development has for the most part publicized issues in shale gas productionwater and air management. This loose been a good one—but it is important is water management. Shale gasregulatory landscape is beginning to recognize the inherent risks and the production is a highly water-intensiveto change with growing state and damage that can be caused by just process, with a typical well requiringfederal attention. In 2010, the U.S. one poor operation…. In the studies around 5 million gallons of water to drillEnvironmental Protection Agency surveyed, no incidents are reported and fracture, depending on the basin(EPA) launched a four-year field study which conclusively demonstrate and geological formation.8 The vaston the impact of shale gas hydraulic contamination of shallow water zones majority of this water is used during thefracturing and, in 2011, the U.S. with fracture fluids.”9 fracturing process, with large volumesDepartment of Energy received a report of water pumped into the well with sand In areas with deep unconventionalby the Secretary of Energy Advisory and chemicals to facilitate the extraction formations, such as the MarcellusBoard (SEAB) for shale gas providing of the gas; the remainder is used in areas in Appalachia, the shale gasrecommendations on how to reduce the drilling stage, with water being the under development is separated fromthe environmental impact and improve major component of the drilling fluids. freshwater aquifers by thousands ofthe safety of shale gas production. In Relatively small amounts of water are feet and multiple confining layers. Toaddition to these reports, numerous also used for dust suppression on site, reach these deep formations where thesmaller studies continue to provide and for the cleaning and flushing of fracturing of rock occurs, drilling goesinformation to support improvements drilling equipment. Although increasing through the shallower areas, with thein regulation and leading practice. volumes of water are being recycled and drilling equipment and production pipeIn 2010, New York issued a temporary reused, freshwater is still required in high sealed off using casing and cementingmoratorium on additional shale gas quantities for the drilling operations as techniques. A new voluntary chemicaldevelopment to allow the state’s brackish water is more likely to damage registry (FracFocus) for disclosingDepartment of Environmental the equipment and result in formation fracturing fluid additives was launchedConservation (DEC) to finish its damage that reduces the chance of a in the spring of 2011 by the GroundSupplemental Generic Environmental successful well. The need for freshwater Water Protection Council (GWPC) andImpact Statement (SGEIS) on issues is a growing issue, especially in water- the Interstate Oil and Gas Compactsurrounding natural gas drilling. scarce regions and in areas with high Commission (IOGCC). Texas operatorsNew York published a Revised Draft cumulative demand for water, leading are required by law to use FracFocus.SGEIS on September 28, 2011, which to pressure on sources and competition The IOGCC, comprised of 30 memberwas open for public comment until for water withdrawal permits. The states in the United States, reportedJanuary 2012.6 There has been no pressure to increase efficiencies is high in 2009 that there have been no casesfurther movement from the DEC on the as industry demand for water grows with where hydraulic fracturing has beenmoratorium. In June 2011, Maryland the development of more wells. verified to have contaminated water.Governor Martin O’Malley issued an A key objective of the EPA’s ongoing Water contamination is anotherorder calling for a three-year study of study is to better understand the aspect of shale gas production thatthe economic and environmental effects full life-cycle relationship between has generated significant resistanceof drilling the Marcellus Shale before hydraulic fracturing and drinking to current shale production processes.permits to drill can be issued. And in water and groundwater resources.10 According to the MassachusettsAugust 2011, New Jersey Governor Institute of Technology (MIT) 2011 Gas The movement and disposal of producedChris Christie placed a one-year report, which reviewed three studies water from fractured wells is also amoratorium on hydraulic fracturing so of publicly reported incidents related part of the debate on the environmentalthat the Department of Environmental to gas well drilling, there were only 43 impact of shale gas production.Protection “can further evaluate the “widely reported” water contamination After fracturing, each well returns apotential environmental impacts of incidents related to gas well drilling percentage of the injected fracturethis practice in New Jersey, as well in the past decade (to 2010) during fluid volume over its lifetime; this wateras evaluate the findings of ongoing which time, there were about 20,000 is heavily polluted, creating a risk offederal studies.”7 (Note, however, that shale gas wells drilled with almost all groundwater contamination upon itsno hydraulic fracturing operations were of them being hydraulically fractured. return to the surface if not correctlytaking place in New Jersey when the Of these, 48 percent of the incidents contained and treated. Concerns aroundmoratorium was issued.) Several other involved groundwater contamination such risks have led to the moratoriumstates, however—including Wyoming, by natural gas or drilling fluids; 33 on shale gas development in NewPennsylvania, Arkansas, Colorado, percent involved on-site surface spills; York’s Marcellus Shale. In addition toLouisiana and Texas—have passed new 10 percent involved water withdrawal the nature of the produced water, thelegislation or regulations in response and air quality issues, and blowouts; and, growing volumes of wastewater areto the increased activity associated the remaining 9 percent involved off-site increasing demand for efficiencieswith natural gas development. disposal issues (see Figure 2). in water treatment technologies to improve water reuse and 6
  8. 8. recycling. Innovative water management can represent up to 80 percent of Operational performancesolutions are required to address the logistics activity. Research into water- Better monitoring and planninglong-term sustainability of water use in free fracking, on-site treatment and capabilities will reduce bottlenecksshale gas production. disposal and assessment of alternative and smooth delivery into a site (e.g., modes of transport are all being managed slot windows, dynamicWater movements pursued, but are currently unable to generate significant impact. Within the re-routing to avoid congestion). Availability of accurate operational dataThe volume of equipment, materials boundaries of current capabilities, the can allow operators to identify issuesand water required to support shale adoption and integration of logistics and enable continuous improvementgas operations presents a significant leading practice provide the most in both drilling and transportation.logistics challenge. Given the remote straightforward, technology-ready Logistics costs can be reduced throughnature of most locations and the approach to reducing transport cost efficiency gains (e.g., reduction offrequent operations movements across and regulatory and HSSE exposure. waiting time) and automated processeshighly dispersed and numerous well site can reduce administrative costs. Pastlocations, flexibility is required in the Improvements in water movements implementations have shown thattransport model making road transport also have an impact on other aspects consistent adoption of logistics leadingthe logistics model of choice for most of shale operations, specifically HSSE practices can deliver up to 45 percentenvironments. While pipeline and rail exposure, operational performance reduction in transport costs.movements can be effective for long- and compliance.distance or point-to-point movements, Compliancethe final distribution to and from the HSSE exposure The use of a water inventory monitoringwell pad is almost exclusively managed Improved transport planning processes tool can support water managementvia road transport. Road transport and systems can reduce the number regulatory compliance through visibilityvolumes and types vary significantly of truck moves, while telematics of water draw, usage and movements.depending on the operational phase of systems can provide real-time visibility Automated end-to-end processes andthe project, with the majority of demand of truck movements and driver systems enable accurate and rapidduring the fracking and completion performance, supporting reduction data capture, storage and reporting.phases, which can account for 60–85 in wait times, less congestion and A cross-operator, basin-wide solutionpercent of total transport volumes. better driver HSSE compliance. would also confirm consistent basin-Some large operations are required to wide reporting standards acrosssource, plan and manage up to 300 multiple sites and operators.truck movements per day within asingle basin, which is the equivalent ofa pan-regional transport operation inmany other sectors. This concentrationcreates significant challenges, withon-site congestion causing issues to the Figure 2. Chart of water contamination incidents related to gas well drilling.operations teams and local residents,and leading to significant cost exposureto an already marginal cost operation. 9%The high volume and intensity ofroad transport associated with shale 10%gas production present some uniquechallenges for operators. A shortageof transport operators with sufficient 48%knowledge, difficulties in tracking andoptimizing delivery schedules, reducing Groundwater contamination 33%burden on strained road infrastructure, On-site surface spillsand a lack of standardized reporting Water withdrawal and air quality issues,and regulatory data can all lead to and blowoutshigh costs, Health Safety Security Off-site disposal issuesEnvironment (HSSE) exposure, andregulatory compliance issues. Withup to 30 percent of completion costs Source: Massachusetts Institute of Technology 2011 Gas Report.related to transportation, operatorsare exploring different options toreduce transport activity, with akey focus on water hauling, which7
  9. 9. Overview of shale gas life cycle activitiesCivil/site prep Completion/frackingForest clearing, excavation, building As drilling is completed, multipleof access routes, constructing and layers of metal casing and cement areinstalling wells pads and preparing placed around the wellbore. After thesite for drilling activities. well is completed, a fluid composed of water, sand and chemicals is injectedDrilling under high pressure to crack the shale, increasing the permeability of the rockNatural gas will not readily flow to and easing the flow of natural gas.vertical wells because of the lowpermeability of shales. This can beovercome by drilling horizontal wells Flowbackwhere the drill bit is steered from A portion of the fracturing fluid willits downward trajectory to follow a return through the well to the surfacehorizontal trajectory for one to two due to the subsurface pressures. Thekilometers, thereby exposing the volume of fluid will steadily reduce andwellbore to as much of the reservoir be replaced by natural gas production.as possible. Production The fissures created in the fracking process are held open by the sand particles so that natural gas from within the shale can flow up through the well. Once released through the well, the natural gas is captured, stored and transported away for processing.Figure 3. Shale gas lifecycle. Civil/site prep Drilling Completion/ Flowback Production Build access Drill vertical and fracking Capture, store Capture, store roads, construct horizontal wells Complete wells and treat and transport gas and install well with steel and returned fracking pads, prepare site cement casings fluids for drilling Release gas through hydro-fracking DecommissionTypical 60 days 15-60 days 15-30 days 20 days 5–40 yearstimelinesSource: Accenture 2012. 8
  10. 10. 1.1 cubic feet for the United States and detailed shale gas resource assessments the other 32 countries assessed. To by the countries themselves, with many put this shale gas resource estimate of these assessments being assisted by in context, the world’s technically a number of US federal agencies underShale resources recoverable gas resources are roughly 16,000 trillion cubic feet, largely the auspices of the Global Shale Gas Initiative (GSGI) that was launched inoutside the excluding shale gas.11 Thus, adding the identified shale gas resources to April 2010.United States other gas resources increases total world technically recoverable gas At a country level, there are two country groupings that emerge where shale gasAlthough estimates are likely to change resources by more than 40 percent development appears most attractive.over time as additional information to 22,600 trillion cubic feet.12 The first group consists of countriesbecomes available, the international that are currently highly dependentshale gas resource base is currently The estimates of technically recoverable upon natural gas imports, have at leastconsidered to be significant. The initial shale gas resources for the 32 countries some gas production infrastructure, andestimate of technically recoverable outside the United States represent their estimated shale gas resources areshale gas resources in the 32 countries a moderately conservative “risked” substantial relative to their current gasexamined in the EIA’s “World Shale resource for the basins reviewed. Given consumption. For these countries, shaleGas Resources” study is 5,760 trillion the relatively sparse data currently gas development could significantlycubic feet (see Figure 4). Adding the US available and the differences in alter their future gas balance, whichestimate of the shale gas technically approaches employed to determine the may motivate development. Examplesrecoverable resources of 862 trillion resources, these estimates are quite of countries in this group includecubic feet results in a total shale uncertain. At the current time, there Chile, France, Morocco, Poland, Southresource base estimate of 6,622 trillion are efforts under way to develop more Africa, Turkey and Ukraine. In addition,Figure 4. Map of 48 major shale gas basins in 32 countries. Legend Assessed Basins with Resource Estimate Assessed Basins without Resource Estimate Countries within Scope of EIA Report Countries outside Scope of EIA ReportSource: “World Shale Gas Resources: An Initial Assessment of 14 Regions Outside the United States,”U.S. Energy Information Administration, 2011, www.cia.gov.9
  11. 11. South Africa’s shale gas resourceendowment is interesting as it may Argentina’s biggest energy company, YPF, has found unconventional shale oil China – Sichuan andbe attractive to use this natural gas and natural gas in Mendoza province, Tarim Basinas a feedstock to its existing gas-to- confirming the extension of the massive In 2011, the EIA estimated thatliquids (GTL), coal-to-liquids (CTL) Vaca Muerta area. YPF said exploration China had 1,275 trillion cubic feetplants and combined cycle gas turbine at the Payun Oeste and Valle del Rio of technically recoverable shale(CCGT) currently running on diesel. Grande blocks pointed to an estimated gas. Since then a geological survey one billion barrels of oil equivalentThe second group consists of those led by China Ministry of Land and (boe) in unconventional oil and gas incountries where the shale gas resource Resources (MLR) confirmed a total of Mendoza. Energy resources and reservesestimate is large (e.g., above 200 trillion 882 trillion cubic feet of technically in the province, which border the Andescubic feet) and there already exists recoverable shale gas, excluding Tibet. mountain range in western Argentina,a significant natural gas production The Sichuan Basin, located in south- currently stand at 685 million boe.infrastructure for internal use or for central China, covers a large 211,000export. In addition to the United States, km2 and accounts for 40 percent ofnotable examples of this group include Canada – Horn River the country’s shale resources.13Algeria, Argentina, Australia, Brazil, Shale Basin China hopes to produce between 60Canada, China, Libya and Mexico. British Columbia’s Horn River Shale billion and 100 billion cubic meters aExisting infrastructure would aid in Formation is the largest shale gas year by 2020—an objective that somethe timely conversion of the resource field in Canada and part of Canadian analysts are skeptical can be achieved.into production, but could also lead deposits that amount to as much Royal Dutch Shell has recently signedto competition with other natural gas as 250 trillion cubic feet of natural the first production-sharing contract tosupply sources. For an individual country gas. Since 2008, a total of nine explore, develop and produce shale gasthe situation could be more complex. companies has ventured into the Horn in China, a move that fits in with China’sOutside the United States there River market, including ExxonMobil, overall strategy to bring technicalare certain shale plays that could Apache, Devon Energy and Encana. and operational know-how to thechange the energy security of the development of its untapped reservescountries in which they are located. While large-scale commercial of the unconventional fuel. CNOOCThese include the following: production of shale gas has not yet been Ltd., China’s biggest offshore energy achieved in Canada, many companies producer, plans to develop new fields, are now exploring for and developing acquire overseas assets and developArgentina – The Neuquén shale gas resources in Alberta, British unconventional resources such as shaleBasin Columbia, Quebec and New Brunswick. Development of shale gas, and other gas to meet output targets. The country is “determined” to learn shale-gasAccording to the EIA, Argentina has unconventional resources, will help technology from its partners and deploy774 trillion cubic feet of technically confirm supplies of natural gas it in China, holder of the world’s largestrecoverable shale gas, making it the are available to the growing North deposits of the fuel, Chairman Wangworld’s third‐largest player in the shale American natural gas market for many Yilin has stated.14game behind the United States and decades. Encana, Canada’s largestChina. Located on Argentina’s borderwith Chile, the 137,000 km² Neuquén natural gas producer and one of the biggest in North America, is looking Poland – Baltic-Podlasie-Basin is the South American nation’s for a single partner for a package of Lublin Basinslargest source of hydrocarbons, holding assets that could include positions in35 percent of the country’s oil reserves The EIA has assessed that Eastern the Collingwood Shale, the Tuscaloosaand 47 percent of its gas reserves. Europe may hold as much as 250 trillion Marine Shale, the Mississippi LimeWithin the basin, the Vaca Muerta Shale cubic feet of shale gas, with Poland’s and the Eaglebine Shale in the Unitedformation may hold as much as 240 Silurian Shale plays boasting 187 trillion States. All have natural gas liquids or oiltrillion cubic feet of exploitable gas. cubic feet of that total. The Russia potential and are in the early stages ofExxonMobil has recently entered into Federation currently supplies 25 percent exploration and development.an agreement with Americas Petrogas of Europe’s natural gas, and Poland’sfor the Exploration and Production potential shale resources could reduce(E&P) farm‐out of 163,500 gross acres Europe’s dependence on natural gasof its Neuquén-based Los Toldos blocks. imports. Whether these reserves willThis area is also being explored and be developed is still to be seen, but thedeveloped by Shell, Apache, EOG, Total 38-million-strong Slavic nation will haveand Wintershall, among others. a strong claim to energy independence as its projected reserves equate to 300 years of domestic consumption. 10
  12. 12. Several companies including ExxonMobiland Chevron have begun to drill test Other regionswells and more than 100 companies India’s Oil and Natural Gas Corp (ONGC)rushed to grab a share of Poland’s gas and US oil company ConocoPhillips haveconcessions. Some of those early tests signed an agreement to explore andproduced decent flows, but others develop shale gas assets and look forshowed quite different results from opportunities in deepwater exploration.wells drilled into US shale deposits. The agreement is for sharing technicalExxonMobil said its two test wells did knowledge on shale gas explorations,not justify commercial production. but ONGC and ConocoPhillips couldExxonMobil said in January 2012 that also jointly bid for shale gas assetstwo exploratory wells failed to flow overseas. India may still launch the firstenough gas to make development shale gas licensing round by the endprofitable. In June 2012, ExxonMobil of 2013 even though the governmentannounced it would end its search for pushed back plans to unveil a policyshale gas in Poland.15 Flow rates at on exploration of unconventionalsites drilled by 3Legs Resources Plc. and gas resources trapped in rocks.BNK Petroleum Inc. were not as high assimilar wells in the United States.South Africa – The KarooSupergroupKnown by paleontologists as one of theworld’s most fertile hunting grounds forfossil remains, the Karoo Supergroup(KSG) might also be one of the mostplentiful sources of shale gas in theworld. The KSG is constituted mainly ofshales and sandstones and spans across88,000 km², underlying more thantwo-thirds of the entire area of SouthAfrica and containing an estimated485 trillion cubic feet of technicallyrecoverable gas. Shale gas could reducethe country’s dependence on coal tofuel 85 percent of its energy needs.11
  13. 13. In FocusShale developments in Argentina, China, Poland andSouth AfricaA key objective of this report is tohighlight the trends and lessons learned Argentina in 2011 due to decreasing exploration activities in the past decade.17from shale development in the United Argentina is the largest natural gas Meanwhile, the demand for natural gasStates that can be applied to shale producer in South America with 1,416 in Argentina has increased in recentdevelopments in other geographies. To billion cubic feet (bcf) annual output in years in line with economic growth,emphasize this point, we will present 2010.16 Natural gas prices in Argentina and the country has had to rely on gasfour case studies in this report of four were kept low by the government imports from neighboring Bolivia andvery different shale developments: since the economic crisis in 2002. Liquefied Natural Gas (LNG) shipments.Argentina, China, Poland and South As a result natural gas production Shale gas has brought new hope forAfrica. The following is a detailed dropped almost 15 percent from its addressing energy demands. Baseddescription of these shale developments. peak of 1,628 bcf and natural gas on an EIA estimation, Argentina has tested reserves dropped 50 percent 774 trillion cubic feet of technically to only 13.4 trillion cubic feet recoverable shale gas, which is almost 60 times that of its current tested natural gas reserves.18 To encourageFigure 5. Neuquén Basin Shale Gas Prospective Area and Basemap. domestic natural gas exploration and production, the Argentinian government introduced its “Gas Legend Plus” program in 2008 to allow new Neuquén Basin discovered unconventional gas to be Thrust Fault sold at a higher price based on cost City Water and reasonable profit.19 This incentive program allows approved companies to Cu charge up to $5/thousand cubic feet yo (mcf) for their natural gas production. Ba sin The Neuquén Basin covers the Neuquén province and parts of Mendoza, Rio Negro and La Pampa provinces in central-west of Argentina, holding 407 lt trillion cubic feet of the country’s 774 Agrid Fold & Thrust Be trillion cubic feet estimated resources. Andes Mountains This basin largely overlaps with existing natural gas production regions. The Neuquén province alone currently produces almost half of the nation’s conventional gas.20 The geological formation of the Neuquén Basin is very Productive Area similar to major US shales with the Extensional Structures average depth of the 204 trillion cubic feet of recoverable shale gas in the Vaca Muerta formation within the Neuquén Basin at 2,400 meters. Geological features and existing local natural gas Colorado Basin Neuquén Huincul Arch / n infrastructure make future development Dorsal de Neuque in the Neuquén Basin very promising. h Nort onian Other basins including the San Jorge g Basin and the Austral Magallanes Basin Pata f have 95 trillion cubic feet and 172 i Mass trillion cubic feet reserves, respectively.Source: “World Shale Gas Resources: An Initial Assessment of 14 Regions Outside the United States,”U.S. Energy Information Administration, 2011, www.eia.gov. 12
  14. 14. Many shale operators have startedexploration activities in Argentina. China Data from a recent Ministry of Land and Resources (MLR)-led geological surveyApache partnered with YPF, previously The recent success of shale gas shows China has 882 trillion cubiccontrolled by Repsol, but was development in the United States, as feet of technically recoverable shalerenationalized in April 2012 by the well as a domestic push to reshape the gas resources, a lower figure than theArgentinian government, to explore energy structure to reduce dependence EIA’s estimate. Figure 6 illustrates shaleunconventional resources including on coal, has put shale gas under the gas distribution in China. The Sichuanshale gas in the Neuquén and Austral spotlight in China. In December 2011, Basin in the Upper Yangzi region andBasins. Apache has been awarded the China State Council approved shale southwest China (a region covering1.6 million gross acres (3,642 km2) gas as a new type of natural resource Sichuan, Chongqing, Yunnan, Guizhouin the Neuquén Basin for shale gas that will be managed separately from and Guangxi provinces) has 10 trilliondevelopment and the company drilled conventional gas.23 In March 2012, cubic meters (350 trillion cubic feet) ofthe first horizontal multi-fracture shale the National Development and Reform shale gas, which equates to 40 percentgas well in South America in 2011.21 In Commission (NDRC) issued its Shale Gas of total national reserves. Unlike USMay 2011, one of Apache’s horizontal Development Plan (2011–2015)24 that formations, where most shale seamswells in the Neuquén Basin tested at sets clear targets for the industry by are at depths of less than 3,000 metersa rate of 7 million cubic feet (mmcf)/ 2015 and 2020. However, the shale gas (with the exception of the Haynesvilleday. Canadian firm America Petrogas industry in China remains at an early Shale), the shale-bearing layers in manyjoined with ExxonMobil to explore 660 stage with most activity in exploration Chinese formations are between 3,000km2 of blocks in the Neuquén Basin. and drilling of test wells. to 5,000 meters deep. Therefore, USThe company drilled a test well together shale gas development models cannotwith ExxonMobil and the result is be simply replicated in China and theunder evaluation.22 With undergoing complex geological conditions willexploration activities, EIA’s original increase the cost of drilling wells.estimation on Argentina’s shale gaspotential is waiting to be confirmedwith new data from the operators.Figure 6. Shale gas distribution in China. Northwest zone 15% North and Northeast zone 26% Upper Yangzi & Southwest zone Lower Yangzi & 40% Southeast zone Sichuan Chongqing 19% Guizhou Yunnan GuangxiSource: China Ministry of Land and Resources, People’s Republic of China, www.mlr.gov.cn.13
  15. 15. The shale gas industry has, for the China CBM has proposed to start The average depth of shale formationsfirst time, been put in a strategically exploring three regions in Shanxi in Poland is from 2,500 to 3,800 meters,important position in the government’s province.26 In the first round of national which is up to twice as deep as the12th five-year energy plan (2011–2015). shale gas exploration rights auctions, average depth of 2,000 meters observedIn addition, the Shale Gas Development organized by the MLR, Sinopec and in the Marcellus Shale.29 30 VariationsPlan (2011–2015) states that by 2015, Henan Coal Bed Methane Co won the have been observed among differentthe government aims to complete an bid. A second round of auctions is due basins, with 1,000–4,500 meters depthinvestigation on shale gas reserves and to start in late 2012. for the Baltic Basin, 1,000–3,500 meterstheir national distribution. The plan also depth for the Lublin Basin, and 4,000–estimates annual production reaching International oil majors are actively 5,000 meters depth for the Podlasie6.5 billion cubic meters (230 billion partnering with NOCs to enter China’s Basin (near Warsaw). These geologicalcubic feet) and confirmed technically shale gas market. CNPC and Statoil characteristics could likely result inrecoverable reserves reaching 600 began test drilling in China in early higher drilling costs, linked to higherbillion cubic meters (21 trillion 2011. Sinopec has teamed with BP to demands on water in the drilling stages.cubic feet) by 2015. With almost no explore shale gas in Guizhou in 2010,commercial production today, reaching joined forces with ExxonMobil to Shale gas activities in Poland startedsuch targets will require significant conduct geological research in Sichuan, in 2007; by September 2011, a total ofinvestment at each stage of the value and is also working with Chevron in 101 shale gas exploration authorizationschain in the next couple of years, as Guizhou to carry out risk assessments. had been granted and another 26well as technology development and Shell is the most active international oil applications were being processed.31collaboration between national oil company (IOC) in China, and has already International oil majors have enteredcompanies (NOCs) and experienced shale signed the first production-sharing the Polish market in the form of jointgas operators from other countries. contract with CNPC to explore, develop ventures. 3Legs Resources formed and produce shale gas. a joint venture with ConocoPhillipsNOCs and state-owned entities have to evaluate shale gas potential inbeen the first to be allowed to exploreand develop shale gas resources in Poland the Baltic Basin and drilled the first exploration well in Poland. PKN andChina. So far most activities are in Poland has the most significant shale PGNiG are the most active Polishexploration, with only very limited gas potential in Europe. Poland’s operators. As of August 2011, basedcommercial production. The three major shale gas resources are located in on square kilometers covered, the topNOCs (CNPC, Sinopec and CNOOC), the Baltic-Podlasie-Lublin Basins (see 10 concession holders in Poland were:Yangchang Petroleum Group, and China Figure 7), creating a strip across the (1) San Leon Energy with 14 licensesUnited Coalbed Methane Co (China country from northwest to southeast. covering 11,520 km2, (2) ExxonMobil, (3)CBM) are actively involved in shale gas The EIA estimates 187 trillion cubic PKN Orlen, (4) Chevron, (5) Marathonexploration. By the end of 2011, CNPC feet of technically recoverable shale Oil & Gas, (6) BNK Petroleum, (7)had drilled 11 test wells in southern gas resources in the Baltic-Lublin- 3Legs Resources, (8) Nexen, (9)Sichuan and northern Yunnan, four of Podlasie Basins of Poland; of those, ConocoPhillips and (10) Petrolivest.32which had exhibited industrial-level 120 trillion cubic feet are in thegas flow. Sinopec has its exploration Baltic Basin.27 A report released inactivities mainly in Guizhou, Anhui March 2012 by the Polish GeologicalSichuan and Chongqing. In Chongqing, Institute was able to confirm 67 trillionSinopec has shale gas production in cubic feet of technical recoverableLiangping County with an estimated shale gas resources in these threeannual output 300–500 million cubic basins after a 16-month researchmeters (10–18 billion cubic feet).25 project with external support fromYanchang Group is very active in its the U.S. Geological Survey.28 traditional territory of Shannxi provinceand has successfully fracked the firsthorizontal well in China. 14
  16. 16. With authorizations received, current transforming the coal-based electricityindustry activities have moved onto generation sector. A consortium formeddrilling of testing wells. 22 exploration with state-owned power utilitieswells were started in 2011 and 13 wells companies and PGNiG will co-financewere completed by February 2012. 14 and co-develop shale exploration alongnew exploration wells were planned the Baltic coast. Utilities will financefor late 2012 and as many as 123 wells exploration activities in exchangeare planned by 2017.33 So far, state- for future gas supplies in off-takeowned PGNiG, 3Legs Resources, BNK, agreements.35 Poland’s Treasury MinisterTalisman Energy, Marathon Oil and said the country may be producing oneExxonMobil have all completed their billion cubic meters (35 billion cubicfirst batch test wells. ExxonMobil, BNK feet) of shale gas per year by 2014.36and 3Legs released rather disappointingresults, stating that the gas flows intheir testing wells are lower than similarprospects in US shale and commercialproduction cannot be justified.34Despite this negative news, the Polishgovernment strongly believes shalegas would help to reduce the nation’senergy dependency on Russia and cutgreenhouse gas (GHG) emissions throughFigure 7. Map of Poland’s shale gas basin. Kaliningrad Gdansk Baltic Basin Szczecin Mazury - Belarus High Bydgoszcz Bialystok Berlin Poznan Warsaw Podlasie Basin Brest Lodz Lublin Legend Czestochowa Lublin Basin Trans-European Fault Zone Faults National Capitals Katowice Major Cities Krakow Ostrava Poland Shale Basins Prospectivity Non-Prospective ProspectiveSource: World Shale Gas Resources: An Initial Assessment of 14 Regions Outside the United States, U.S.Energy Information Administration, 2011, www.eia.gov.15
  17. 17. South Africa Shale.40 However, the Karoo Basin contains significant areas of volcanic South African regulations, TCPs allow no more than desktop research; withSouth African electricity generation intrusions that impact the quality further applications required to obtainis currently heavily coal-based. The of the shale gas resources, limit the authorization for physical explorationDepartment of Energy intends to use of seismic imaging and increase activities. However, the applicationhave 9 percent of energy from open the risk of shale gas exploration. to convert these TCPs into physicalcycle gas turbines by 2030 and shale exploration licenses was suspendedgas could help to reach this target.37 A number of companies have started over a year to allow the government toAccording to the EIA, South Africa has pursuing shale gas development in the conduct policy and technical reviewsan estimated 485 trillion cubic feet Karoo Basin by obtaining Technical before final decisions.42 On Septemberof technically recoverable shale gas Cooperation Permits (TCPs) from the 7, 2012, the South Africa governmentlocated in the Karoo Basin (see map, South Africa Petroleum Agency (see accepted the recommendations fromFigure 8). Of this, 298 trillion cubic map, Figure 8). Shell is the biggest the Department of Mineral Resourcesfeet is believed to be in the Whitehill TCP holder with 185,000 square (DMR) and finally lifted the moratoriumShale.38 The real volume of shale gas kilometers of land in the Karoo Basin. on shale gas exploration.43reserves is still waiting to be confirmed Falcon Oil and Gas has 30,000 squarethrough physical exploration activities. kilometers of TCPs. Sasol, Chesapeake and Statoil have formed a joint ventureUnlike Poland and China, where shale and together hold 88,000 squaregas formation are buried deeper kilometers of TCPs, but in Decemberthan the United States, the average 2011, Sasol decided to put its Karoodepth of shale gas in South Africa shale gas plan on hold.41 Anglo Coalis 2,500 meters (8,000 feet),39 and Australian Sunset Energy alsowhich is quite similar to the Barnett have their own TCPs. According toFigure 8. Map of operators’ TCP coverage in the Karoo Basin. Botswana Pretoria Mbabane Johannesburg Swaziland Namibia South Africa Maseru Sasol/Statoil/ Lesotho Chesapeake Durban Anglo Coal Shell Ecca Group Sunset Karoo Basin Energy Falcon Oil and Gas Operator Anglo Coal East London Falcon Oil and Gas Port Elizabeth Sasol/Statoil/Chesapeake Cape Town Shell Sunset Energy CitySource: “World Shale Gas Resources: An Initial Assessment of 14 Regions Outside the United States,” U.S. Energy Information Administration, 2011,www.eia.gov. 16
  18. 18. 17
  19. 19. 2Water regulationThe topic of shale gas regulation is dominated by hydraulicfracturing, the key feature of shale gas that separates itfrom well-regulated conventional gas production. However,existing regulations to protect water resources during oil andgas development are also affected by the greater intensity ofwater, energy and infrastructure used in shale gas operations.This consequence is driving significant uncertainty in the USregulatory landscape, which is still adapting to the new industry.The speed of industry growth has outpaced the availability ofrigorous data on its potential impact, which has hindered theability of government to adequately assess and regulate operations.This situation has led to a patchwork regulatory landscape andto a moratorium on shale gas development in New York State,France and Bulgaria. To resolve this issue, there has been renewedfocus by the US federal government on establishing betterunderstanding of the potential impacts of shale gas development,to most effectively regulate this critical new energy resource. 18
  20. 20. 2.1 State regulations The current regulatory landscape is comprised of an overlapping collection of federal, state and local Regulation of oil and gas production regulations and permitting systems, has traditionally occurred primarily atRegulatory history implemented by oil and gas, natural resources and environmental agencies. the state level. This level of regulation is also the case for shale gas, withand the current A mapping of current federal and state regulation is shown in Figure 9. These most shale gas-producing states issuing more rigorous standards thatlandscape regulations cover different aspects of the development and production of a take primacy over federal regulations, as well as additional regulationsHydraulic fracturing of gas wells shale gas well, with the intention that that control areas not covered atbegan in 1949; however, it remained they combine to manage any potential the federal level, such as hydrauliclargely unregulated until significant impact on the surrounding environment fracturing. Within states, regulationunconventional gas production began and water supplies. These combinations is carried out by a range of agencies.around the millennium with the of regulations have long served to Energy or natural resource-focusedcommercial development of coal- regulate oil and gas development in departments generally set requirementsbed methane. As production grew, numerous states; however, the new for site permits, drilling, completionmedia reports and public complaints process of hydraulic fracturing is and extraction, while environmentalof drinking water contamination something that has not previously or water departments regulate water,raised concerns, leading the EPA to been managed by these regulations. emissions and waste management.commission a study into the risks of Therefore, the related intensity inhydraulic fracturing to drinking water. terms of water, emissions and site The specific regulations varyIn 2004, this study found that hydraulic activity mean existing regulations are considerably among states, such asfracturing of coal-bed methane being reassessed for their suitability different depths for well casing, levelsposed minimal threat to underground for this new production method. of disclosure on drilling and fracturingsources of drinking water, which was fluids, or requirements for watera significant finding in support of the storage. The majority of states in shaleindustry. In 2005, following the EPA Federal regulations gas-producing regions now have varyingreport, the federal Energy Policy Act With its exemption from the SDWA, hydraulic fracturing regulations ongranted hydraulic fracturing a specific hydraulic fracturing is not directly their books, specifically for disclosureexemption from the Safe Drinking regulated by federal standards. However, of fracking fluids, proper casing ofWater Act (SDWA), which regulates all a number of federal laws still direct wells to prevent aquifer contaminationunderground injection. oil and gas development, including and management of wastewater from shale gas.44 These regulations affect flowback and produced water. DisposalSince the Energy Policy Act passed in water management and disposal, as of wastewater by underground injection2005, shale gas production in the United well as air quality and activities on has emerged as a point of concern forStates has grown significantly, from less federal land. The Clean Water Act state regulators due to large inter-statethan one trillion cubic feet in 2005 to is focused on surface waters and flows of wastewater to states withover three trillion cubic feet in 2009. regulates disposal of wastewater and suitable geology for Class II disposalSuch rapid growth, along with continued also includes authorizing the National wells and reports of earthquakes nearreports of environmental effects, has Pollutant Discharge Elimination some well sites. States such as Arkansasled to renewed calls for change in the System (NPDES) permit program, as and Ohio have placed local moratoriumsregulatory landscape, particularly for well as requiring tracking of any toxic on disposal wells in locations wherethe federal government to provide chemicals used in fracturing fluids. increased seismic activity has beenincreased regulation or guidance. This recorded and Ohio is developing rigorouspressure led to the introduction to Outside water use, the Hazardous new standards for disposal wells.45congress of the FRAC Act in 2009, Materials Transport Act and Oil Pollutionwhich sought to repeal the 2005 SDWA Act both regulate ground pollutionexemption and require disclosure of risks relating to spills of materials orcomponents used in all fracturing fluids. hydrocarbons into the water table.The bill was sent to committee butwas not passed to congress for vote. Inthe absence of new federal regulation,states have continued to use existing oiland gas and environmental regulationsto manage shale gas development, aswell as introducing individual stateregulations for hydraulic fracturing.19
  21. 21. Figure 9. Federal and state regulation mapped to the shale gas lifecycle. Civil/site prep Drilling Completion/ Flowback Production Build access roads, Drill vertical and fracking Capture, store and Capture, store and construct and install horizontal wells Complete wells with treat returned transport gas well pads, prepare site steel and cement fracking fluids for drilling casings Release gas through hydro-frackingTypicaltimelines 60 days 15-60 days 15-30 days 20 days • The National Environmental Policy Act (NEPA) • The U.S. Department • The Clean Water Act (CWA) regulates surface requires that exploration and production on of Interior Bureau discharge of produced water and storm water federal lands be thoroughly analyzed for of Land Management through the National Pollutant Discharge environmental impacts. (BLM) is responsible Elimination System (NPDES) permitting for issuing fracking process. • Under the Clean Air Act, National permits on federal emission standards for hazardous air pollutants lands. • The CWA sets wastewater standards for (NESHAP) are used to limit toxic pollutants. industry, and water quality standards for Federal regulatory impact • Hazardous chemicals contaminates in the surface water. • Under the Clean Air Act, Engine NESHAP rules must be recorded on regulate newly refurbished engines including material safety data • The Oil Pollution Act (OPA) enforces spill monitoring and reporting requirements. sheets and reported prevention requirements and reporting in the event of a operations. • The US Environmental Protection Agency (EPA) has proposed new performance standards for crisis as part of the • The EPA has proposed that drillers use “green toxic air emissions for oil and natural gas Emergency Planning completion” techniques to reduce emissions of production. and Community volatile organic compounds from wells. Right to Know Act. Green completions are required in Colorado • The US EPA administers most of the federal laws. and Wyoming. • Hazardous Materials Transportation Act • Comprehensive Environmental Response, regulates the Compensation and Liability Act (CERLA) transport of enables the federal government to respond to hazardous materials. releases of hazardous substances that threaten human health or the environment. • States are able to implement federal regulations. • Transportation of • The Safe Drinking Water Act (SDWA) excludes water, sand and fracking from its Underground Injection Control • All states require a permit to drill and operate additives are (UIC) program. Instead, the EPA and states a well. regulated under implement the UIC program to protect • All states have regulations regarding drilling, state regulations. groundwater resources. Forty states have primacy abandonment and plugging of wells. for this with the EPA implementing the • Disclosure of program directly in New York and Pennsylvania. • States regulate the effective casing and chemicals used in fracking is regulated • Groundwater is often protected under State State regulatory impact cementing of wells. at a state level, but Pollutant Discharge Elimination System regulations differ in (SPDES) permits rather than just discharges strength. Wyoming, to surface water, as with the NPDES permits. Texas and Arkansas require disclosure of • In addition to state regulations, the Delaware all chemicals, River Basin Commission and Susquehanna Pennsylvania and River Basin Commission impose water quantity Michigan only laws. require disclosure • States regulate hazardous wastes and deemed hazardous, implement waste management procedures that Louisiana and are exempt from the federal Resource Colorado are Conservation and Recovery Act. expected to implement disclosure regulations soon. 20

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