A report from the U.S. EPA Inspector General's office saying even though the EPA's own 4-year study proves fracking doesn't affect water supplies, the EPA should try to keep its hand in regulating water used in the fracking business.
The document provides a summary and analysis of NERC's Initial Reliability Review of the EPA's proposed Clean Power Plan. The analysis finds that while NERC raises some valid concerns about assumptions in EPA's analysis, reliability is unlikely to be materially affected by the CPP. Compliance can be achieved through a combination of coal plant modifications, gas switching, renewable energy expansion, and energy efficiency, utilizing existing reliability tools. The transformation of the power system is ongoing and system operators have sufficient flexibility and options to ensure reliability with the CPP.
EPA's Final Rule Forcing O&G Drillers to Capture Tiny Amounts of Fugitive Met...Marcellus Drilling News
An onerous and expensive set of rules from a rogue, out-of-control federal bureaucracy--the Environmental Protection Agency--forcing shale drillers to spend huge amounts of money to capture tiny amounts of leaking methane. All in the name of mythical man-made global warming. It is one of Obama's last dirty tricks to attack the fossil fuel industry.
This report summarizes the Hawaii Department of Agriculture's pesticide program activities for FY2015 under the Performance Partnership Grant with the EPA. It finds that HDOA met its inspection goals but needs to improve inspections, reduce a large backlog of inspection files needing review, secure a backup laboratory, and focus on revising enforcement policies. Recommendations include improving inspections and reports, addressing delays in file review and case development, and identifying an alternate laboratory for sample analysis. The report evaluates HDOA's financial reporting, training activities, and quality assurance programs.
The Hawaii Department of Agriculture (HDOA) has failed to fulfill its responsibilities to enforce pesticide use violations under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA). HDOA has a backlog of hundreds of inspection files dating back to 2008 that has prevented meaningful enforcement actions. This has allowed pesticide misuse to continue without consequences. The EPA has repeatedly warned HDOA about improving its enforcement efforts, but the problems have persisted and worsened. Due to HDOA's failures, the EPA should notify Hawaii that it intends to rescind the state's primary enforcement authority under FIFRA if deficiencies are not corrected within 90 days.
20050503 40 Cfr Part 158 Proposed Rule PresentationKaren Warkentien
This document summarizes key points from a presentation on proposed revisions to pesticide data requirements under 40 CFR Part 158. It discusses potential financial implications for registrants and the EPA, including increased study costs and monitoring costs. It also covers proposals regarding confidentiality claims and the codification of environmental fate and ecological effects guidelines that have not been finalized. The presentation urges attendees to submit comments on the proposed rule by the June 9, 2005 deadline.
1) Nearly 20% of all incidents reported to the Pennsylvania Emergency Incident Reporting System in 2011 were related to hazardous materials or petroleum. The document discusses preparing for and responding to environmental emergencies in Pennsylvania.
2) It outlines the relevant Pennsylvania laws around emergency management, hazardous materials, and mutual aid. This includes requirements for emergency operations plans, hazardous chemical reporting and notifications of releases.
3) The document provides guidance on identifying potential environmental hazards through publicly available databases and developing an emergency response plan to address issues around drinking water, air quality, and local resources.
A piece of propaganda issued by the far-left, virulent anti-drilling Earthworks titled "Blackout in the Gas Patch: How Pennsylvania Residents are Left in the Dark on Health and Enforcement". The "study" supposedly offers evidence of regulatory mismanagement at the state's Dept. of Environmental Protection with respect to the miracle of Marcellus Shale drilling. The report is DOA because it's not independent and misrepresents the data. One more anti-drilling tirade by a fossil fuel-hating organization.
NGA Report: State Practices to Protect Drinking Water While Developing Shale ...Marcellus Drilling News
The National Governors Association (NGA) issued a 16-page report in July encouraging governors and their states to adopt policies that encourage a) the use of less drinking water for fracking, and b) the use of more recycling of flowback water in fracking. The report, titled "State Practices to Protect Drinking Water While Developing Shale Energy" (full copy below), is the result of a a 35-member panel that met in March.
The document provides a summary and analysis of NERC's Initial Reliability Review of the EPA's proposed Clean Power Plan. The analysis finds that while NERC raises some valid concerns about assumptions in EPA's analysis, reliability is unlikely to be materially affected by the CPP. Compliance can be achieved through a combination of coal plant modifications, gas switching, renewable energy expansion, and energy efficiency, utilizing existing reliability tools. The transformation of the power system is ongoing and system operators have sufficient flexibility and options to ensure reliability with the CPP.
EPA's Final Rule Forcing O&G Drillers to Capture Tiny Amounts of Fugitive Met...Marcellus Drilling News
An onerous and expensive set of rules from a rogue, out-of-control federal bureaucracy--the Environmental Protection Agency--forcing shale drillers to spend huge amounts of money to capture tiny amounts of leaking methane. All in the name of mythical man-made global warming. It is one of Obama's last dirty tricks to attack the fossil fuel industry.
This report summarizes the Hawaii Department of Agriculture's pesticide program activities for FY2015 under the Performance Partnership Grant with the EPA. It finds that HDOA met its inspection goals but needs to improve inspections, reduce a large backlog of inspection files needing review, secure a backup laboratory, and focus on revising enforcement policies. Recommendations include improving inspections and reports, addressing delays in file review and case development, and identifying an alternate laboratory for sample analysis. The report evaluates HDOA's financial reporting, training activities, and quality assurance programs.
The Hawaii Department of Agriculture (HDOA) has failed to fulfill its responsibilities to enforce pesticide use violations under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA). HDOA has a backlog of hundreds of inspection files dating back to 2008 that has prevented meaningful enforcement actions. This has allowed pesticide misuse to continue without consequences. The EPA has repeatedly warned HDOA about improving its enforcement efforts, but the problems have persisted and worsened. Due to HDOA's failures, the EPA should notify Hawaii that it intends to rescind the state's primary enforcement authority under FIFRA if deficiencies are not corrected within 90 days.
20050503 40 Cfr Part 158 Proposed Rule PresentationKaren Warkentien
This document summarizes key points from a presentation on proposed revisions to pesticide data requirements under 40 CFR Part 158. It discusses potential financial implications for registrants and the EPA, including increased study costs and monitoring costs. It also covers proposals regarding confidentiality claims and the codification of environmental fate and ecological effects guidelines that have not been finalized. The presentation urges attendees to submit comments on the proposed rule by the June 9, 2005 deadline.
1) Nearly 20% of all incidents reported to the Pennsylvania Emergency Incident Reporting System in 2011 were related to hazardous materials or petroleum. The document discusses preparing for and responding to environmental emergencies in Pennsylvania.
2) It outlines the relevant Pennsylvania laws around emergency management, hazardous materials, and mutual aid. This includes requirements for emergency operations plans, hazardous chemical reporting and notifications of releases.
3) The document provides guidance on identifying potential environmental hazards through publicly available databases and developing an emergency response plan to address issues around drinking water, air quality, and local resources.
A piece of propaganda issued by the far-left, virulent anti-drilling Earthworks titled "Blackout in the Gas Patch: How Pennsylvania Residents are Left in the Dark on Health and Enforcement". The "study" supposedly offers evidence of regulatory mismanagement at the state's Dept. of Environmental Protection with respect to the miracle of Marcellus Shale drilling. The report is DOA because it's not independent and misrepresents the data. One more anti-drilling tirade by a fossil fuel-hating organization.
NGA Report: State Practices to Protect Drinking Water While Developing Shale ...Marcellus Drilling News
The National Governors Association (NGA) issued a 16-page report in July encouraging governors and their states to adopt policies that encourage a) the use of less drinking water for fracking, and b) the use of more recycling of flowback water in fracking. The report, titled "State Practices to Protect Drinking Water While Developing Shale Energy" (full copy below), is the result of a a 35-member panel that met in March.
EQT Notice of Appeal Contesting DEP Order Finding Greene County Spill Led to ...Marcellus Drilling News
The appeal from EQT in response to a finding/order by the PA Dept. of Environmental Protection (DEP) in which the DEP alleges a 2010 spill at an EQT drilling site in Greene County, PA led to permanent pollution of a nearby fresh water spring.
A draft version of PA's Oil & Gas Drilling rules known as Chapter 78 and 78a, issued by the PA Dept. of Environmental Protection on August 12, 2015. Two different committees will consider this major revision to drilling rules. The newly revised rules are expected to be adopted later this year.
High Volume Hydraulic Fracturing in Michigan - Integrated Assessment Final Re...Marcellus Drilling News
The final report from the University of Michigan, part of the Hydraulic Fracturing in Michigan Integrated Assessment. The report does not advocate for any particular position, pro or anti-fracking. It simply reports findings and actual science. Let the policy makers use the information to formulate rules and regulations. Bottom line: fracking can be done safely with the right rules and regulations.
Report: Private Interests & Public Office - Coordination Between Governors, t...Marcellus Drilling News
A blockbuster report from the Energy & Environment Legal Institute blows the doors off the potentially illegal collusion between the Obama White House, several state governors, and climate scare-monger groups backed by billionaire Tom Steyer. The report connects the dots of a disgusting, coordinated attack on fossil fuels (specifically coal, but also other fossil fuels). Using open records laws E&E Legal has produced a must-read expose that lays bare how environmental wackos have put their own self-interests ahead of the nation, profiting from it as they do so.
U.S. Second Circuit Court Decision in Beardslee v Inflection Energy, LLCMarcellus Drilling News
A decision by the U.S. Court of Appeals for the Second Circuit that upholds New York's highest court in deciding that the contracts three Marcellus drilling companies signed with Tioga County, NY landowners do not allow for an extension to the lease term due to New York's arbitrary and capricious fracking ban.
Letter to President Obama from Group of Anti-Fossil Fuel Nutters Asking the P...Marcellus Drilling News
A letter from a group of 400 mostly individuals, flying under the moniker of 400 "organizations," asking our Dear Leader to stop all fossil fuel extraction on federally controlled lands. Why? Because of mythical man-made global warming, of course! They have left their senses.
Ohio Oil & Gas Commission Decison: Gary L. Teeter Revocable Trust v. Division...Marcellus Drilling News
The Commission upheld a forced pooling order against Ohio landowner Gary Teeter by reaffirming that Ohio's pooling and unitization provisions work to protect landowners--even those who prefer not to be part of a drilling unit--by fairly compensating them.
Increasing the United States’ export of liquefied natural gas (LNG) above 12 billion cubic feet per day (Bcf/d) would allow the U.S. to continue to provide a competitive advantage for domestic natural-gas-intensive industries relative to their counterparts overseas, according to a new report presented to the U.S. Department of Energy from the Center for Energy Studies at Rice University’s Baker Institute for Public Policy and Oxford Economics.
Tables showing 381 metropolitan regions across the United States and whether those regions saw an expansion or shrinkage of their economies. The tables go into detail as to what sectors saw increases and decreases. Certain regions saw dramatic increases from shale energy activity.
The U.S. Court of Appeals for the Sixth Circuit on Oct 9, 2015 issued a stay on the odious and overreaching Environmental Protection Agency (EPA)/Army Corps of Engineers' (ECA) so-called update that redefines Waters of the United States (WOTUS) to include just about everything, including mud puddles. Some 13 states sued to stop the new rule. This action keeps the rule from being adopted in any of the 50 states until a lawsuit, brought by the 13 states, has a chance of playing out in court.
Proposed Notice of Settlement for Demchak Partners, LLP (and others) v Chesap...Marcellus Drilling News
Proposed settlement in the "Demchak" royalty case in Pennsylvania. PA landowners sued Chesapeake Energy for shorting them on royalty payments using a technique of inflating post-production prices. This settlement compensates "several thousand" landowners with 2/3 of $11 million as part of the settlement--virtual peanuts compared to what they are truly owed.
The Economic Impact of Dominion Capital Expenditure Projects in Virginia 2015...Marcellus Drilling News
A study authored by Chmura Economic & Analytics which proves Dominion, a utility/pipeline giant operating in 14 states, will create nearly 12,000 new jobs and inject over $10 billion of new capital into the State of Virginia over the next five years. A sizable portion of the new projects involve natural gas.
PA Superior Court Ruling in Patricia Wright v. Misty Mountain, LLC and Shirle...Marcellus Drilling News
A ruling in an important mineral rights case in Pennsylvania, stemming from the sale of land, but not the oil and gas mineral rights, in 1950 in Bradford County, PA. The court upheld a decision that that the original mineral rights holder retained those rights even after a lease for those rights had expired.
The document discusses the results of a study on the impact of COVID-19 lockdowns on air pollution. Researchers found that lockdowns led to significant short-term reductions in nitrogen dioxide and fine particulate matter pollution globally as transportation and industrial activities declined substantially. However, the document notes that continued long-term progress on air quality will require systemic changes rather than temporary reductions from emergency measures.
The Natural Gas Supply Association’s (NGSA) 2015 Winter Outlook for Natural Gas. This 89-page report, researched by Energy Ventures Analysis, Inc., concludes that the price of natural gas for the winter ahead will be pretty much the same as last winter's prices.
The PowerPoint presentation used at the annual analyst/investor day held at Marathon Petroleum HQ in Findlay, OH on Dec 3, 2015. The information in the slide deck of most interest to us is the section on midstream, detailing the newly combined operation of Marathon and MarkWest Energy Partners.
EPA Inspector General Report Calling on EPA to Do More About Fugitive MethaneMarcellus Drilling News
A "report" by the Environmental Protection Agency's Inspector General that says the EPA is not doing enough to stop so-called fugitive methane from leaking from pipelines. The IG wants the EPA to use stricter measures and move away from voluntary measures (to forced measures) to reduce methane leakage. All in an attempt to address the issue of mythical global warming.
NATURAL GAS DISTRIBUTION PIPELINES- METHANE EMISSIONS CHALLENGESDr Dev Kambhampati
The EPA has taken limited action to reduce methane emissions from natural gas distribution pipelines. Methane leaks from distribution pipelines accounted for over 13 million metric tons of emissions in 2012 but are not currently regulated by EPA. EPA has a voluntary program called Natural Gas STAR but it has achieved only limited reductions due to financial and policy barriers. EPA needs to work with other agencies, establish emission reduction goals, better track emissions data, and evaluate studies to update its emission factors which are based on outdated data and have high uncertainty. Addressing methane leaks through improved regulation or policies could help reduce climate change impacts.
Memo from EPA Office of Inspector General (OIG) Convening Project to Examine ...Marcellus Drilling News
The EPA OIG is beginning a new project that will "determine and evaluate what regulatory authority is available to the EPA and states, identify potential threats to water resources from hydraulic fracturing, and evaluate the EPA’s and states’ responses to them." In other words, the OIG wants to push its way into regulating oil and gas drilling too--along with their parent EPA. I.e., a federal takeover of drilling regulation.
EQT Notice of Appeal Contesting DEP Order Finding Greene County Spill Led to ...Marcellus Drilling News
The appeal from EQT in response to a finding/order by the PA Dept. of Environmental Protection (DEP) in which the DEP alleges a 2010 spill at an EQT drilling site in Greene County, PA led to permanent pollution of a nearby fresh water spring.
A draft version of PA's Oil & Gas Drilling rules known as Chapter 78 and 78a, issued by the PA Dept. of Environmental Protection on August 12, 2015. Two different committees will consider this major revision to drilling rules. The newly revised rules are expected to be adopted later this year.
High Volume Hydraulic Fracturing in Michigan - Integrated Assessment Final Re...Marcellus Drilling News
The final report from the University of Michigan, part of the Hydraulic Fracturing in Michigan Integrated Assessment. The report does not advocate for any particular position, pro or anti-fracking. It simply reports findings and actual science. Let the policy makers use the information to formulate rules and regulations. Bottom line: fracking can be done safely with the right rules and regulations.
Report: Private Interests & Public Office - Coordination Between Governors, t...Marcellus Drilling News
A blockbuster report from the Energy & Environment Legal Institute blows the doors off the potentially illegal collusion between the Obama White House, several state governors, and climate scare-monger groups backed by billionaire Tom Steyer. The report connects the dots of a disgusting, coordinated attack on fossil fuels (specifically coal, but also other fossil fuels). Using open records laws E&E Legal has produced a must-read expose that lays bare how environmental wackos have put their own self-interests ahead of the nation, profiting from it as they do so.
U.S. Second Circuit Court Decision in Beardslee v Inflection Energy, LLCMarcellus Drilling News
A decision by the U.S. Court of Appeals for the Second Circuit that upholds New York's highest court in deciding that the contracts three Marcellus drilling companies signed with Tioga County, NY landowners do not allow for an extension to the lease term due to New York's arbitrary and capricious fracking ban.
Letter to President Obama from Group of Anti-Fossil Fuel Nutters Asking the P...Marcellus Drilling News
A letter from a group of 400 mostly individuals, flying under the moniker of 400 "organizations," asking our Dear Leader to stop all fossil fuel extraction on federally controlled lands. Why? Because of mythical man-made global warming, of course! They have left their senses.
Ohio Oil & Gas Commission Decison: Gary L. Teeter Revocable Trust v. Division...Marcellus Drilling News
The Commission upheld a forced pooling order against Ohio landowner Gary Teeter by reaffirming that Ohio's pooling and unitization provisions work to protect landowners--even those who prefer not to be part of a drilling unit--by fairly compensating them.
Increasing the United States’ export of liquefied natural gas (LNG) above 12 billion cubic feet per day (Bcf/d) would allow the U.S. to continue to provide a competitive advantage for domestic natural-gas-intensive industries relative to their counterparts overseas, according to a new report presented to the U.S. Department of Energy from the Center for Energy Studies at Rice University’s Baker Institute for Public Policy and Oxford Economics.
Tables showing 381 metropolitan regions across the United States and whether those regions saw an expansion or shrinkage of their economies. The tables go into detail as to what sectors saw increases and decreases. Certain regions saw dramatic increases from shale energy activity.
The U.S. Court of Appeals for the Sixth Circuit on Oct 9, 2015 issued a stay on the odious and overreaching Environmental Protection Agency (EPA)/Army Corps of Engineers' (ECA) so-called update that redefines Waters of the United States (WOTUS) to include just about everything, including mud puddles. Some 13 states sued to stop the new rule. This action keeps the rule from being adopted in any of the 50 states until a lawsuit, brought by the 13 states, has a chance of playing out in court.
Proposed Notice of Settlement for Demchak Partners, LLP (and others) v Chesap...Marcellus Drilling News
Proposed settlement in the "Demchak" royalty case in Pennsylvania. PA landowners sued Chesapeake Energy for shorting them on royalty payments using a technique of inflating post-production prices. This settlement compensates "several thousand" landowners with 2/3 of $11 million as part of the settlement--virtual peanuts compared to what they are truly owed.
The Economic Impact of Dominion Capital Expenditure Projects in Virginia 2015...Marcellus Drilling News
A study authored by Chmura Economic & Analytics which proves Dominion, a utility/pipeline giant operating in 14 states, will create nearly 12,000 new jobs and inject over $10 billion of new capital into the State of Virginia over the next five years. A sizable portion of the new projects involve natural gas.
PA Superior Court Ruling in Patricia Wright v. Misty Mountain, LLC and Shirle...Marcellus Drilling News
A ruling in an important mineral rights case in Pennsylvania, stemming from the sale of land, but not the oil and gas mineral rights, in 1950 in Bradford County, PA. The court upheld a decision that that the original mineral rights holder retained those rights even after a lease for those rights had expired.
The document discusses the results of a study on the impact of COVID-19 lockdowns on air pollution. Researchers found that lockdowns led to significant short-term reductions in nitrogen dioxide and fine particulate matter pollution globally as transportation and industrial activities declined substantially. However, the document notes that continued long-term progress on air quality will require systemic changes rather than temporary reductions from emergency measures.
The Natural Gas Supply Association’s (NGSA) 2015 Winter Outlook for Natural Gas. This 89-page report, researched by Energy Ventures Analysis, Inc., concludes that the price of natural gas for the winter ahead will be pretty much the same as last winter's prices.
The PowerPoint presentation used at the annual analyst/investor day held at Marathon Petroleum HQ in Findlay, OH on Dec 3, 2015. The information in the slide deck of most interest to us is the section on midstream, detailing the newly combined operation of Marathon and MarkWest Energy Partners.
EPA Inspector General Report Calling on EPA to Do More About Fugitive MethaneMarcellus Drilling News
A "report" by the Environmental Protection Agency's Inspector General that says the EPA is not doing enough to stop so-called fugitive methane from leaking from pipelines. The IG wants the EPA to use stricter measures and move away from voluntary measures (to forced measures) to reduce methane leakage. All in an attempt to address the issue of mythical global warming.
NATURAL GAS DISTRIBUTION PIPELINES- METHANE EMISSIONS CHALLENGESDr Dev Kambhampati
The EPA has taken limited action to reduce methane emissions from natural gas distribution pipelines. Methane leaks from distribution pipelines accounted for over 13 million metric tons of emissions in 2012 but are not currently regulated by EPA. EPA has a voluntary program called Natural Gas STAR but it has achieved only limited reductions due to financial and policy barriers. EPA needs to work with other agencies, establish emission reduction goals, better track emissions data, and evaluate studies to update its emission factors which are based on outdated data and have high uncertainty. Addressing methane leaks through improved regulation or policies could help reduce climate change impacts.
Memo from EPA Office of Inspector General (OIG) Convening Project to Examine ...Marcellus Drilling News
The EPA OIG is beginning a new project that will "determine and evaluate what regulatory authority is available to the EPA and states, identify potential threats to water resources from hydraulic fracturing, and evaluate the EPA’s and states’ responses to them." In other words, the OIG wants to push its way into regulating oil and gas drilling too--along with their parent EPA. I.e., a federal takeover of drilling regulation.
EPA New Rules Governing Air Pollution Standards for Hydraulic FracturingMarcellus Drilling News
New rules (40 CFR Part 63) issued by the Environmental Protection Agency on Wednesday, April 18 that will govern air pollution standards at oil and gas drilling operations, in particular at well sites using hydraulic fracturing (fracking). The EPA claims that the new standards will mean drillers will capture more gas that currently "leaks" into the atmosphere during drilling completions, and that the extra gas can be sold to offset the cost of new equipment and procedures required under the regulations.
FUNDING FOR ENVIRONMENTAL RESEARCH AND DEVELOPMENT BY THE U.S. ENVIRONMENTAL ...Lyle Birkey
This document summarizes federal funding for environmental research and development by the U.S. Environmental Protection Agency (EPA) in 2014. It outlines the EPA's six major research areas and budgets for each. In 2014, the EPA's total budget for environmental research was $555 million. The largest shares went to research related to sustainable and healthy communities ($155 million), chemical safety and sustainability ($131 million), and safe and sustainable water resources ($111 million). The document provides details on the goals and programs within each research area.
The Georgia Department of Defense Environmental Stewardship Branch exists to support Commanders and their Mission by reducing environmental liabilities and promoting the US Army Environmental Stewardship Program. The newsletter provides information on the branch's ongoing projects and activities for 2014, including its energy program to promote water and energy efficiency, upcoming environmental training opportunities, issues regarding funding of state parks and air quality compliance, cleanup and restoration efforts of past environmental issues, and natural resource conservation work involving bald eagles.
So-Called Performance Audit of the PA Dept. of Environmental ProtectionMarcellus Drilling News
A very biased and anti-drilling performance audit conducted by Pennsylvania's "renewable energy only" Auditor General Eugene DePasquale of the state's Dept. of Environmental Protection, the agency charged with regulating and overseeing Marcellus Shale drilling in the state. From his very first day in office DePasquale targeted the shale drilling industry with his attempt to smear it and slander it in the public's perception. Shame on him and this fraudulent "report".
Contents: Hoping for the Best, Preparing for the Worst: Utilities continue to prepare to implement the EPA's most sweeping carbon-dioxide rule to date.
-Nuclear Still Delivers: Some public power utilities continue to invest in nuclear power plants as CO2-free, diversified energy sources.
-Smart Start for Public Power: Utilities modernized the gird with smart meters.
-Power in Numbers: New Jersey public power utilities are trying to secure state legislation that would allow them to work together through a joint action agency and harness economies of scale.
----------------------------------------------------------------------
Public Power magazine is the trade magazine for the more than 2,000 community-owned electric utilities that serve more than 48 million people in the United States. The American Public Power Association publishes the magazine bi-monthly online and in print.
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A GAO report published in June 2014 but not released to the public until July 28, 2014. Titled "EPA Program to Protect Underground Sources from Injection of Fluids Associated with Oil and Gas Production Needs Improvement" the report, as the title indicates, takes EPA to task for what they say is lax oversight of oil and gas injection wells--wells used to dispose of wastewater from drilling operations. It's important to note that the GAO is extremely partisan and populated with liberal Democrat lifers with an agenda.
A letter from Dan Fitzsimmons, president of the Joint Landowners Coalition of New York (JLCNY) to NY Gov. Andrew Cuomo expressing profound disappointment that Cuomo intends to let the Nov. 29 date slip by without releasing new drilling rules to allow shale gas drilling in the state.
The dissenting opinion of a member of the 31-member Science Advisory Board panel appointed to review the EPA's own study of fracking and its impact on water. Dr. Walt Hufford disagrees with other members of the panel and believes the original study and its findings are accurate and do not need to be changed.
Erci mar2015 webinar 2014 10 k reports on environmental liabilities - trendsjohnrosengard
This document summarizes a webinar presented by John Rosengard on trends seen in environmental liability disclosures in 2014 10-K reports. Some of the key findings from the webinar include: disclosures of environmental liabilities are not always uniform; 17 of 18 companies reviewed showed growing environmental liabilities from 1995 to 2014; and most companies claim to use fair value measurement for liabilities but only metals/mining say they apply it to environmental liabilities. The webinar also included case studies on environmental liability balances and spending at various large companies over time.
The Utah Department of Environmental Quality's 2015 State of the Environment Report discusses the department's work to improve air, land, and water quality in Utah. For air quality, the department conducted research on pollution sources, implemented incentive programs to reduce emissions, and developed plans to address issues like PM2.5 levels and ozone standards. For land, the Division of Waste Management and Radiation Control regulated proper waste handling and cleanup of contaminated sites. The report provided details on specific projects, regulations, and plans carried out by DEQ to protect the environment and public health in Utah.
This document discusses pollution from point sources (industrial and municipal facilities) that discharge into the Chesapeake Bay watershed. It analyzes data from 2010-2011 on nitrogen discharges and compliance from significant sources. While discharges decreased substantially in VA, MD, and WV, they increased in PA and slightly in NY. Some permits lack numeric nutrient limits. Violations of permit limits are common, releasing over 700,000 pounds of excess nitrogen in 2011. Achieving pollution reductions from all sources, including improved compliance and enforcement, will be needed to restore water quality in the Bay.
A letter from a littany of virulent anti-drilling groups to the secretary of the PA Dept. of Environmental Protection telling him he's falling down on the job. Pure propaganda and bullcrap.
Food & Water Watch Letter to EPA Requesting the Agency Lie About Fracking Res...Marcellus Drilling News
A letter from a group of radical environmental organizations, including Food & Water Watch, the Sierra Club, and others, requesting that EPA Administrator Gina McCarthy lie about the science-based conclusions reach in last year's EPA report that said fracking does not contaminate water supplies. These groups want the EPA to reverse its language in the report in order to lie about fracking. Very sick.
Waterkeeper's submission to the NR Standing Committee on the current state an...LOWaterkeeper
On May 29, 2018, Pippa Feinstein presented Waterkeeper’s submission on the current and future of National Energy data to the House of Commons Standing Committee on Natural Resources.
The document summarizes five key facts about the recovery of US shale oil production:
1) Rig counts have increased by 90% since bottoming out in May 2016 and are up 30% year-over-year, signaling increased drilling and production capacity.
2) While decline rates remain steep, production profiles have increased substantially due to technological advances, meaning aggregate supply will be stronger.
3) Preliminary data shows that net new shale supply turned positive in December 2016 for the first time since March 2015, recovering just 7 months after rig counts increased.
4) Increased drilling activity is supported by a large stock of drilled but uncompleted wells, demonstrating the recovery and expansion of the shale sector.
5)
Quarterly legislative action update: Marcellus and Utica shale region (4Q16)Marcellus Drilling News
A quarterly update from the legal beagles at global law firm Norton Rose Fulbright. A quarterly legislative action update for the second quarter of 2016 looking at previously laws acted upon, and new laws introduced, affecting the oil and gas industry in Pennsylvania, Ohio and West Virginia.
An update from Spectra Energy on their proposed $3 billion project to connect four existing pipeline systems to flow more Marcellus/Utica gas to New England. In short, Spectra has put the project on pause until mid-2017 while it attempts to get new customers signed.
A letter from Rover Pipeline to the Federal Energy Regulatory Commission requesting the agency issue the final certificate that will allow Rover to begin tree-clearing and construction of the 511-mile pipeline through Pennsylvania, West Virginia, Ohio and Michigan. If the certificate is delayed beyond the end of 2016, it will delay the project an extra year due to tree-clearing restrictions (to accommodate federally-protected bats).
DOE Order Granting Elba Island LNG Right to Export to Non-FTA CountriesMarcellus Drilling News
An order issued by the U.S. Dept. of Energy that allows the Elba Island LNG export facility to export LNG to countries with no free trade agreement with the U.S. Countries like Japan and India have no FTA with our country (i.e. friendly countries)--so this is good news indeed. Although the facility would have operated by sending LNG to FTA countries, this order opens the market much wider.
A study released in December 2016 by the London School of Economics, titled "On the Comparative Advantage of U.S. Manufacturing: Evidence from the Shale Gas Revolution." While America has enough shale gas to export plenty of it, exporting it is not as economic as exporting oil due to the elaborate processes to liquefy and regassify natural gas--therefore a lot of the gas stays right here at home, making the U.S. one of (if not the) cheapest places on the planet to establish manufacturing plants, especially for manufacturers that use natural gas and NGLs (natural gas liquids). Therefore, manufacturing, especially in the petrochemical sector, is ramping back up in the U.S. For every two jobs created by fracking, another one job is created in the manufacturing sector.
Letter From 24 States Asking Trump & Congress to Withdraw the Unlawful Clean ...Marcellus Drilling News
A letter from the attorneys general from 24 of the states opposed to the Obama Clean Power Plan to President-Elect Trump, RINO Senate Majority Leader Mitch McConnel and RINO House Speaker Paul Ryan. The letter asks Trump to dump the CPP on Day One when he takes office, and asks Congress to adopt legislation to prevent the EPA from such an egregious overreach ever again.
Report: New U.S. Power Costs: by County, with Environmental ExternalitiesMarcellus Drilling News
Natural gas and wind are the lowest-cost technology options for new electricity generation across much of the U.S. when cost, public health impacts and environmental effects are considered. So says this new research paper released by The University of Texas at Austin. Researchers assessed multiple generation technologies including coal, natural gas, solar, wind and nuclear. Their findings are depicted in a series of maps illustrating the cost of each generation technology on a county-by-county basis throughout the U.S.
Annual report issued by the U.S. Energy Information Administration showing oil and natural gas proved reserves, in this case for 2015. These reports are issued almost a year after the period for which they report. This report shows proved reserves for natural gas dropped by 64.5 trillion cubic feet (Tcf), or 16.6%. U.S. crude oil and lease condensate proved reserves also decreased--from 39.9 billion barrels to 35.2 billion barrels (down 11.8%) in 2015. Proved reserves are calculated on a number of factors, including price.
The document is a report from the U.S. Energy Information Administration analyzing oil and gas production from seven regions in the U.S. It includes charts and tables showing historical and projected production levels of oil and gas from each region from 2008 to 2017, as well as metrics like the average production per rig. The regions - Bakken, Eagle Ford, Haynesville, Marcellus, Niobrara, Permian, and Utica - accounted for 92% of domestic oil production growth and all domestic natural gas production growth from 2011-2014.
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Report: Enhanced EPA Oversight and Action Can Further Protect Water Resources From the Potential Impacts of Hydraulic Fracturing
1. f
Enhanced EPA Oversight
and Action Can Further
Protect Water Resources
From the Potential Impacts of
Hydraulic Fracturing
Report No. 15-P-0204 July 16, 2015
U.S. ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF INSPECTOR GENERAL
Scan this mobile
code to learn more
about the EPA OIG.
2. Report Contributors: Dan Engelberg
Khadija Walker
Johnny Ross
Stacey Banks
Danielle Tesch
Abbreviations
API American Petroleum Institute
CERCLA Comprehensive Environmental Response, Compensation and Liability Act
CWA Clean Water Act
EPA U.S. Environmental Protection Agency
GAO U.S. Government Accountability Office
OCSPP Office of Chemical Safety and Pollution Prevention
OECA Office of Enforcement and Compliance Assurance
OIG Office of Inspector General
ORD Office of Research and Development
OSWER Office of Solid Waste and Emergency Response
OW Office of Water
RCRA Resource Conservation and Recovery Act
SDWA Safe Drinking Water Act
STRONGER Inc. State Review of Oil & Natural Gas Environmental Regulations Inc.
TSCA Toxic Substances Control Act
UIC Underground Injection Control
Cover photo: Example of a hydraulic fracturing site located in the Marcellus Shale.
(EPA photo)
Are you aware of fraud, waste or abuse in an
EPA program?
EPA Inspector General Hotline
1200 Pennsylvania Avenue, NW (2431T)
Washington, DC 20460
(888) 546-8740
(202) 566-2599 (fax)
OIG_Hotline@epa.gov
More information at www.epa.gov/oig/hotline.html.
EPA Office of Inspector General
1200 Pennsylvania Avenue, NW (2410T)
Washington, DC 20460
(202) 566-2391
www.epa.gov/oig
Subscribe to our Email Updates
Follow us on Twitter @EPAoig
Send us your Project Suggestions
3. 15-P-0204
July 16, 2015
Why We Did This Review
The U.S. Environmental
Protection Agency (EPA),
Office of Inspector General
(OIG), conducted this review to
evaluate how the EPA and
states use existing authorities
to regulate the potential
impacts of hydraulic fracturing
on water.
The use of horizontal drilling
with hydraulic fracturing greatly
expanded the ability of
producers to recover natural
gas and oil from
unconventional sources.
According to an April 2014
report by the U.S. Energy
Information Administration,
natural gas production is
projected to increase by
56 percent from 2012 to 2040.
In addition, crude oil production
will climb from 7.5 million
barrels per day in 2013 to
9.6 million barrels per day by
2019. The increase in
unconventional oil and gas
development has led to new
and increased potential impacts
to water resources.
This report addresses the
following EPA goals or
cross-agency strategies:
Protecting America’s
waters.
Ensuring the safety of
chemicals and preventing
pollution.
Send all inquiries to our public
affairs office at (202) 566-2391
or visit www.epa.gov/oig.
The full report is at:
www.epa.gov/oig/reports/2015/
20150716-15-P-0204.pdf
Enhanced EPA Oversight and Action Can
Further Protect Water Resources From the
Potential Impacts of Hydraulic Fracturing
What We Found
Since 2007, the EPA, states and
other stakeholders have collectively
established regulations, policy,
guidance, industry standards and
recommended practices to manage
impacts to water resources from
unconventional oil and gas
development. Our review identified
two issues in need of improvement by
the EPA.
First, the EPA needs to improve oversight of permit issuance for hydraulic
fracturing using diesel fuels, and address any related compliance issues.
Evidence shows that companies have used diesel fuels during hydraulic fracturing
without EPA or primacy state underground injection control Class II permits. The
EPA has also not determined whether primacy states and tribes are following the
agency’s interpretive memorandum for issuing permits for hydraulic fracturing
using diesel fuels. Enhanced EPA oversight can increase assurance that risks
associated with diesel fuel hydraulic fracturing are being adequately addressed.
Second, the EPA needs to develop a plan for responding to the public’s concerns
about chemicals used in hydraulic fracturing. In May 2014, the EPA initiated a
process to evaluate whether to establish federal requirements for chemical
disclosure. However, the agency has not yet developed a plan of action for further
steps in this proposed rulemaking activity. A plan outlining the agency’s next steps
would inspire public confidence that the agency is indeed taking action to evaluate
disclosure options within a defined timeframe.
Recommendations and Planned Agency Corrective Actions
We recommend that the EPA’s Assistant Administrator for Water determine
whether primacy states and tribes issue permits for the use of diesel fuels as
required. We recommend that the Assistant Administrator for Enforcement and
Compliance Assurance address any compliance issues related to issuing permits
for hydraulic fracturing using diesel fuels. We also recommend that the Assistant
Administrator for Chemical Safety and Pollution Prevention establish and publish
a plan with milestone dates that outlines all steps for determining whether to
propose a rule to obtain information concerning chemical substances and
mixtures used in hydraulic fracturing.
The agency either agreed with our recommendations or proposed actions that
meet the intent of our recommendations. All recommendations are resolved or
closed and no further response from the agency is needed.
U.S. Environmental Protection Agency
Office of Inspector General
At a Glance
Enhanced EPA oversight of the
permitting process for diesel fuel use
during hydraulic fracturing can further
EPA efforts to protect water resources,
and establishment of a plan for
determining whether to propose a
chemical disclosure rule can help
address the public’s concerns about
hydraulic fracturing chemicals.
4. July 16, 2015
MEMORANDUM
SUBJECT: Enhanced EPA Oversight and Action Can Further Protect Water Resources
From the Potential Impacts of Hydraulic Fracturing
Report No. 15-P-0204
FROM: Arthur A. Elkins Jr.
TO: Ken Kopocis, Deputy Assistant Administrator
Office of Water
Cynthia Giles, Assistant Administrator
Office of Enforcement and Compliance Assurance
Jim Jones, Assistant Administrator
Office of Chemical Safety and Pollution Prevention
This is our report on the subject evaluation conducted by the Office of Inspector General (OIG) of the
U.S. Environmental Protection Agency (EPA). This report contains findings that describe the problems
the OIG has identified and corrective actions the OIG recommends. This report represents the opinion of
the OIG and does not necessarily represent the final EPA position. Final determinations on matters in
this report will be made by EPA managers in accordance with established audit resolution procedures.
The EPA’s Office of Water, Office of Enforcement and Compliance Assurance, and Office of Chemical
Safety and Pollution Prevention have primary responsibility for implementing the recommendations in
this report.
You are not required to provide a written response to this final report because you provided agreed-to
corrective actions and planned completion dates for the report recommendations. The OIG may make
periodic inquiries on your progress in implementing these corrective actions. Please update the EPA’s
Management Audit Tracking System as you complete planned corrective actions. Should you choose to
provide a final response, we will post your response on the OIG’s public website, along with our
memorandum commenting on your response. Your response should be provided as an Adobe PDF file
that complies with the accessibility requirements of Section 508 of the Rehabilitation Act of 1973, as
amended. The final response should not contain data that you do not want to be released to the public;
if your response contains such data, you should identify the data for redaction or removal along with
corresponding justification.
We will post this report to our website at http://www.epa.gov/oig.
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
THE INSPECTOR GENERAL
5. Enhanced EPA Oversight and Action Can 15-P-0204
Further Protect Water Resources From the
Potential Impacts of Hydraulic Fracturing
Table of Contents
Chapters
1 Introduction ...................................................................................................... 1
Purpose ..................................................................................................... 1
Background................................................................................................ 1
Responsible Offices................................................................................... 5
Scope and Methodology ............................................................................ 5
2 EPA, States and Other Stakeholders Are Taking Steps to Manage
Impacts to Water Resources, But Action Is Needed on the Use of
Diesel Fuels in Hydraulic Fracturing, and Chemical Disclosure................... 8
EPA and States Share Responsibilities for Managing Impacts to
Water Resources................................................................................... 8
Other Stakeholder Initiatives Support Managing Impacts to
Water Resources……………………….. ................................................. 11
EPA Needs to Assess Whether Permits Are Issued and Enforced
Properly When Diesel Fuels Are Used in Hydraulic Fracturing
Under the UIC Class II Program ............................................................ 11
EPA Has Started Responding to the Public’s Concerns About
Chemicals Used in Fracturing Fluid, But Action Plan Is Needed............ 14
Conclusion................................................................................................. 14
Recommendations..................................................................................... 15
Agency Comments and OIG Evaluation..................................................... 15
Status of Recommendations and Potential Monetary Benefits ............................. 17
Appendices
A Additional Details on Scope and Methodology .............................................. 18
B Agency Response to Draft Report and OIG Evaluation ................................. 22
C Distribution ....................................................................................................... 27
6. 15-P-0204 1
Chapter 1
Introduction
Purpose
The U.S. Environmental Protection Agency (EPA), Office of Inspector General
(OIG), conducted this review to examine how the EPA and states use their
authorities to manage the potential impacts of hydraulic fracturing on water
resources.
Background
In this report, hydraulic fracturing refers to unconventional oil and gas
development where vertical and horizontal drilling are combined to exploit
unconventional sources of oil and gas. Recent advances in unconventional oil and
gas development have made it profitable to extract oil and natural gas reserves
previously not economically viable. Although unconventional oil and gas
development was used as early as 2003, the process came into widespread use
around 2007. Since 2007, the production of oil and gas has grown steadily. The
production of natural gas in the major shale formations in the United States has
grown from approximately 15.5 billion cubic feet per day in 2007 to 40.5 billion
cubic feet per day in 2014 (Figure 1). The production of oil in major shale
formations is projected to increase from 7.5 million barrels a day in 2013 to
9.6 million barrels per day by 2019.
Figure 1: Annual natural gas production from seven shale plays (2007–2014)a
a
This includes the Bakken, Eagle Ford, Haynesville, Marcellus, Niobrara, Permian and Utica
shale plays.
Source: OIG analysis of January 2015 data from the U.S. Energy Information Administration.
7. 15-P-0204 2
According to the U.S. Energy Information Administration, 95 percent of domestic
oil production growth and all domestic natural gas production growth during 2011
through 2013 came from seven key regions (or shale plays): Bakken, Eagle Ford,
Haynesville, Marcellus, Niobrara, Permian and Utica (Figure 2).
Figure 2: “Shale plays” in the continental United Statesa
a
A “shale play” is an industry term used to refer to any shale formation that
produces natural gas and oil.
Source: U.S. Energy Information Administration (updated February 6, 2015).
Different Stages of Unconventional Oil and Gas Development Have
Varying Potential Impacts to Water Resources
The process of unconventional oil and gas development involves the following
stages:
1. Preparing the well pad, creating the infrastructure to the pad site, and
drilling the well (“construction”).
2. Extracting the water needed for well stimulation from groundwater and
surface water sources (“water acquisition”).
3. Mixing water with chemicals that will be used to stimulate, including
hydraulically fracturing, the well (“chemical mixing”).
4. Injecting the fracturing fluid into the well to stimulate (creating and
propping open fractures) the formation and extracting oil and/or natural
gas (“well stimulation”).
5. Collecting the wastewater that returns from the well as either flowback
and/or produced water (“wastewater management and storage”).
6. Treating and/or disposing of the wastewater (“wastewater treatment and
waste disposal”).
8. 15-P-0204 3
In the 2011 publication Blueprint for a Secure Energy Future, the White House
highlighted the importance of proactively addressing concerns about potential
negative impacts of hydraulic fracturing activities. The growth of unconventional
oil and gas development has been accompanied by attention to the impacts of this
practice on the environment.
Table 1 summarizes how water resources may be impacted during different stages
of unconventional oil and gas development. For example, well pad construction
can cause land erosion and runoff of sediment and other harmful pollutants into
nearby water bodies. Spills and leaks of hydraulic fracturing chemicals can also
result from improper well construction and/or chemical storage and handling
during the chemical mixing and well-stimulation stages.
Table 1: Potential impacts to water resources during different stages of
unconventional oil and gas development
Stage Potential impacts to water resources
Construction Erosion and sediment runoff into surface waters from land
disturbing activities impacting water quality, aquatic life and
wetlands.
Improper well construction could impact water resources in other
stages of the process.
Spills of drilling mud (i.e., a complex mixture of chemicals used
to control pressure, lubricate the drill bit, stabilize the shale
formation, control fluid loss, and retrieve cuttings).
Water
Acquisition
Impacts depend on the time of the year, the geographic location
of water withdrawals and current water-management practices,
but there could be impacts on local water quantity and quality.
Chemical Mixing Surface spills or spills that reach the subsurface of individual
hydraulic fracturing chemicals or fracturing fluid (i.e., chemicals
mixed with water for hydraulic fracturing).
Well Stimulation Migration of chemicals and natural gas/oil to groundwater
sources as a result of improper well construction, well casing or
cement failure under high pressure and/or repeated fracturing.
Migration of fluids through the hydraulically fractured network
and/or the existing faults and fractures in the subsurface.
Spills and leaks from hydraulic fracturing equipment (e.g.,
pumps and flowlines).
Wastewater
Management
and Storage
Surface spills and releases of flowback and produced waters
while transporting wastewater to or from storage tanks or
impoundments containing constituents from the formation water
(e.g., naturally occurring radioactive material, barium, dissolved
solids, heavy metals and salts).
Wastewater
Treatment
and/or Disposal
Water treatment facilities (i.e., publicly owned treatment works
and centralized waste treatment) may not be able to effectively
treat wastewater from hydraulic fracturing activities, which can
impact surface water when discharged.
Spills to surface waters during transportation of wastewater to
treatment facilities or disposal sites.
Source: OIG analysis and summary.
9. 15-P-0204 4
Recent EPA Activities Related to Unconventional Oil and Gas
Development
The EPA is taking steps to examine its role, responsibilities and prior regulatory
determinations in light of a surge in unconventional oil and gas development.
The agency has designated a headquarters-level official to share information and
coordinate initiatives from various program offices involved with energy
extraction activities, including hydraulic fracturing. In addition, EPA regions have
managers and staff who coordinate oversight of energy extraction activities on a
regional level.
The EPA is also working with states and other stakeholders to understand and
address potential concerns with hydraulic fracturing, to ensure the public has
confidence that natural gas production will proceed in a safe and responsible
manner. The EPA has been moving forward with initiatives to provide regulatory
clarity with respect to existing laws and using existing authorities, where
appropriate. For example, in February 2014, the Office of Water (OW) issued an
interpretive memorandum1
specific to the use of diesel fuels in hydraulic
fracturing. In 2011, the EPA’s Region 3 clarified National Pollutant Discharge
Elimination System permit requirements if treatment plants accept wastewater
from hydraulic fracturing operations.
The EPA’s Office of
Solid Waste and
Emergency Response
(OSWER) completed a
review of waste-related
provisions contained in
the state regulations for
26 of the 33 gas-
producing states as of
March 2014. OSWER
also developed a list of
more than 80 publicly
available sources of
voluntary management
practices for oil and
gas exploration and
production wastes. The results of both efforts are posted on the OSWER website
as a resource for policymakers and operators.
1
EPA OW. 2014. Memorandum from Peter Grevatt, Director, Office of Ground Water and Drinking Water, to
Regional Administrators and State and Tribal Underground Injection Control Program Directors, Subject:
Implementation of the Safe Drinking Water Act’s Existing Underground Injection Control Program Requirements
for Oil and Gas Hydraulic Fracturing Activities Using Diesel Fuel, February 2014.
An unconventional oil and gas development site. (EPA photo)
10. 15-P-0204 5
In November 2014, OW submitted to the Office of Management and Budget
proposed pretreatment standards for hydraulic fracturing wastewater from
unconventional oil and gas formations sent to municipal wastewater treatment
plants. The EPA proposed these pretreatment standards in the Federal Register in
April 2015. OW also expects to release its draft chloride water-quality criterion
for the protection of aquatic life from discharges of highly saline wastewater into
surface water in early 2016.
In March 2015, the EPA’s Office of Research and Development (ORD) published
results of its analysis of chemical disclosures reported by the oil and gas industry
to FracFocus 1.0 between January 1, 2011, and February 28, 2013.2
In the
analysis, ORD identified 692 unique ingredients used as base fluids, proppants,
and additives in hydraulic fracturing fluids. In June 2015, the ORD released its
draft assessment of the potential impacts of oil and gas hydraulic fracturing
activities on the quality and quantity of drinking water resources in the United
States for public comment and peer review.3
Responsible Offices
The EPA’s OW, Office of Enforcement and Compliance Assurance (OECA), and
Office of Chemical Safety and Pollution Prevention (OCSPP) are responsible for
the issues identified in the report recommendations.
Scope and Methodology
We conducted this performance audit in accordance with generally accepted
government auditing standards. Those standards require that we plan and perform
the audit to obtain sufficient, appropriate evidence to provide a reasonable basis
for our findings and conclusions based on our audit objectives. We believe that
the evidence obtained provides a reasonable basis for our findings and
conclusions based on our audit objectives. We conducted this performance audit
from February 2014 through April 2015.
We conducted a literature review on unconventional oil and gas development,
as defined earlier. During the literature review, we focused on identifying the
potential impacts during different stages, as well as the authorities and/or
activities used by the EPA, states and other stakeholders to manage the potential
impacts (Appendix A).
2
EPA ORD. 2015. Analysis of Hydraulic Fracturing Fluid Data from the FracFocus Chemical Disclosure Registry
1.0, EPA/601/R-14/003 (March 2015). The data ORD analyzed is an incomplete picture of all hydraulic fracturing
due to the voluntary reporting in some states, the omission of Confidential Business Information from disclosures,
and invalid or erroneous information in the original disclosures or created during the development of ORD’s project
database.
3
EPA ORD. 2015. Assessment of the Potential Impacts of Hydraulic Fracturing for Oil and Gas on Drinking Water
Resources (External Review Draft), EPA/600/R-15/047c.
11. 15-P-0204 6
We conducted interviews with the EPA and three states about their respective
programs regulating the different stages of unconventional oil and gas
development, any ongoing initiatives to address potential impacts to water
resources, practices observed from industry or implemented by the agency, and
their views regarding gaps in regulations. We conducted interviews at EPA
headquarters and in EPA Regions 3, 6 and 8. We also interviewed managers and
staff from environmental protection and oil and gas agencies in Pennsylvania,
Arkansas and Colorado.
We interviewed other stakeholders (e.g., environmental groups, industry groups
and academics) about unconventional oil and gas development and any activities
or initiatives being implemented to manage potential impacts to water resources
during hydraulic fracturing.
Our review focused on identifying the EPA’s and states’ existing authorities and
regulations that protect water resources from unconventional oil and gas
development, not on how effectively these authorities and regulations actually
protect water resources. We also did not examine the implementation or overall
effectiveness of practices recommended by environmental and industry
stakeholders at protecting water resources. This did not impact our conclusions or
recommendations.
Additional details concerning our scope and methodology are found in
Appendix A.
Prior Audit Coverage
The U.S. Government Accountability Office (GAO) issued a report on the
development of shale oil and gas resources, and the environmental and public
health risks associated with the activity, in September 2012.4
GAO did not make
any recommendations in this report. Also in September 2012, GAO issued a
report detailing the key environmental and public health laws that apply to
unconventional oil and gas development and the exemptions or limitations that
affect how some of these laws can be applied.5
For this report, GAO also
reviewed the environmental and public health requirements governing
unconventional oil and gas development in six states (Colorado, North Dakota,
Ohio, Pennsylvania, Texas and Wyoming). The GAO identified challenges faced
by federal and state agencies in regulating unconventional oil and gas
development. The GAO did not make any recommendations to the EPA.
4
GAO. 2012. Oil and Gas: Information on Shale Resources, Development, and Environmental and Public Health
Risks. Report No. GAO-12-732.
5
GAO. 2012. Unconventional Oil and Gas Development: Key Environmental and Public Health Requirements.
Report No. GAO 12-874.
12. 15-P-0204 7
In May 2014, GAO published a report on the management and oversight of oil
and gas development on federal and Indian lands.6
GAO recommended that the
Bureau of Land Management establish a process to ensure that its rules and
guidance are reviewed and updated, improve coordination of inspection with
states, provide data and direction to allow staff to efficiently locate resources and
wells and determine situations where development may occur without prior
approval, and improve timeliness of agreement reviews. The Bureau of Land
Management agreed with all recommendations.
In June 2014, GAO published a report on its review of the EPA’s oversight of the
Underground Injection Control (UIC) Class II program.7
GAO recommended that
the EPA review emerging risks and program safeguards; improve data collection
and reporting; conduct a rulemaking to incorporate state program requirements
and changes into federal regulations; evaluate and consider alternative processes
for incorporating state program changes into federal regulations; and evaluate and
revise, if necessary, the UIC program guidance on effective oversight. The EPA
agreed with all recommendations except one. While the EPA did not agree to
conduct a rulemaking to incorporate state program requirements into federal
regulations, it agreed to evaluate alternatives to rulemaking.
6
GAO. 2014. Updated Guidance, Increased Coordination, and Comprehensive Data Could Improve BLM’s
Management and Oversight. Report No. GAO-14-238.
7
GAO. 2014. Drinking Water: EPA Program to Protect Underground Sources from Injection of Fluids Associated
with Oil and Gas Production Needs Improvement. Report No. GAO-14-555.
13. 15-P-0204 8
Chapter 2
EPA, States and Other Stakeholders Are Taking
Steps to Manage Impacts to Water Resources,
But Action Is Needed on the Use of Diesel Fuels
in Hydraulic Fracturing, and Chemical Disclosure
Since 2007, the EPA, states and other stakeholders have collectively established
regulations, policy, guidance, industry standards and recommended practices to
manage impacts to water resources from unconventional oil and gas development.
However, our review identified two issues in need of improvement by the EPA.
First, the EPA needs to improve its oversight of permit issuance for
hydraulic fracturing using diesel fuels. Evidence shows that companies have
used diesel fuels during hydraulic fracturing without required EPA or
primacy state UIC Class II permits. The EPA has also not determined
whether primacy states and tribes are following the agency’s interpretive
memorandum for issuing permits when using diesel fuels during hydraulic
fracturing.
Second, the EPA has not developed a plan for responding to public
concerns about chemicals used in hydraulic fracturing. In May 2014,
the EPA initiated a process to seek public and stakeholder comments to
evaluate whether to establish federal chemical disclosure requirements.
However, the agency has not yet developed a plan of action for further
steps in this rulemaking activity.
EPA and States Share Responsibilities for Managing Impacts to
Water Resources
The EPA and states have developed different approaches to address the
environmental challenges of unconventional oil and gas development. Five key
federal laws give the EPA the authority to manage impacts to water resources:
Comprehensive Environmental Response, Compensation and Liability Act
(CERCLA), Clean Water Act (CWA), Safe Drinking Water Act (SDWA),
Resource Conservation and Recovery Act (RCRA), Toxic Substances Control Act
(TSCA).
Many states have their own regulations for the six stages of unconventional oil
and gas development, and they adapt regulations in response to development
activities as needed. Figure 3 summarizes the regulatory tools established by the
EPA and states for use in unconventional oil and gas development.
14. 15-P-0204 9
Figure 3: Summary of EPA, state regulatory and other tools established for use in
unconventional oil and gas development
Source: OIG analysis and summary.
15. 15-P-0204 10
According to a 2014 study conducted by the Ground Water Protection Council: 8
…State regulatory strategies differ in response to unique local
circumstances and characteristics; over time, they evolve to
address public concerns about the safety and environmental impact
of oil and gas development, as well as rapidly changing
technologies, new field discoveries, revised leading operational
practices, internal and external reviews, and regulatory experience.
In 2012, the National Conference of State Legislators reported that 170 bills
pertaining to unconventional oil and gas development were introduced in 29
states, but only 14 of those states enacted legislation (about 48 percent). In 2013,
the number of bills introduced by states increased to more than 225 in 40 states;
23 of those 40 states (approximately 58 percent) enacted legislation in 2013. The
introduced bills focused on aspects of the unconventional oil and gas process that
are solely part of a state’s authority.
In 2009, for example, the state of Arkansas found elevated levels of benzene
(a known carcinogen) and chlorides in groundwater. The presence of the
chemicals in the groundwater was caused by the improper storage and disposal of
hydraulic fracturing wastewater. As a result, the state revoked all land disposal
permits and established new permit requirements for storage pits and wastewater
disposal. The new requirements also included wastewater pre-testing and set new
limits for allowable chloride levels.
In another example, Pennsylvania found that
one company contributed to methane
groundwater contamination because of failure
to properly cement casing at certain wells, as
well as groundwater contamination because of
a diesel fuel spill. In response, the state
developed new regulations that require stricter
containment practices for unconventional
wells. Colorado and Pennsylvania use their
own authorities to require operators to obtain
a stormwater discharge permit during the
construction stage and implement best
management practices to reduce erosion.
Stormwater discharges at oil and gas sites
generally cannot be regulated under the
federal National Pollutant Discharge
Elimination System program.
8
The Ground Water Protection Council is a nonprofit 501(c)6 organization whose members consist of state
groundwater regulatory agencies that come together to mutually work toward the protection of the nation’s
groundwater supplies. The council’s mission is to promote the protection and conservation of groundwater resources
for all beneficial uses.
An unconventional oil and gas
development site. (EPA photo)
16. 15-P-0204 11
Other Stakeholder Initiatives Support Managing Impacts to
Water Resources
Other stakeholders also help to develop measures to address current and potential
impacts to water resources from oil and gas development. Two active
stakeholders are the American Petroleum Institute (API) and the State Review of
Oil & Natural Gas Environmental Regulations Inc. (STRONGER Inc.). Between
2009 and 2011, the API developed and published a set of five guidance
documents that addressed different issues related to hydraulic fracturing
operations (e.g., well construction and integrity, water management, and
mitigating surface impacts). Appendix A contains a partial list of the API
documents.
In 2013, STRONGER Inc. published guidelines the group uses when it evaluates
state regulatory programs. The guidelines address well integrity, baseline
groundwater monitoring protocols, and public disclosure of information about
chemical additives.
According to the EPA and state regulators, oil and gas companies are also
developing new strategies to lessen the impact on water resources by recycling
wastewater, storing wastewater in tanks instead of open pits, and not sending
wastewater to treatment plants lacking the capacity to handle oil and gas waste.
For example, the Arkansas Public Policy Panel reports that the largest producer in
the Fayetteville Shale has been working with environmental groups and Arkansas
state officials to ensure all operators abide by state and local rules governing
unconventional oil and gas activities. This Fayetteville Shale producer also
pledged to recycle 100 percent of its wastewater by 2017.
EPA Needs to Assess Whether Permits Are Issued and Enforced
Properly When Diesel Fuels Are Used in Hydraulic Fracturing Under
the UIC Class II Program
The Energy Policy Act of 2005 (Pub. L 109-58 §322, 119 Stat. 594 (2005))
amended the SDWA (42 U.S.C. 300h (d)) to require permitting of hydraulic
fracturing with diesel fuels.9
As a result of the 2005 amendments to the SDWA
(Pub. L 109-58 §322, 119 Stat. 594 (2005)) and the EPA’s UIC regulations, a UIC
Class II permit must be obtained prior to underground injection of diesel fuels for
hydraulic fracturing.
In February 2014, the EPA issued a memorandum with its interpretation of the
statutory term “diesel fuels,” and guidance containing nonbinding
recommendations for how to permit the use of diesel fuels in hydraulic fracturing.
The memorandum contained the EPA’s interpretation of existing statutory and
regulatory requirements. The agency considers the following five substances to be
9
Diesel fuels contain chemicals, such as benzene, a known carcinogen.
17. 15-P-0204 12
diesel fuels: diesel fuels, No. 2 diesel fuels, No. 2 fuel oil, No. 4 fuel oil, and
kerosene. While the guidance is directed to EPA regional permit writers, the
agency believes the guidance will be useful to primacy states and tribes
implementing the UIC Class II program.10
Since the Energy Policy Act
amended the SDWA in
2005, there is evidence that
the EPA and primacy states
have not been fully
successful in their efforts to
effectively control the use
of diesel fuels for well
stimulation. In 2011, a
congressional investigation
reported that the injection
of over 32 million gallons
of diesel fuels without
permits occurred in 19
states between 2005 and
2009.11
According to the EPA, this congressional investigation prompted the
agency to revise its permitting guidance and issue an interpretive memorandum in
2014. The EPA stated the findings from the congressional investigation informed
the agency that a 2003 Memorandum of Agreement with three well service
companies (BJ Services, Halliburton and Schlumberger) to voluntarily eliminate
diesel fuels from hydraulic fracturing fluids injected directly into underground
sources of drinking water for coal-bed methane production12
was not being
followed.
In 2012, after discovering that four companies may have used substances during
hydraulic fracturing that may have qualified as diesel fuel constituents under the
EPA’s draft permitting guidance, EPA Region 3 issued written notification to the
operators that permits are required under the UIC program.
10
Primacy states and tribes have Class II UIC programs approved by the EPA through Sections 1422 or 1425 of the
SDWA; therefore, states and tribes with approved primacy programs have primary enforcement authority over their
respective underground injection activities. States receive primacy from the EPA, provided that the state has
regulations as stringent as federal regulations, or the state demonstrates its program is effective in protecting
underground sources of drinking waters.
11
U.S. House of Representatives, Committee on Energy & Commerce, Waxman, Markey, and DeGette
Investigation Finds Continued Use of Diesel in Hydraulic Fracturing Fluids (January 2011); and Reps. Waxman,
Markey, and DeGette Report Updated Hydraulic Fracturing Statistics to EPA (October 2011).
12
Methane is generated during coal formation and is contained in the coal microstructure. Typical recovery entails
pumping water out of the coal to allow the gas to escape. Between 2008 and 2013, production of coal bed methane
decreased from 1,966 billion cubic feet to 1,466 billion cubic feet.
An unconventional oil and gas development site. (EPA photo)
18. 15-P-0204 13
More recently, in “Fracking Beyond the Law,”13
the Environmental Integrity
Project reported that between 2010 and 2014 there were hundreds of instances in
which wells were hydraulically fractured with diesel fuels without having a
permit.14
However, in response to the Environmental Integrity Project
investigation, Energy in Depth discusses the uncertainty that exists among
primacy states and the industry regarding the interpretation of diesel fuels and
how the SDWA UIC permitting applies to the use of diesel fuels during hydraulic
fracturing.15
If primacy states and tribes are unclear about the permitting of diesel
fuels, this could cause a disparity in the level of protection provided to the
environment and public health.
The ORD’s analysis of data
from FracFocus,16
the chemical
disclosure database, shows that
diesel fuels (diesel fuels, No. 2
diesel fuels, and kerosene) have
been used during hydraulic
fracturing. However, the ORD’s
timeframe for the FracFocus
analysis is prior to the EPA
OW’s issuance of its
interpretive memorandum and
permitting guidance for diesel
fuels use during hydraulic
fracturing. The ORD did not
analyze whether a UIC Class II
permit had been issued for
these instances.
The EPA says it intends to follow the interpretation of “diesel fuels” in its
implementation, enforcement and oversight of the UIC Class II program. The
EPA’s issuance of a memorandum and guidance is an important management
control. However, the EPA’s implementation of the memorandum and guidance
by the agency’s permit writers, as well as oversight of primacy states and tribes,
will increase assurance that the risks to groundwater resources associated with
diesel fuels hydraulic fracturing are adequately addressed.
13
Environmental Integrity Project. 2014. Fracking Beyond the Law: Despite Industry Denials, Investigation Reveals
Continued Use of Diesel Fuels in Hydraulic Fracturing.
14
Many of the wells noted in the Environmental Integrity Project’s analysis as hydraulically fractured without a
permit were done so with kerosene, which EPA did not clarify as a diesel fuel until after the EPA issued its
interpretive memorandum and revised permitting guidance in February 2014.
15
Energy in Depth is a research, education and public outreach project, launched by the Independent Petroleum
Association of America in 2009, focused on oil and natural gas energy development. See their analysis of the
Environmental Integrity Project’s investigation at http://energyindepth.org/national/eip-diesel-fuel-report-lacks-data-
integrity/.
16
ORD analyzed chemical disclosures reported by the oil and gas industry to FracFocus 1.0 between January 1,
2011, and February 28, 2013.
An example of a pit or impoundment at an
unconventional oil and gas development site.
(EPA photo)
19. 15-P-0204 14
EPA Has Started Responding to the Public’s Concerns About
Chemicals Used in Fracturing Fluid, But Action Plan Is Needed
In 2011, the EPA received a petition from 115 environmental groups to
promulgate rules to require full disclosure of chemicals and mixtures used in oil
and gas exploration and production. In response, the EPA agreed to convene a
stakeholder process to develop an overall approach to require reporting of
chemicals and mixtures used in hydraulic fracturing, while minimizing reporting
burdens and costs, taking advantage of existing information, and avoiding
duplication of efforts. To facilitate public comment, in May 2014, the EPA
published an advance notice of proposed rulemaking identifying key issues for
further discussion and analysis. The advance notice of proposed rulemaking
requested public comments on various aspects of obtaining information on
chemical substances and mixtures used for hydraulic fracturing. Also, the EPA
solicited public comment on “appropriate disclosure to ensure that information
about the chemicals and mixtures used in hydraulic fracturing activities is
provided to the public in a transparent fashion.”
The EPA asked the public to comment on several factors, including: (a) the
overall approach to reporting and disclosure of chemical substances and mixtures
used in hydraulic fracturing, (b) what information companies should report or
disclose, (c) the scope of reporting or disclosure of information, and (d) the
possible use of third parties in data collection and verification.
The comment period closed in September 2014. The EPA received over 260,000
submissions in response to the advance notice of proposed rulemaking. During
our review, the EPA officials said that they will review the comments and
consider next steps. To date, however, the agency has not addressed the
comments or developed a plan of action for the next steps. The EPA’s OCSPP
needs to develop an action plan with a timeline to address the public comments
and determine whether to propose a rule to obtain information on chemical
substances and mixtures used in hydraulic fracturing.
Conclusion
The EPA, states and other stakeholders have made progress developing policies
and regulations to manage potential impacts to water resources from hydraulic
fracturing. Areas for improvement that can be addressed by the EPA include
determining how its memorandum and guidance on the permitting of hydraulic
fracturing using diesel fuels is implemented by primacy states and tribes and
addressing any compliance issues identified. Additionally, the agency should
develop an action plan to address public comments and determine whether there is
a need for a federal chemical disclosure program. Addressing these areas will
support and strengthen program and environmental protection controls for the
growing field of hydraulic fracturing.
20. 15-P-0204 15
Recommendations
We recommend that the Assistant Administrator for Water:
1. Use authorities under the Safe Drinking Water Act to:
a. Determine whether the EPA, primacy states and tribes issue permits
for hydraulic fracturing using diesel fuels as required by statute, the
interpretive memorandum and permitting guidance.
b. Report the results of the determination to the public.
c. Submit an action plan outlining the steps (along with completion
dates) the agency will take if the determination reveals permitting of
hydraulic fracturing using diesel fuels is not occurring in accordance
with statute, the interpretive memorandum and permitting guidance.
We recommend that the Assistant Administrator for Enforcement and Compliance
Assurance:
2. Address compliance issues related to diesel fuel hydraulic fracturing
without a permit and not in accordance with statute, the interpretive
memorandum and permitting guidance.
We recommend that the Assistant Administrator for Chemical Safety and
Pollution Prevention:
3. Establish and publish an action plan with milestone dates that outlines the
steps necessary for determining whether to propose a rule to obtain
information on the chemical substances and mixtures used in hydraulic
fracturing.
Agency Comments and OIG Evaluation
The Deputy Assistant Administrator for Water provided a response to our draft
report on May 28, 2015 (Appendix B), which also included responses from
OCSPP and OECA. OIG staff met with these offices on June 10, 2015, to gather
additional information and discuss the recommendations and the agency
responses.
The agency agreed with Recommendation 1 and provided high-level corrective
actions that are responsive. The agency disagreed with Recommendation 1(c) in its
official response. However, in further discussions, OW staff and managers
indicated they will determine by March 2017 if additional steps are needed based
on the results of the determination in Recommendation 1(a) and develop an action
21. 15-P-0204 16
plan if appropriate. Recommendations 1(a)-(c) are resolved and open, pending
completion of the actions.
The agency disagreed with Recommendation 2 and suggested that this
recommendation was unnecessary because of OECA’s ongoing work under the
agency’s Energy Extraction and Production National Enforcement Initiative,
which focuses on compliance at onshore natural gas extraction and production
facilities. Based on additional information received from OECA, we conclude that
the EPA’s proposed corrective actions meet the intent of this recommendation.
This recommendation is resolved and closed.
The agency agreed with Recommendation 3 and provided high-level corrective
actions that are responsive. The agency’s initial response did not include a
milestone date for completion. However, during later discussions, the agency
provided a milestone date of January 2016 to complete evaluation of the public
comments received as part of the advance notice of proposed rulemaking and to
determine next steps. This recommendation is resolved and open, pending
completion of the actions.
The agency also provided technical comments from OW; OSWER; OCSPP; the
Office of General Counsel; and Regions 3, 4 and 6. Where appropriate, we
incorporated changes to the report based on the agency’s technical comments.
22. 15-P-0204 17
Status of Recommendations and
Potential Monetary Benefits
RECOMMENDATIONS
POTENTIAL MONETARY
BENEFITS (in $000s)
Rec.
No.
Page
No. Subject Status1 Action Official
Planned
Completion
Date
Claimed
Amount
Agreed-To
Amount
1 15 Use authorities under the Safe Drinking Water Act
to:
O Assistant Administrator
for Water
a. Determine whether the EPA, primacy states
and tribes issue permits for hydraulic
fracturing using diesel fuels as required by
statute, the interpretive memorandum and
permitting guidance.
12/31/16
b. Report the results of the determination to
the public.
3/30/17
c. Submit an action plan outlining the steps
(along with completion dates) the agency
will take if the determination reveals
permitting of hydraulic fracturing using
diesel fuels is not occurring in accordance
with statute, the interpretive memorandum
and permitting guidance.
3/30/17
2 15 Address compliance issues related to diesel fuel
hydraulic fracturing without a permit and not in
accordance with statute, the interpretive
memorandum and permitting guidance.
C Assistant Administrator
for Enforcement and
Compliance Assurance
7/16/15
3 15 Establish and publish an action plan with milestone
dates that outlines the steps necessary for
determining whether to propose a rule to obtain
information on chemical substances and mixtures
used in hydraulic fracturing.
O Assistant Administrator for
Chemical Safety and
Pollution Prevention
1/31/16
1 O = Recommendation is open with agreed-to corrective actions pending.
C = Recommendation is closed with all agreed-to actions completed.
U = Recommendation is unresolved with resolution efforts in progress.
23. 15-P-0204 18
Appendix A
Additional Details on Scope and Methodology
Literature Review of Potential Impacts
We reviewed the EPA’s national study plan and progress report on the potential impacts on
hydraulic fracturing. We reviewed GAO reports and published articles about unconventional oil
and gas development, including hydraulic fracturing. We also reviewed reports from industry
sources and environmental groups for information about potential public health and
environmental impacts. A listing of the reports appears below.
Through a literature review, we identified and evaluated the authorities and activities relevant to
the EPA, states and other stakeholders involved with the management of potential health and
environmental impacts. We reviewed the Energy Policy Act of 2005 and the CWA, SDWA,
RCRA, TSCA and CERCLA.
Our review of state regulations focused on the coverage of the regulations, not their quality or
effectiveness. For example, we did not conduct a detailed evaluation of what regulators, permit
writers or enforcers require when they design and implement their program(s).
EPA Guidance and Reports
ORD. 2012. Study of the Potential Impacts of Hydraulic Fracturing on Drinking Water
Resources Progress Report. EPA 601/R-12/011.
ORD. 2011. Plan to Study the Potential Impacts of Hydraulic Fracturing on Drinking
Water Resources. EPA/600/R-11/122.
OW. 2014. Permitting Guidance for Oil and Gas Hydraulic Fracturing Activities Using
Diesel Fuels: Underground Injection Control Program Guidance #84, February 2014.
EPA 816-R-14-001.
OW. 2014. Memorandum from Peter Grevatt, Director, Office of Ground Water and
Drinking Water to Regional Administrators and State and Tribal UIC Program Directors,
Subject: Implementation of the Safe Drinking Water Act’s Existing Underground
Injection Control Program Requirements for Oil and Gas Hydraulic Fracturing Activities
Using Diesel Fuel, February 2014.
Other Documents, Reports and Articles
API. 2011. Guidance Document HF3, Practices for Mitigating Surface Impacts
Associated with Hydraulic Fracturing, First Edition.
API. 2010. Guidance Document HF2, Water Management Related to Hydraulic
Fracturing, First Edition.
API. 2009. Guidance Document HF1, Hydraulic Fracturing Operations-Well
Construction and Integrity Guidelines, First Edition.
24. 15-P-0204 19
API. 2009. Recommended Practice 51R, Environmental Protection for Onshore Oil and
Gas Production Operations and Leases, First Edition.
Bagheri, F. 2013. Regulation of Hydraulic Fracturing of Shale Gas Formations in the
United States. Pepperdine Public Policy Review 6(1).
Behr, P. 2012. Authors of Model Fracking Regulation Find It’s Lonely in the Middle.
Midwest Energy News. October 4, 2012.
Boling, M. 2013. Balancing Environmental, Social and Economic Impacts of Shale Gas
Development Activities. Emerging Issues in Shale Gas Development Webinar
presentation. Yale Center for Environmental Law and Policy, January 23, 2013.
Brady, W.J. and J.P. Crannell. 2012. Hydraulic Fracturing Regulation in the United
States—The Laissez-Faire Approach of the Federal Government and Varying State
Regulations. Vermont Journal of Environmental Law 14(2012-2103): 39-70.
Brown, K. 2014. Environmental Integrity Project Diesel Fuel Report Lacks Data
Integrity. Energy in Depth.
Congressional Letters to former EPA Administrator Lisa Jackson. Results of a
Congressional Investigation into the Use of Diesel Fuel, January 31, 2011, and
October 25, 2011.
Congressional Research Service. 2013. Hydraulic Fracturing and Safe Drinking Water
Act Regulatory Issues. Report No. R41760.
Cricco-Lizza, G. 2012. Hydraulic Fracturing and Cooperative Federalism: Injection
Reality Into Policy Formation. Seton Hall Law Review 42(2): 703-740.
Dennis, J.P. 2013. The Emergence of Natural Gas and the Need for Cooperative
Federalism to Address a Big “Fracking” Problem. San Diego Journal of Climate &
Energy Law 4: 253-275.
Environmental Defense Fund. 2014. Model Regulatory Framework for Hydraulically
Fractured Hydrocarbon Production Wells.
Environmental Integrity Project. 2014. Fracking Beyond the Law: Despite Industry
Denials, Investigation Reveals Continued Use of Diesel Fuels in Hydraulic Fracturing.
Farrell, A., D. Frongillo, K. Kennedy, M. Paque, M. Robertson, and C.M. Smith. 2012.
Fracking: The Roles of Corporate Self Governance and Federal, State and Local Control;
The Environmental Forum 29(6): 44-51.
Fershee, J.P. 2012. The Oil and Gas Evolution: Learning from the Hydraulic Fracturing
Experiences in North Dakota and West Virginia. West Virginia University Law Legal
Studies Research Paper No. 2012-14. Texas Wesleyan Law Review 19: 23-36.
GAO. 2014. Drinking Water: EPA Program to Protect Underground Sources from
Injection of Fluids Associated with Oil and Gas Production Needs Improvement.
Report No. GAO-14-555.
GAO. 2014. Oil and Gas: Updated Guidance, Increased Coordination, and
Comprehensive Data Could Improve BLM’s Management and Oversight.
Report No. GAO-14-238.
GAO. 2012. Oil and Gas: Information on Shale Resources, Development, and
Environmental and Public Health Risks. Report No. GAO-12-732.
GAO. 2012. Unconventional Oil and Gas Development: Key Environmental and
Public Health Requirements. Report No. GAO 12-874.
25. 15-P-0204 20
Gradijan, F. 2012. State Regulation, Litigation, and Hydraulic Fracturing. Environmental
& Energy Law & Policy Journal 7(1): 47-85.
Ground Water Protection Council/ALL Consulting/U.S. Department of Energy. 2009.
Modern Shale Gas Development in the United States: A Primer.
Ground Water Protection Council. 2014. State Oil and Natural Gas Regulations Designed
to Protect Water Resources: 2014 Edition.
Hatzenbuhler, H. and T.J. Centner. 2012. Regulation of Water Pollution from Hydraulic
Fracturing in Horizontally-Drilled Wells in the Marcellus Shale Region, USA.
Water 4(4): 983-994.
Horizon Environmental Services, Inc./Independent Producers Association of America.
2004. Guidance Document: Reasonable and Prudent Practices for Stabilization (RAPPS)
of Oil and Gas Construction Sites.
Investor Environmental Health Network/Interfaith Center on Corporate Responsibility.
2014. Disclosing the Facts 2014: Transparency and Risk in Hydraulic Fracturing
Operations.
Konschnik, K.E. and M.K. Boling. 2014. Shale Gas Development: A Smart Regulation
Framework. Environmental Science & Technology.
Kulander, C.S. 2013. Shale Oil and Gas State Regulatory Issues and Trends.
Case Western Reserve Law Review 63(4): 1101-1141.
Liroff, R. 2011. Extracting the Facts: An Investor Guide to Disclosing Risks from
Hydraulic Fracturing Operations, published by the Investor Environmental Health
Network.
National Conference of State Legislatures. 2013. States Take the Lead on Regulating
Hydraulic Fracturing Overview of 2012 State Legislation.
National Resources Defense Council. 2012. State Hydraulic Fracturing Disclosure Rules
and Enforcement: A Comparison.
Negro, S.E. 2012. Fracking Wars: Federal, State and Local Conflicts over the Regulation
of Natural Gas Activities. Zoning and Planning Law Report 35(2): 1-14.
Rahm, D. 2011. Regulating Hydraulic Fracturing in Shale Gas Plays: The Case of Texas.
Energy Policy 39 (2011): 2974-2981.
Resources for the Future. 2013. The State of State Shale Gas Regulation.
Resources for the Future. 2013. The State of State Shale Gas Regulation: State by State
Tables.
Spence, D.B. 2013. Federalism, Regulatory Lags, and the Political Economy of Energy
Production. University of Pennsylvania Law Review 161: 431-508.
Warner, B. and J. Shapiro. 2012. Fracing and Federalism: A Regulatory Battle of the
Titans. American Political Science Association 2012 Annual Meeting Paper.
Wiseman, H. 2010. Regulatory Adaptation in Fractured Appalachia. Villanova
Environmental Law Journal 21(2): 229-292.
Wiseman, H. and F. Gradijan. 2011. Regulation of Shale Gas Development, Including
Hydraulic Fracturing. University of Tulsa Legal Studies Research Paper No. 2011-11.
26. 15-P-0204 21
Interviews with EPA, States and Other Stakeholders
We interviewed the EPA and states about their respective programs that regulate the different
stages of hydraulic fracturing, any ongoing initiatives to address the potential impacts,
recommended practices observed from industry or implemented by the agency, and their views
on gaps in regulations. We interviewed EPA Regions 3, 6 and 8 based on the following factors:
the amount of unconventional oil and gas development, the current level of federal and state
activity and involvement, and recent news or occurrences of alleged contamination from
hydraulic fracturing. We also selected one state from each region to interview using the same
factors that we used to select the EPA regions. Pennsylvania was selected from Region 3,
Arkansas from Region 6, and Colorado from Region 8. In each state, we met with managers and
staff from the environmental protection and oil and gas agencies or offices. Table A-1 provides a
listing of the organizations interviewed.
Table A-1: Interviews conducted during the OIG evaluation
EPA Office of the Administrator
Office of Chemical Safety and Pollution Prevention
Office of Enforcement and Compliance Assurance
Office of Research and Development
Office of Solid Waste and Emergency Response
Office of Water
Region 3
Region 6
Region 8
State and Basin Arkansas Department of Environmental Quality
Arkansas Department of Natural Resources
Colorado Department of Public Health and the Environment
Colorado Oil and Gas Conservation Commission
Pennsylvania Department of Environmental Protection
Delaware River Basin Commission
Susquehanna River Basin Commission
Industry
nongovernmental
organizations
American Petroleum Institute
Colorado Oil and Gas Association
Independent Producers Association of America
Environmental
nongovernmental
organizations
Earthworks
Environmental Defense Fund
Natural Resources Defense Council
Others STRONGER Inc.
Ground Water Protection Council
Arkansas Public Policy Panel
Professor of Environmental Engineering at the University of Colorado
Source: OIG analysis and summary.
27. 15-P-0204 22
Appendix B
Agency Response to Draft Report
and OIG Evaluation
May 28, 2015
SUBJECT: Response to the Office of Inspector General’s Draft Report/Project No. OPE-
FY14-0018, “Enhanced EPA Oversight and Action Can Further Protect Water
Resources from the Potential Impacts of Hydraulic Fracturing,” dated April 28,
2015
FROM: Kenneth J. Kopocis
Deputy Assistant Administrator
TO: Arthur A. Elkins, Jr.
Inspector General
Thank you for the opportunity to respond to the issues and recommendations in the subject audit
report. The following is a summary of the U.S. Environmental Protection Agency’s overall
response to the draft report, along with specific comments on each of the report’s
recommendations. We have also included an attachment with technical comments on the report.
The EPA agrees with and appreciates the recognition by the Office of Inspector General that the
Agency is taking positive steps to protect public health and the environment in light of a surge in
unconventional oil and gas development. Over the past several years, the EPA has proactively
coordinated initiatives from various program and regional offices involved with energy
extraction activities, including hydraulic fracturing. The Agency also agrees that it needs to
consider the public’s interest in the chemicals and mixtures used in hydraulic fracturing
activities. The EPA is currently evaluating public and stakeholder comments on the Agency’s
2014 Advance Notice of Proposed Rulemaking to obtain information on chemicals and mixtures
used in hydraulic fracturing, and to determine appropriate next steps.
Over the past several years, the EPA has worked with states and the regulated community to
improve understanding of the provisions of the Safe Drinking Water Act and Underground
Injection Control regulations regarding hydraulic fracturing activities. The Agency provided
regulatory clarity on hydraulic fracturing by issuing an interpretive memorandum1
in 2014. In the
memorandum, the EPA explains that any owner or operator who injects diesel fuels as part of
hydraulic fracturing for oil or gas extraction must obtain a UIC Class II permit before injection,
and provides the Agency’s interpretation of the statutory term “diesel fuels” for permitting
purposes. The EPA also provided detailed recommendations to EPA permit writers in its
1
“Implementation of the Safe Drinking Water Act’s Existing Underground Injection Control Program Requirements
for Oil and Gas Hydraulic Fracturing Activities Using Diesel Fuels” (EPA, 2014)
28. 15-P-0204 23
permitting guidance for hydraulic fracturing using diesel fuels.2
The EPA engaged with state and
tribal programs, industry stakeholders and the environmental community throughout the
development and after publication of the UIC permitting guidance and interpretive memorandum
for the use of diesel fuels in hydraulic fracturing.
The EPA coordinates with states where use of diesel fuels in hydraulic fracturing has been
reported and evaluates any information regarding injection of diesel fuels for hydraulic fracturing
on a case-by-case basis. For example, the Environmental Integrity Project issued a report in late
2014, stating that diesel fuels usage had been reported in multiple states through the disclosure
website www.fracfocus.org. In response, EPA regional offices met with the states where
unpermitted diesel fuels usage was reported. As a result of this communication, the state
programs initiated investigations. Upon review of the wells’ final stimulation plans, the states
found that diesel fuels were not actually used in those hydraulic fracturing activities. The reports
of diesel fuel usage in FracFocus were either filing mistakes or were part of initial drilling plans
that were not implemented. With assistance from the EPA, state and tribal governments have
worked to inform well service companies and operators of the UIC permit implications of using
diesel fuels for hydraulic fracturing, and have encouraged the use of safer alternatives.
Based on the EPA’s outreach and evaluation, to date, no states or tribes with permitting authority
for the UIC Class II program have received applications or issued any permits for the use of
diesel fuels in hydraulic fracturing. Likewise, the Agency has not received applications nor
issued any permits for the use of diesel fuels in hydraulic fracturing where the EPA is the
permitting authority. Further, as noted above, investigations of diesel fuels use since the release
of the Agency’s 2014 guidance and memorandum show that no improper permitting of diesel
occurred in these cases.
In 2011, the EPA designated “energy extraction” as one of its six National Enforcement
Initiatives, which includes a focus on unconventional gas extraction and production. The
Initiative’s primary goal is to address impacts to air and water from onshore natural gas
extraction and production activities that may cause or contribute to significant harm to public
health and/or the environment. Compliance issues associated with hydraulic fracturing at natural
gas sites, including the UIC Class II program, fall under the Energy Extraction Initiative.
The EPA will continue to use its oversight authorities under the Safe Drinking Water Act to
work with state primacy programs and EPA regional permit authorities to communicate
requirements and responsibilities regarding the use of diesel fuels during hydraulic fracturing,
and to evaluate reports of unpermitted use of diesel fuels in hydraulic fracturing. If a permit is
warranted, the EPA will ensure that the activity is permitted in a manner that is protective of
underground sources of drinking water.
2
Revised Guidance: Permitting Guidance for Oil and Gas Hydraulic Fracturing Activities Using Diesel Fuels:
Underground Injection Control Program Guidance #84 (EPA, 2014)
29. 15-P-0204 24
AGENCY’S RESPONSE TO REPORT RECOMMENDATIONS
Agreements
No. Recommendation High-Level Intended
Corrective Action(s)
Estimated
Completion by
1(a). Use oversight authorities under
the Safe Drinking Water Act to
determine whether the EPA,
primacy states and tribes issue
permits for the use of diesel fuel
during hydraulic fracturing as
required by statute, the
interpretive memorandum and
permitting guidance.
As part of the EPA UIC
program’s regular oversight
activities with states and
through direct implementation
of the UIC program, the
Agency will continue to
communicate requirements and
responsibilities regarding the
use of diesel fuels during
hydraulic fracturing. Through
these oversight activities, we
will determine whether diesel
fuels are used; and, if so,
whether the EPA, states and
tribes are issuing permits in
accordance with the SDWA and
UIC regulations.
December 2016
1(b). Report the results of the
determination to the public.
The Office of Water will
compile results of regional and
primacy program permitting
activities regarding the use of
diesel fuels in hydraulic
fracturing and post those results
on our public website.
March 2017
3. Establish and publish an action
plan with milestone dates that
outlines the steps necessary for
determining whether to propose a
rule to obtain information on the
chemical substances and mixtures
used in hydraulic fracturing.
In May 2014, the EPA issued
an Advance Notice of Proposed
Rulemaking to seek public and
stakeholder input on how best
to obtain information on
chemicals and mixtures used in
hydraulic fracturing. The EPA
is currently evaluating the
comments to determine
appropriate next steps and our
future plan of action.
To be determined based
on evaluation of public
comments.
OIG Response: The agency’s high-level corrective actions for Recommendations 1(a) and 1(b) are
responsive. Subsequent to a meeting with the agency in June 2015, the EPA provided an estimated
date of January 2016 for Recommendation 3 of when it will complete its evaluation of public comments
and decide whether to continue the rulemaking process.
30. 15-P-0204 25
Disagreements
No. Recommendation High-Level Intended
Corrective Action(s)
Estimated
Completion by
1(c). Submit an action plan outlining
the steps (along with completion
dates) the Agency will take if the
determination reveals permitting
of diesel fuel during hydraulic
fracturing is not occurring in
accordance with statute, the
interpretive memorandum and
permitting guidance.
Outreach and evaluation to date
has shown that neither states,
tribes, nor the EPA have
received applications or issued
any permits for the use of diesel
fuels in hydraulic fracturing.
Since the 2014 guidance and
memo clarified requirements,
the EPA has not seen any
evidence of improper use of
diesel fuels, so an action plan
would be premature without the
results of the determination in
1(a).
The EPA will
determine any next
steps based on the
results of the
determination in
recommendation 1(a).
If significant diesel use
is found and states are
issuing permits, the
EPA may decide to
examine how states are
permitting the use of
diesel fuels in hydraulic
fracturing activities
with respect to the
practices found in the
guidance.
2. Address compliance issues
related to diesel fuel use during
hydraulic fracturing without a
permit and not in accordance with
statute, the interpretive
memorandum and permitting
guidance.
This recommendation is
unnecessary and should be
deleted. The EPA designated
“energy extraction” as a
National Enforcement Initiative
in 2011. The Initiative has the
primary goal of addressing
impacts to air and water from
onshore natural gas extraction
and production activities that
may cause or contribute to
significant harm to public
health and/or the environment.
The Agency is
implementing the
Energy Extraction
National Enforcement
Initiative, which is
focused on onshore
natural gas extraction
and production, and
which encompasses
UIC Class II
compliance issues.
OIG Response: The agency’s high-level corrective actions for Recommendation 1(c) are responsive.
Following a June 2015 meeting to discuss the agency’s comments, the agency provided an estimated
milestone completion date of March 2017 for Recommendation 1(c), based on the results of
Recommendation 1(a), For example, if significant diesel use is found and states are issuing permits,
the EPA may decide to examine how states are permitting the use of diesel fuels in hydraulic fracturing
activities with respect to the recommendations for the EPA permit writers found in the guidance. Should
significant unpermitted diesel use be found, the EPA’s response would depend on considerations such
as its extent and location, as well as the reasons for the unpermitted use.
The OIG disagrees with the agency that Recommendation 2 should be deleted. During the June 2015
exit meeting, agency staff indicated that any compliance issues identified from onshore natural gas and
concurrent oil extraction and production activities would be part of the Energy Extraction and
Production National Enforcement Initiative. Other oil extraction activities would be part of the regions’
core enforcement programs. After receiving and reviewing clarifying information from the agency, we
consider Recommendation 2 as closed upon issuance of the final report.
31. 15-P-0204 26
CONTACT INFORMATION
If you have any questions regarding this response, please contact Ronald Bergman, Acting
Director, Drinking Water Protection Division, Office of Ground Water and Drinking Water at
(202) 565-3823; Andrew Stewart, Acting Director, Special Litigation and Projects Division,
Office of Civil Enforcement/Office of Enforcement and Compliance Assurance at (202) 564-
1463; or Paul Lewis, Chief, Chemical Information and Testing Branch, Office of Pollution
Prevention and Toxics at (202) 564-6738.
cc:
Mike Shapiro
Marilyn Ramos
Dan Engelberg
Johnny Ross
Peter Grevatt
Cynthia Giles
Jim Jones
Mary Hanley
Action Follow-up Coordinators (HQ and RT)
32. 15-P-0204 27
Appendix C
Distribution
Office of the Administrator
Deputy Assistant Administrator for Water
Assistant Administrator for Enforcement and Compliance Assurance
Assistant Administrator for Chemical Safety and Pollution Prevention
Agency Follow-Up Official (the CFO)
Agency Follow-Up Coordinator
General Counsel
Associate Administrator for Congressional and Intergovernmental Relations
Associate Administrator for Public Affairs
Principal Deputy Assistant Administrator for Water
Principal Deputy Assistant Administrator for Enforcement and Compliance Assurance
Deputy Assistant Administrator for Enforcement and Compliance Assurance
Deputy Assistant Administrator for Chemical Safety and Pollution Prevention
Audit Follow-Up Coordinator, Office of Water
Audit Follow-Up Coordinator, Office of Enforcement and Compliance Assurance
Audit Follow-Up Coordinator, Office of Chemical Safety and Pollution Prevention