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Water and Shale Gas Development
Leveraging the US experience in new shale developments
Global development of shale gas resources has
the potential to expand significantly outside
the United States. However, there continue to
be environmental concerns, particularly with
respect to water use. As operators outside the
United States explore shale gas, there are many
lessons that can be taken from the United
States’ experience. This paper highlights areas
that operators of new shale developments
should consider. It also includes an analysis
of considerations for Argentina, China, Poland
and South Africa focusing on water regulation,
water use and management, and water
movements during shale gas development.


1
Contents

1	Introduction	                                                                      4
    Overview of shale gas life cycle activities	                                     8

1.1	 Shale resources outside the United States	                                      9
     In Focus: Shale developments in Argentina, China, Poland and South Africa	     12

2	 Water regulation	                                                                18
2.1	 Regulatory history and the current landscape	                                  19
2.2	 Federal efforts to support regulatory consistency	                             21
2.3	 Key trends	                                                                    22
     In Focus: Water regulation in Argentina, China, Poland and South Africa	       23

3	 Water management	                                                                26
3.1	 Water use and production	                                                      27
     Comparison: Managing produced water: unconventional vs. conventional	          30
3.2	 Water management options	                                                      31
     Primer: Water treatment technologies	                                          33
3.3	 Key trends	                                                                    34
     In Focus: Water use/management in Argentina, China, Poland and South Africa	   35

4	 Water movements	                                                                 42
4.1	 Shale gas development life cycle: logistics requirements	                      43
4.2	 Significance of water transportation	                                          45
4.3	 Rising to the water transportation challenge	                                  45
4.4	 Key trends	                                                                    46
     In Focus: Water movements in Argentina, China, Poland and South Africa	        47
     Concept Overview: Basin-wide water logistics management model	                 49

5	 Lessons learned for new shale developments	                                      52
    In Focus: Implications for Argentina, China, Poland and South Africa	           57

6	 Implications for operators	                                                      60
    Overview of the challenges in the shale gas lifecycle	                          63




                                                                                     2
3
1
Introduction
Natural gas production in the United States has grown significantly
in recent years as improvements in horizontal drilling and hydraulic
fracturing technologies have made it commercially viable to recover
gas trapped in tight formations, such as shale and coal. The United
States is now the number one natural gas producer in the world
and, together with Canada, accounts for more than 25 percent of
global natural gas production.1 Shale gas will play an ever-increasing
role in this resource base and is projected to increase to 49 percent
of total US gas production by 2035, up from 23 percent in 2010,
highlighting the significance of shale gas in the US energy mix in
the future. Lower and less volatile prices for natural gas in the past
two years reflect these new realities, with benefits for American
consumers and the nation’s competitive and strategic interests,
including the revitalization of several domestic industries.2




                                                                         4
In its “2012 Annual Energy Outlook,” the
U.S. Energy Information Administration
                                                            (74.7 trillion cubic feet), and Barnett
                                                            (43.4 trillion cubic feet). Activity in
                                                                                                                             Water regulation
(EIA) referred to the “enormous                             new plays has increased shale gas                                This rapid expansion in shale gas
potential” of shale gas, and according                      production in the United States from                             production has given rise to concerns
to the Institute for Energy Research,                       11 billion cubic meters (bcm) in 2000                            around the impact of operations in
the United States has enough natural                        to 140 bcm in 2010.4 Such production                             areas such as water, road, air quality,
gas to meet domestic electricity                            potential has the ability to change the                          seismic and greenhouse gas emissions
demand for 575 years at current fuel                        nature of the North American energy                              (GHG). The process of hydraulic
demand for generation levels—enough                         mix and according to the National                                fracturing (fracking) in a shale gas well
natural gas to fuel homes heated                            Petroleum Council 2011 study, “Prudent                           requires significant volumes of water
by natural gas in the United States                         Development: Realizing the Potential                             and causes additional greenhouse gas
for 857 years and more natural gas                          of North America’s Abundant Natural                              emissions compared to conventional
than Russia, Iran, Qatar, Saudi Arabia                      Gas and Oil Resources,” the natural                              gas wells. There is already significant
and Turkmenistan combined.3                                 gas resource base could support supply                           resistance to shale gas development
                                                            for five or more decades at current or                           due to these water and emission
As Figure 1 illustrates, US shale gas                       greatly expanded levels of use.5                                 concerns in many parts of the United
reserves are vast and broadly dispersed;                                                                                     States and Western Europe, with France
the EIA estimates that the lower 48                                                                                          and Bulgaria imposing nationwide
states have a total of 482 trillion cubic                                                                                    moratoriums on shale gas production
feet of technically recoverable shale                                                                                        through fracking. The regulation of
gas resources with the largest portions                                                                                      shale gas is an evolving landscape
in the Northeast (63 percent), Gulf                                                                                          as the industry has developed so
Coast (13 percent), and Southwest                                                                                            rapidly that it has often outpaced
regions (10 percent), respectively. The                                                                                      the availability of information for
largest shale gas plays are the Marcellus                                                                                    regulators to develop specific guidance.
(141 trillion cubic feet), Haynesville


Figure 1. US lower 48 states shale gas plays.




                                                Niobrara*
                                      Montana
                                      Thrust                     Bakken***
                                      Belt           Heath**
                                       Cody                                      Williston
                                                                                 Basin
                                              Big Hom Powder River       Gammon
                                Hilliard      Basin   Basin
                                Baxter                            Mowry                                                                              Appalachian
                                Mancos                                                                             Michigan
                                                                                                                                                     Basin
                                           Greater Green                                                           Basin    Antrim
                                                         Park        Niobrara*
                                           River Basin
                                                         Basin                                 Forest                                                              Devonian (Ohio)
                                                                                               City Basin
                                  Uinta Basin                                                                     Illinois                                         Marcellus
                          Manning                                                                                 Basin                                               Utica
                          Canyon                Piceance           Denver
         San Joaquin             Mancos                                          Excello-                                    New
                                                Basin              Basin
         Basin                   Hermosa                                         Mulky Cherokee Platform                     Albany
                Monterey-              Paradox Basin               Pierre
                Temblor                 Lewis                               Woodford
                                              San Juan           Raton    Anadarko               Fayetteville
                                                                 Basin    Basin                                          Chattanooga
                                              Basin                        Ard
    Monterey                                                                   mo               Arkoma Basin Black Warrior
                                                               Palo Duro Bend re Bas                            Basin                  Conasauga
    Santa Maria                                                                      in
                                                               Basin                                                             Valley & Ridge
    Ventura,                                  Avalon-                                                       Floyd-Neal           Province
    Los Angeles                               Bone Spring            Permian     Barnett                    TX-LA-MS
    Basins                                                           Basin         Ft. Worth                Salt Basin
                                              Barnett- Marfa                       Basin                                 Tuscaloosa
                                              Woodford Basin
                                                                                    Eagle          Haynesville-
                                                                                                   Bossier                    Shale plays                    Basins
                                                                                    Ford
                                                                    Pearsall                                                     Current plays            * Mixed shale &
                                                                                   Western                                       Prospective plays            chalk play
                                                                                   Gulf                                                                   ** Mixed shale &
                                                                                                                              Stacked plays                   Iimestone play
                                                                                                                                 Shallowest/youngest      *** Mixed shale &
                                                                                                                                 Intermediate depth/age       tight dolostone-
                                                                                                                                 Deepest/oldest               siltstone-sandstone




Source: Shale Gas and Oil Plays, Lower 48 States, U.S. Energy Information Administration, www.eia.gov.




5
At present, the US shale gas industry
is regulated by a patchwork of existing
                                          Water use and                                  Regarding contamination incidents,
                                                                                         the MIT report stated that “with over
oil and gas regulations on drilling       management                                     20,000 shale wells drilled in the last 10
and well site activities, combined                                                       years, the environmental record of shale
                                          One of the most contentious and widely
with environmental regulations on                                                        gas development has for the most part
                                          publicized issues in shale gas production
water and air management. This loose                                                     been a good one—but it is important
                                          is water management. Shale gas
regulatory landscape is beginning                                                        to recognize the inherent risks and the
                                          production is a highly water-intensive
to change with growing state and                                                         damage that can be caused by just
                                          process, with a typical well requiring
federal attention. In 2010, the U.S.                                                     one poor operation…. In the studies
                                          around 5 million gallons of water to drill
Environmental Protection Agency                                                          surveyed, no incidents are reported
                                          and fracture, depending on the basin
(EPA) launched a four-year field study                                                   which conclusively demonstrate
                                          and geological formation.8 The vast
on the impact of shale gas hydraulic                                                     contamination of shallow water zones
                                          majority of this water is used during the
fracturing and, in 2011, the U.S.                                                        with fracture fluids.”9
                                          fracturing process, with large volumes
Department of Energy received a report
                                          of water pumped into the well with sand        In areas with deep unconventional
by the Secretary of Energy Advisory
                                          and chemicals to facilitate the extraction     formations, such as the Marcellus
Board (SEAB) for shale gas providing
                                          of the gas; the remainder is used in           areas in Appalachia, the shale gas
recommendations on how to reduce
                                          the drilling stage, with water being the       under development is separated from
the environmental impact and improve
                                          major component of the drilling fluids.        freshwater aquifers by thousands of
the safety of shale gas production. In
                                          Relatively small amounts of water are          feet and multiple confining layers. To
addition to these reports, numerous
                                          also used for dust suppression on site,        reach these deep formations where the
smaller studies continue to provide
                                          and for the cleaning and flushing of           fracturing of rock occurs, drilling goes
information to support improvements
                                          drilling equipment. Although increasing        through the shallower areas, with the
in regulation and leading practice.
                                          volumes of water are being recycled and        drilling equipment and production pipe
In 2010, New York issued a temporary      reused, freshwater is still required in high   sealed off using casing and cementing
moratorium on additional shale gas        quantities for the drilling operations as      techniques. A new voluntary chemical
development to allow the state’s          brackish water is more likely to damage        registry (FracFocus) for disclosing
Department of Environmental               the equipment and result in formation          fracturing fluid additives was launched
Conservation (DEC) to finish its          damage that reduces the chance of a            in the spring of 2011 by the Ground
Supplemental Generic Environmental        successful well. The need for freshwater       Water Protection Council (GWPC) and
Impact Statement (SGEIS) on issues        is a growing issue, especially in water-       the Interstate Oil and Gas Compact
surrounding natural gas drilling.         scarce regions and in areas with high          Commission (IOGCC). Texas operators
New York published a Revised Draft        cumulative demand for water, leading           are required by law to use FracFocus.
SGEIS on September 28, 2011, which        to pressure on sources and competition         The IOGCC, comprised of 30 member
was open for public comment until         for water withdrawal permits. The              states in the United States, reported
January 2012.6 There has been no          pressure to increase efficiencies is high      in 2009 that there have been no cases
further movement from the DEC on the      as industry demand for water grows with        where hydraulic fracturing has been
moratorium. In June 2011, Maryland        the development of more wells.                 verified to have contaminated water.
Governor Martin O’Malley issued an                                                       A key objective of the EPA’s ongoing
                                          Water contamination is another
order calling for a three-year study of                                                  study is to better understand the
                                          aspect of shale gas production that
the economic and environmental effects                                                   full life-cycle relationship between
                                          has generated significant resistance
of drilling the Marcellus Shale before                                                   hydraulic fracturing and drinking
                                          to current shale production processes.
permits to drill can be issued. And in                                                   water and groundwater resources.10
                                          According to the Massachusetts
August 2011, New Jersey Governor
                                          Institute of Technology (MIT) 2011 Gas         The movement and disposal of produced
Chris Christie placed a one-year
                                          report, which reviewed three studies           water from fractured wells is also a
moratorium on hydraulic fracturing so
                                          of publicly reported incidents related         part of the debate on the environmental
that the Department of Environmental
                                          to gas well drilling, there were only 43       impact of shale gas production.
Protection “can further evaluate the
                                          “widely reported” water contamination          After fracturing, each well returns a
potential environmental impacts of
                                          incidents related to gas well drilling         percentage of the injected fracture
this practice in New Jersey, as well
                                          in the past decade (to 2010) during            fluid volume over its lifetime; this water
as evaluate the findings of ongoing
                                          which time, there were about 20,000            is heavily polluted, creating a risk of
federal studies.”7 (Note, however, that
                                          shale gas wells drilled with almost all        groundwater contamination upon its
no hydraulic fracturing operations were
                                          of them being hydraulically fractured.         return to the surface if not correctly
taking place in New Jersey when the
                                          Of these, 48 percent of the incidents          contained and treated. Concerns around
moratorium was issued.) Several other
                                          involved groundwater contamination             such risks have led to the moratorium
states, however—including Wyoming,
                                          by natural gas or drilling fluids; 33          on shale gas development in New
Pennsylvania, Arkansas, Colorado,
                                          percent involved on-site surface spills;       York’s Marcellus Shale. In addition to
Louisiana and Texas—have passed new
                                          10 percent involved water withdrawal           the nature of the produced water, the
legislation or regulations in response
                                          and air quality issues, and blowouts; and,     growing volumes of wastewater are
to the increased activity associated
                                          the remaining 9 percent involved off-site      increasing demand for efficiencies
with natural gas development.
                                          disposal issues (see Figure 2).                in water treatment technologies to
                                                                                         improve water reuse and


                                                                                                                                    6
recycling. Innovative water management      can represent up to 80 percent of                     Operational performance
solutions are required to address the       logistics activity. Research into water-              Better monitoring and planning
long-term sustainability of water use in    free fracking, on-site treatment and                  capabilities will reduce bottlenecks
shale gas production.                       disposal and assessment of alternative                and smooth delivery into a site (e.g.,
                                            modes of transport are all being                      managed slot windows, dynamic
Water movements                             pursued, but are currently unable to
                                            generate significant impact. Within the
                                                                                                  re-routing to avoid congestion).
                                                                                                  Availability of accurate operational data
The volume of equipment, materials          boundaries of current capabilities, the               can allow operators to identify issues
and water required to support shale         adoption and integration of logistics                 and enable continuous improvement
gas operations presents a significant       leading practice provide the most                     in both drilling and transportation.
logistics challenge. Given the remote       straightforward, technology-ready                     Logistics costs can be reduced through
nature of most locations and the            approach to reducing transport cost                   efficiency gains (e.g., reduction of
frequent operations movements across        and regulatory and HSSE exposure.                     waiting time) and automated processes
highly dispersed and numerous well site                                                           can reduce administrative costs. Past
locations, flexibility is required in the   Improvements in water movements
                                                                                                  implementations have shown that
transport model making road transport       also have an impact on other aspects
                                                                                                  consistent adoption of logistics leading
the logistics model of choice for most      of shale operations, specifically HSSE
                                                                                                  practices can deliver up to 45 percent
environments. While pipeline and rail       exposure, operational performance
                                                                                                  reduction in transport costs.
movements can be effective for long-        and compliance.
distance or point-to-point movements,                                                             Compliance
the final distribution to and from the      HSSE exposure
                                                                                                  The use of a water inventory monitoring
well pad is almost exclusively managed      Improved transport planning processes
                                                                                                  tool can support water management
via road transport. Road transport          and systems can reduce the number
                                                                                                  regulatory compliance through visibility
volumes and types vary significantly        of truck moves, while telematics
                                                                                                  of water draw, usage and movements.
depending on the operational phase of       systems can provide real-time visibility
                                                                                                  Automated end-to-end processes and
the project, with the majority of demand    of truck movements and driver
                                                                                                  systems enable accurate and rapid
during the fracking and completion          performance, supporting reduction
                                                                                                  data capture, storage and reporting.
phases, which can account for 60–85         in wait times, less congestion and
                                                                                                  A cross-operator, basin-wide solution
percent of total transport volumes.         better driver HSSE compliance.
                                                                                                  would also confirm consistent basin-
Some large operations are required to
                                                                                                  wide reporting standards across
source, plan and manage up to 300
                                                                                                  multiple sites and operators.
truck movements per day within a
single basin, which is the equivalent of
a pan-regional transport operation in
many other sectors. This concentration
creates significant challenges, with
on-site congestion causing issues to the    Figure 2. Chart of water contamination incidents related to gas well drilling.
operations teams and local residents,
and leading to significant cost exposure
to an already marginal cost operation.
                                                                9%
The high volume and intensity of
road transport associated with shale                  10%
gas production present some unique
challenges for operators. A shortage
of transport operators with sufficient                                            48%
knowledge, difficulties in tracking and
optimizing delivery schedules, reducing                                                                      Groundwater contamination
                                                       33%
burden on strained road infrastructure,                                                                      On-site surface spills
and a lack of standardized reporting
                                                                                                             Water withdrawal and air quality issues,
and regulatory data can all lead to                                                                          and blowouts
high costs, Health Safety Security                                                                           Off-site disposal issues
Environment (HSSE) exposure, and
regulatory compliance issues. With
up to 30 percent of completion costs
                                            Source: Massachusetts Institute of Technology 2011 Gas Report.
related to transportation, operators
are exploring different options to
reduce transport activity, with a
key focus on water hauling, which




7
Overview of shale gas life cycle activities
Civil/site prep                              Completion/fracking
Forest clearing, excavation, building        As drilling is completed, multiple
of access routes, constructing and           layers of metal casing and cement are
installing wells pads and preparing          placed around the wellbore. After the
site for drilling activities.                well is completed, a fluid composed of
                                             water, sand and chemicals is injected
Drilling                                     under high pressure to crack the shale,
                                             increasing the permeability of the rock
Natural gas will not readily flow to         and easing the flow of natural gas.
vertical wells because of the low
permeability of shales. This can be
overcome by drilling horizontal wells
                                             Flowback
where the drill bit is steered from          A portion of the fracturing fluid will
its downward trajectory to follow a          return through the well to the surface
horizontal trajectory for one to two         due to the subsurface pressures. The
kilometers, thereby exposing the             volume of fluid will steadily reduce and
wellbore to as much of the reservoir         be replaced by natural gas production.
as possible.
                                             Production
                                             The fissures created in the fracking
                                             process are held open by the sand
                                             particles so that natural gas from within
                                             the shale can flow up through the
                                             well. Once released through the well,
                                             the natural gas is captured, stored and
                                             transported away for processing.




Figure 3. Shale gas lifecycle.


              Civil/site prep       Drilling                Completion/             Flowback            Production
              Build access          Drill vertical and      fracking                Capture, store      Capture, store
              roads, construct      horizontal wells        Complete wells          and treat           and transport gas
              and install well                              with steel and          returned fracking
              pads, prepare site                            cement casings          fluids
              for drilling                                  Release gas
                                                            through
                                                            hydro-fracking


                                                                                                             Decommission

Typical
                     60 days             15-60 days              15-30 days               20 days           5–40 years
timelines


Source: Accenture 2012.




                                                                                                                            8
1.1
                                                    cubic feet for the United States and              detailed shale gas resource assessments
                                                    the other 32 countries assessed. To               by the countries themselves, with many
                                                    put this shale gas resource estimate              of these assessments being assisted by
                                                    in context, the world’s technically               a number of US federal agencies under
Shale resources                                     recoverable gas resources are roughly
                                                    16,000 trillion cubic feet, largely
                                                                                                      the auspices of the Global Shale Gas
                                                                                                      Initiative (GSGI) that was launched in
outside the                                         excluding shale gas.11 Thus, adding
                                                    the identified shale gas resources to
                                                                                                      April 2010.

United States                                       other gas resources increases total
                                                    world technically recoverable gas
                                                                                                      At a country level, there are two country
                                                                                                      groupings that emerge where shale gas
Although estimates are likely to change             resources by more than 40 percent                 development appears most attractive.
over time as additional information                 to 22,600 trillion cubic feet.12                  The first group consists of countries
becomes available, the international                                                                  that are currently highly dependent
shale gas resource base is currently                The estimates of technically recoverable          upon natural gas imports, have at least
considered to be significant. The initial           shale gas resources for the 32 countries          some gas production infrastructure, and
estimate of technically recoverable                 outside the United States represent               their estimated shale gas resources are
shale gas resources in the 32 countries             a moderately conservative “risked”                substantial relative to their current gas
examined in the EIA’s “World Shale                  resource for the basins reviewed. Given           consumption. For these countries, shale
Gas Resources” study is 5,760 trillion              the relatively sparse data currently              gas development could significantly
cubic feet (see Figure 4). Adding the US            available and the differences in                  alter their future gas balance, which
estimate of the shale gas technically               approaches employed to determine the              may motivate development. Examples
recoverable resources of 862 trillion               resources, these estimates are quite              of countries in this group include
cubic feet results in a total shale                 uncertain. At the current time, there             Chile, France, Morocco, Poland, South
resource base estimate of 6,622 trillion            are efforts under way to develop more             Africa, Turkey and Ukraine. In addition,



Figure 4. Map of 48 major shale gas basins in 32 countries.




    Legend
      Assessed Basins with Resource Estimate
      Assessed Basins without Resource Estimate
      Countries within Scope of EIA Report
      Countries outside Scope of EIA Report




Source: “World Shale Gas Resources: An Initial Assessment of 14 Regions Outside the United States,”
U.S. Energy Information Administration, 2011, www.cia.gov.




9
South Africa’s shale gas resource
endowment is interesting as it may
                                              Argentina’s biggest energy company,
                                              YPF, has found unconventional shale oil
                                                                                            China – Sichuan and
be attractive to use this natural gas         and natural gas in Mendoza province,          Tarim Basin
as a feedstock to its existing gas-to-        confirming the extension of the massive
                                                                                            In 2011, the EIA estimated that
liquids (GTL), coal-to-liquids (CTL)          Vaca Muerta area. YPF said exploration
                                                                                            China had 1,275 trillion cubic feet
plants and combined cycle gas turbine         at the Payun Oeste and Valle del Rio
                                                                                            of technically recoverable shale
(CCGT) currently running on diesel.           Grande blocks pointed to an estimated
                                                                                            gas. Since then a geological survey
                                              one billion barrels of oil equivalent
The second group consists of those                                                          led by China Ministry of Land and
                                              (boe) in unconventional oil and gas in
countries where the shale gas resource                                                      Resources (MLR) confirmed a total of
                                              Mendoza. Energy resources and reserves
estimate is large (e.g., above 200 trillion                                                 882 trillion cubic feet of technically
                                              in the province, which border the Andes
cubic feet) and there already exists                                                        recoverable shale gas, excluding Tibet.
                                              mountain range in western Argentina,
a significant natural gas production                                                        The Sichuan Basin, located in south-
                                              currently stand at 685 million boe.
infrastructure for internal use or for                                                      central China, covers a large 211,000
export. In addition to the United States,                                                   km2 and accounts for 40 percent of
notable examples of this group include        Canada – Horn River                           the country’s shale resources.13
Algeria, Argentina, Australia, Brazil,        Shale Basin                                   China hopes to produce between 60
Canada, China, Libya and Mexico.
                                              British Columbia’s Horn River Shale           billion and 100 billion cubic meters a
Existing infrastructure would aid in
                                              Formation is the largest shale gas            year by 2020—an objective that some
the timely conversion of the resource
                                              field in Canada and part of Canadian          analysts are skeptical can be achieved.
into production, but could also lead
                                              deposits that amount to as much               Royal Dutch Shell has recently signed
to competition with other natural gas
                                              as 250 trillion cubic feet of natural         the first production-sharing contract to
supply sources. For an individual country
                                              gas. Since 2008, a total of nine              explore, develop and produce shale gas
the situation could be more complex.
                                              companies has ventured into the Horn          in China, a move that fits in with China’s
Outside the United States there               River market, including ExxonMobil,           overall strategy to bring technical
are certain shale plays that could            Apache, Devon Energy and Encana.              and operational know-how to the
change the energy security of the                                                           development of its untapped reserves
countries in which they are located.          While large-scale commercial                  of the unconventional fuel. CNOOC
These include the following:                  production of shale gas has not yet been      Ltd., China’s biggest offshore energy
                                              achieved in Canada, many companies            producer, plans to develop new fields,
                                              are now exploring for and developing          acquire overseas assets and develop
Argentina – The Neuquén                       shale gas resources in Alberta, British       unconventional resources such as shale
Basin                                         Columbia, Quebec and New Brunswick.
                                              Development of shale gas, and other
                                                                                            gas to meet output targets. The country
                                                                                            is “determined” to learn shale-gas
According to the EIA, Argentina has           unconventional resources, will help           technology from its partners and deploy
774 trillion cubic feet of technically        confirm supplies of natural gas               it in China, holder of the world’s largest
recoverable shale gas, making it the          are available to the growing North            deposits of the fuel, Chairman Wang
world’s third‐largest player in the shale     American natural gas market for many          Yilin has stated.14
game behind the United States and             decades. Encana, Canada’s largest
China. Located on Argentina’s border
with Chile, the 137,000 km² Neuquén
                                              natural gas producer and one of the
                                              biggest in North America, is looking
                                                                                            Poland – Baltic-Podlasie-
Basin is the South American nation’s          for a single partner for a package of         Lublin Basins
largest source of hydrocarbons, holding       assets that could include positions in
35 percent of the country’s oil reserves                                                    The EIA has assessed that Eastern
                                              the Collingwood Shale, the Tuscaloosa
and 47 percent of its gas reserves.                                                         Europe may hold as much as 250 trillion
                                              Marine Shale, the Mississippi Lime
Within the basin, the Vaca Muerta Shale                                                     cubic feet of shale gas, with Poland’s
                                              and the Eaglebine Shale in the United
formation may hold as much as 240                                                           Silurian Shale plays boasting 187 trillion
                                              States. All have natural gas liquids or oil
trillion cubic feet of exploitable gas.                                                     cubic feet of that total. The Russia
                                              potential and are in the early stages of
ExxonMobil has recently entered into                                                        Federation currently supplies 25 percent
                                              exploration and development.
an agreement with Americas Petrogas                                                         of Europe’s natural gas, and Poland’s
for the Exploration and Production                                                          potential shale resources could reduce
(E&P) farm‐out of 163,500 gross acres                                                       Europe’s dependence on natural gas
of its Neuquén-based Los Toldos blocks.                                                     imports. Whether these reserves will
This area is also being explored and                                                        be developed is still to be seen, but the
developed by Shell, Apache, EOG, Total                                                      38-million-strong Slavic nation will have
and Wintershall, among others.                                                              a strong claim to energy independence
                                                                                            as its projected reserves equate to 300
                                                                                            years of domestic consumption.




                                                                                                                                      10
Several companies including ExxonMobil
and Chevron have begun to drill test
                                            Other regions
wells and more than 100 companies           India’s Oil and Natural Gas Corp (ONGC)
rushed to grab a share of Poland’s gas      and US oil company ConocoPhillips have
concessions. Some of those early tests      signed an agreement to explore and
produced decent flows, but others           develop shale gas assets and look for
showed quite different results from         opportunities in deepwater exploration.
wells drilled into US shale deposits.       The agreement is for sharing technical
ExxonMobil said its two test wells did      knowledge on shale gas explorations,
not justify commercial production.          but ONGC and ConocoPhillips could
ExxonMobil said in January 2012 that        also jointly bid for shale gas assets
two exploratory wells failed to flow        overseas. India may still launch the first
enough gas to make development              shale gas licensing round by the end
profitable. In June 2012, ExxonMobil        of 2013 even though the government
announced it would end its search for       pushed back plans to unveil a policy
shale gas in Poland.15 Flow rates at        on exploration of unconventional
sites drilled by 3Legs Resources Plc. and   gas resources trapped in rocks.
BNK Petroleum Inc. were not as high as
similar wells in the United States.

South Africa – The Karoo
Supergroup
Known by paleontologists as one of the
world’s most fertile hunting grounds for
fossil remains, the Karoo Supergroup
(KSG) might also be one of the most
plentiful sources of shale gas in the
world. The KSG is constituted mainly of
shales and sandstones and spans across
88,000 km², underlying more than
two-thirds of the entire area of South
Africa and containing an estimated
485 trillion cubic feet of technically
recoverable gas. Shale gas could reduce
the country’s dependence on coal to
fuel 85 percent of its energy needs.




11
In Focus
Shale developments in Argentina, China, Poland and
South Africa


A key objective of this report is to
highlight the trends and lessons learned
                                                               Argentina                                           in 2011 due to decreasing exploration
                                                                                                                   activities in the past decade.17
from shale development in the United                           Argentina is the largest natural gas                Meanwhile, the demand for natural gas
States that can be applied to shale                            producer in South America with 1,416                in Argentina has increased in recent
developments in other geographies. To                          billion cubic feet (bcf) annual output in           years in line with economic growth,
emphasize this point, we will present                          2010.16 Natural gas prices in Argentina             and the country has had to rely on gas
four case studies in this report of four                       were kept low by the government                     imports from neighboring Bolivia and
very different shale developments:                             since the economic crisis in 2002.                  Liquefied Natural Gas (LNG) shipments.
Argentina, China, Poland and South                             As a result natural gas production                  Shale gas has brought new hope for
Africa. The following is a detailed                            dropped almost 15 percent from its                  addressing energy demands. Based
description of these shale developments.                       peak of 1,628 bcf and natural gas                   on an EIA estimation, Argentina has
                                                               tested reserves dropped 50 percent                  774 trillion cubic feet of technically
                                                               to only 13.4 trillion cubic feet                    recoverable shale gas, which is almost
                                                                                                                   60 times that of its current tested
                                                                                                                   natural gas reserves.18 To encourage
Figure 5. Neuquén Basin Shale Gas Prospective Area and Basemap.                                                    domestic natural gas exploration
                                                                                                                   and production, the Argentinian
                                                                                                                   government introduced its “Gas
                                                                                        Legend                     Plus” program in 2008 to allow new
                                                                                          Neuquén Basin            discovered unconventional gas to be
                                                                                          Thrust Fault             sold at a higher price based on cost
                                                                                          City
                                                                                          Water
                                                                                                                   and reasonable profit.19 This incentive
                                                                                                                   program allows approved companies to
                                                                          Cu




                                                                                                                   charge up to $5/thousand cubic feet
                                                                            yo




                                                                                                                   (mcf) for their natural gas production.
                                                                                Ba
                                                                                sin




                                                                                                                   The Neuquén Basin covers the Neuquén
                                                                                                                   province and parts of Mendoza, Rio
                                                                                                                   Negro and La Pampa provinces in
                                                                                                                   central-west of Argentina, holding 407
                                     lt




                                                                                                                   trillion cubic feet of the country’s 774
                              Agrid Fold & Thrust Be




                                                                                                                   trillion cubic feet estimated resources.
            Andes Mountains




                                                                                                                   This basin largely overlaps with existing
                                                                                                                   natural gas production regions. The
                                                                                                                   Neuquén province alone currently
                                                                                                                   produces almost half of the nation’s
                                                                                                                   conventional gas.20 The geological
                                                                                                                   formation of the Neuquén Basin is very
                                                       Productive Area                                             similar to major US shales with the
                                                       Extensional Structures                                      average depth of the 204 trillion cubic
                                                                                                                   feet of recoverable shale gas in the Vaca
                                                                                                                   Muerta formation within the Neuquén
                                                                                                                   Basin at 2,400 meters. Geological
                                                                                                                   features and existing local natural gas
                                                                                                  Colorado Basin




                                                       Neuquén
                                       Huincul Arch / n                                                            infrastructure make future development
                                       Dorsal de Neuque
                                                                                                                   in the Neuquén Basin very promising.
                                                                        h
                                                                    Nort onian
                                                                                                                   Other basins including the San Jorge
                                                                         g                                         Basin and the Austral Magallanes Basin
                                                                     Pata f                                        have 95 trillion cubic feet and 172
                                                                           i
                                                                      Mass                                         trillion cubic feet reserves, respectively.
Source: “World Shale Gas Resources: An Initial Assessment of 14 Regions Outside the United States,”
U.S. Energy Information Administration, 2011, www.eia.gov.

                                                                                                                                                           12
Many shale operators have started
exploration activities in Argentina.
                                                    China                                           Data from a recent Ministry of Land and
                                                                                                    Resources (MLR)-led geological survey
Apache partnered with YPF, previously               The recent success of shale gas                 shows China has 882 trillion cubic
controlled by Repsol, but was                       development in the United States, as            feet of technically recoverable shale
renationalized in April 2012 by the                 well as a domestic push to reshape the          gas resources, a lower figure than the
Argentinian government, to explore                  energy structure to reduce dependence           EIA’s estimate. Figure 6 illustrates shale
unconventional resources including                  on coal, has put shale gas under the            gas distribution in China. The Sichuan
shale gas in the Neuquén and Austral                spotlight in China. In December 2011,           Basin in the Upper Yangzi region and
Basins. Apache has been awarded                     the China State Council approved shale          southwest China (a region covering
1.6 million gross acres (3,642 km2)                 gas as a new type of natural resource           Sichuan, Chongqing, Yunnan, Guizhou
in the Neuquén Basin for shale gas                  that will be managed separately from            and Guangxi provinces) has 10 trillion
development and the company drilled                 conventional gas.23 In March 2012,              cubic meters (350 trillion cubic feet) of
the first horizontal multi-fracture shale           the National Development and Reform             shale gas, which equates to 40 percent
gas well in South America in 2011.21 In             Commission (NDRC) issued its Shale Gas          of total national reserves. Unlike US
May 2011, one of Apache’s horizontal                Development Plan (2011–2015)24 that             formations, where most shale seams
wells in the Neuquén Basin tested at                sets clear targets for the industry by          are at depths of less than 3,000 meters
a rate of 7 million cubic feet (mmcf)/              2015 and 2020. However, the shale gas           (with the exception of the Haynesville
day. Canadian firm America Petrogas                 industry in China remains at an early           Shale), the shale-bearing layers in many
joined with ExxonMobil to explore 660               stage with most activity in exploration         Chinese formations are between 3,000
km2 of blocks in the Neuquén Basin.                 and drilling of test wells.                     to 5,000 meters deep. Therefore, US
The company drilled a test well together                                                            shale gas development models cannot
with ExxonMobil and the result is                                                                   be simply replicated in China and the
under evaluation.22 With undergoing                                                                 complex geological conditions will
exploration activities, EIA’s original                                                              increase the cost of drilling wells.
estimation on Argentina’s shale gas
potential is waiting to be confirmed
with new data from the operators.

Figure 6. Shale gas distribution in China.




                         Northwest zone
                         15%
                                                                                             North and
                                                                                             Northeast zone
                                                                                             26%



                                                      Upper Yangzi &
                                                      Southwest zone                                 Lower Yangzi &
                                                      40%                                            Southeast zone
                                                                  Sichuan
                                                                                    Chongqing        19%


                                                                               Guizhou
                                                              Yunnan
                                                                                   Guangxi




Source: China Ministry of Land and Resources, People’s Republic of China, www.mlr.gov.cn.



13
The shale gas industry has, for the          China CBM has proposed to start              The average depth of shale formations
first time, been put in a strategically      exploring three regions in Shanxi            in Poland is from 2,500 to 3,800 meters,
important position in the government’s       province.26 In the first round of national   which is up to twice as deep as the
12th five-year energy plan (2011–2015).      shale gas exploration rights auctions,       average depth of 2,000 meters observed
In addition, the Shale Gas Development       organized by the MLR, Sinopec and            in the Marcellus Shale.29 30 Variations
Plan (2011–2015) states that by 2015,        Henan Coal Bed Methane Co won the            have been observed among different
the government aims to complete an           bid. A second round of auctions is due       basins, with 1,000–4,500 meters depth
investigation on shale gas reserves and      to start in late 2012.                       for the Baltic Basin, 1,000–3,500 meters
their national distribution. The plan also                                                depth for the Lublin Basin, and 4,000–
estimates annual production reaching         International oil majors are actively        5,000 meters depth for the Podlasie
6.5 billion cubic meters (230 billion        partnering with NOCs to enter China’s        Basin (near Warsaw). These geological
cubic feet) and confirmed technically        shale gas market. CNPC and Statoil           characteristics could likely result in
recoverable reserves reaching 600            began test drilling in China in early        higher drilling costs, linked to higher
billion cubic meters (21 trillion            2011. Sinopec has teamed with BP to          demands on water in the drilling stages.
cubic feet) by 2015. With almost no          explore shale gas in Guizhou in 2010,
commercial production today, reaching        joined forces with ExxonMobil to             Shale gas activities in Poland started
such targets will require significant        conduct geological research in Sichuan,      in 2007; by September 2011, a total of
investment at each stage of the value        and is also working with Chevron in          101 shale gas exploration authorizations
chain in the next couple of years, as        Guizhou to carry out risk assessments.       had been granted and another 26
well as technology development and           Shell is the most active international oil   applications were being processed.31
collaboration between national oil           company (IOC) in China, and has already      International oil majors have entered
companies (NOCs) and experienced shale       signed the first production-sharing          the Polish market in the form of joint
gas operators from other countries.          contract with CNPC to explore, develop       ventures. 3Legs Resources formed
                                             and produce shale gas.                       a joint venture with ConocoPhillips
NOCs and state-owned entities have                                                        to evaluate shale gas potential in
been the first to be allowed to explore
and develop shale gas resources in
                                             Poland                                       the Baltic Basin and drilled the first
                                                                                          exploration well in Poland. PKN and
China. So far most activities are in         Poland has the most significant shale        PGNiG are the most active Polish
exploration, with only very limited          gas potential in Europe. Poland’s            operators. As of August 2011, based
commercial production. The three major       shale gas resources are located in           on square kilometers covered, the top
NOCs (CNPC, Sinopec and CNOOC),              the Baltic-Podlasie-Lublin Basins (see       10 concession holders in Poland were:
Yangchang Petroleum Group, and China         Figure 7), creating a strip across the       (1) San Leon Energy with 14 licenses
United Coalbed Methane Co (China             country from northwest to southeast.         covering 11,520 km2, (2) ExxonMobil, (3)
CBM) are actively involved in shale gas      The EIA estimates 187 trillion cubic         PKN Orlen, (4) Chevron, (5) Marathon
exploration. By the end of 2011, CNPC        feet of technically recoverable shale        Oil & Gas, (6) BNK Petroleum, (7)
had drilled 11 test wells in southern        gas resources in the Baltic-Lublin-          3Legs Resources, (8) Nexen, (9)
Sichuan and northern Yunnan, four of         Podlasie Basins of Poland; of those,         ConocoPhillips and (10) Petrolivest.32
which had exhibited industrial-level         120 trillion cubic feet are in the
gas flow. Sinopec has its exploration        Baltic Basin.27 A report released in
activities mainly in Guizhou, Anhui          March 2012 by the Polish Geological
Sichuan and Chongqing. In Chongqing,         Institute was able to confirm 67 trillion
Sinopec has shale gas production in          cubic feet of technical recoverable
Liangping County with an estimated           shale gas resources in these three
annual output 300–500 million cubic          basins after a 16-month research
meters (10–18 billion cubic feet).25         project with external support from
Yanchang Group is very active in its         the U.S. Geological Survey.28 	
traditional territory of Shannxi province
and has successfully fracked the first
horizontal well in China.




                                                                                                                                14
With authorizations received, current               transforming the coal-based electricity
industry activities have moved onto                 generation sector. A consortium formed
drilling of testing wells. 22 exploration           with state-owned power utilities
wells were started in 2011 and 13 wells             companies and PGNiG will co-finance
were completed by February 2012. 14                 and co-develop shale exploration along
new exploration wells were planned                  the Baltic coast. Utilities will finance
for late 2012 and as many as 123 wells              exploration activities in exchange
are planned by 2017.33 So far, state-               for future gas supplies in off-take
owned PGNiG, 3Legs Resources, BNK,                  agreements.35 Poland’s Treasury Minister
Talisman Energy, Marathon Oil and                   said the country may be producing one
ExxonMobil have all completed their                 billion cubic meters (35 billion cubic
first batch test wells. ExxonMobil, BNK             feet) of shale gas per year by 2014.36
and 3Legs released rather disappointing
results, stating that the gas flows in
their testing wells are lower than similar
prospects in US shale and commercial
production cannot be justified.34
Despite this negative news, the Polish
government strongly believes shale
gas would help to reduce the nation’s
energy dependency on Russia and cut
greenhouse gas (GHG) emissions through




Figure 7. Map of Poland’s shale gas basin.




                                                                                Kaliningrad
                                                  Gdansk


                                                      Baltic Basin
                     Szczecin
                                                                             Mazury - Belarus High
                                      Bydgoszcz                                                Bialystok
     Berlin
                                         Poznan
                                                                                      Warsaw     Podlasie Basin
                                                                                                            Brest
                                                                     Lodz

                                                                                              Lublin

     Legend                                                     Czestochowa                 Lublin Basin
        Trans-European Fault Zone
        Faults
        National Capitals                                      Katowice
        Major Cities                                                      Krakow
                                                     Ostrava
     Poland Shale Basins
     Prospectivity
        Non-Prospective
        Prospective



Source: World Shale Gas Resources: An Initial Assessment of 14 Regions Outside the United States, U.S.
Energy Information Administration, 2011, www.eia.gov.




15
South Africa                                        Shale.40 However, the Karoo Basin
                                                    contains significant areas of volcanic
                                                                                                         South African regulations, TCPs allow
                                                                                                         no more than desktop research; with
South African electricity generation                intrusions that impact the quality                   further applications required to obtain
is currently heavily coal-based. The                of the shale gas resources, limit the                authorization for physical exploration
Department of Energy intends to                     use of seismic imaging and increase                  activities. However, the application
have 9 percent of energy from open                  the risk of shale gas exploration.                   to convert these TCPs into physical
cycle gas turbines by 2030 and shale                                                                     exploration licenses was suspended
gas could help to reach this target.37              A number of companies have started                   over a year to allow the government to
According to the EIA, South Africa has              pursuing shale gas development in the                conduct policy and technical reviews
an estimated 485 trillion cubic feet                Karoo Basin by obtaining Technical                   before final decisions.42 On September
of technically recoverable shale gas                Cooperation Permits (TCPs) from the                  7, 2012, the South Africa government
located in the Karoo Basin (see map,                South Africa Petroleum Agency (see                   accepted the recommendations from
Figure 8). Of this, 298 trillion cubic              map, Figure 8). Shell is the biggest                 the Department of Mineral Resources
feet is believed to be in the Whitehill             TCP holder with 185,000 square                       (DMR) and finally lifted the moratorium
Shale.38 The real volume of shale gas               kilometers of land in the Karoo Basin.               on shale gas exploration.43
reserves is still waiting to be confirmed           Falcon Oil and Gas has 30,000 square
through physical exploration activities.            kilometers of TCPs. Sasol, Chesapeake
                                                    and Statoil have formed a joint venture
Unlike Poland and China, where shale                and together hold 88,000 square
gas formation are buried deeper                     kilometers of TCPs, but in December
than the United States, the average                 2011, Sasol decided to put its Karoo
depth of shale gas in South Africa                  shale gas plan on hold.41 Anglo Coal
is 2,500 meters (8,000 feet),39                     and Australian Sunset Energy also
which is quite similar to the Barnett               have their own TCPs. According to




Figure 8. Map of operators’ TCP coverage in the Karoo Basin.

                                  Botswana                                                          Pretoria
                                                                                                                                                   Mbabane
                                                                                            Johannesburg
                                                                                                                                           Swaziland

    Namibia

                                                            South Africa
                                                                                          Maseru

                                                                         Sasol/Statoil/              Lesotho
                                                                         Chesapeake                                                         Durban

                                                                                                               Anglo
                                                                                                               Coal
                                                Shell
                                                                                                                          Ecca Group
                                                                         Sunset                                               Karoo Basin
                                                                         Energy
                                     Falcon Oil and Gas                                                                   Operator
                                                                                                                              Anglo Coal
                                                                                                      East London             Falcon Oil and Gas
                                                                  Port Elizabeth                                              Sasol/Statoil/Chesapeake
          Cape Town                                                                                                           Shell
                                                                                                                              Sunset Energy
                                                                                                                              City




Source: “World Shale Gas Resources: An Initial Assessment of 14 Regions Outside the United States,” U.S. Energy Information Administration, 2011,
www.eia.gov.




                                                                                                                                                         16
17
2
Water regulation
The topic of shale gas regulation is dominated by hydraulic
fracturing, the key feature of shale gas that separates it
from well-regulated conventional gas production. However,
existing regulations to protect water resources during oil and
gas development are also affected by the greater intensity of
water, energy and infrastructure used in shale gas operations.
This consequence is driving significant uncertainty in the US
regulatory landscape, which is still adapting to the new industry.
The speed of industry growth has outpaced the availability of
rigorous data on its potential impact, which has hindered the
ability of government to adequately assess and regulate operations.
This situation has led to a patchwork regulatory landscape and
to a moratorium on shale gas development in New York State,
France and Bulgaria. To resolve this issue, there has been renewed
focus by the US federal government on establishing better
understanding of the potential impacts of shale gas development,
to most effectively regulate this critical new energy resource.




                                                                      18
2.1                                                                                     State regulations
                                            The current regulatory landscape
                                            is comprised of an overlapping
                                            collection of federal, state and local      Regulation of oil and gas production
                                            regulations and permitting systems,         has traditionally occurred primarily at
Regulatory history                          implemented by oil and gas, natural
                                            resources and environmental agencies.
                                                                                        the state level. This level of regulation
                                                                                        is also the case for shale gas, with
and the current                             A mapping of current federal and state
                                            regulation is shown in Figure 9. These
                                                                                        most shale gas-producing states
                                                                                        issuing more rigorous standards that
landscape                                   regulations cover different aspects of
                                            the development and production of a
                                                                                        take primacy over federal regulations,
                                                                                        as well as additional regulations
Hydraulic fracturing of gas wells           shale gas well, with the intention that     that control areas not covered at
began in 1949; however, it remained         they combine to manage any potential        the federal level, such as hydraulic
largely unregulated until significant       impact on the surrounding environment       fracturing. Within states, regulation
unconventional gas production began         and water supplies. These combinations      is carried out by a range of agencies.
around the millennium with the              of regulations have long served to          Energy or natural resource-focused
commercial development of coal-             regulate oil and gas development in         departments generally set requirements
bed methane. As production grew,            numerous states; however, the new           for site permits, drilling, completion
media reports and public complaints         process of hydraulic fracturing is          and extraction, while environmental
of drinking water contamination             something that has not previously           or water departments regulate water,
raised concerns, leading the EPA to         been managed by these regulations.          emissions and waste management.
commission a study into the risks of        Therefore, the related intensity in
hydraulic fracturing to drinking water.     terms of water, emissions and site          The specific regulations vary
In 2004, this study found that hydraulic    activity mean existing regulations are      considerably among states, such as
fracturing of coal-bed methane              being reassessed for their suitability      different depths for well casing, levels
posed minimal threat to underground         for this new production method.             of disclosure on drilling and fracturing
sources of drinking water, which was                                                    fluids, or requirements for water
a significant finding in support of the                                                 storage. The majority of states in shale
industry. In 2005, following the EPA
                                            Federal regulations                         gas-producing regions now have varying
report, the federal Energy Policy Act       With its exemption from the SDWA,           hydraulic fracturing regulations on
granted hydraulic fracturing a specific     hydraulic fracturing is not directly        their books, specifically for disclosure
exemption from the Safe Drinking            regulated by federal standards. However,    of fracking fluids, proper casing of
Water Act (SDWA), which regulates all       a number of federal laws still direct       wells to prevent aquifer contamination
underground injection.                      oil and gas development, including          and management of wastewater from
                                            shale gas.44 These regulations affect       flowback and produced water. Disposal
Since the Energy Policy Act passed in       water management and disposal, as           of wastewater by underground injection
2005, shale gas production in the United    well as air quality and activities on       has emerged as a point of concern for
States has grown significantly, from less   federal land. The Clean Water Act           state regulators due to large inter-state
than one trillion cubic feet in 2005 to     is focused on surface waters and            flows of wastewater to states with
over three trillion cubic feet in 2009.     regulates disposal of wastewater and        suitable geology for Class II disposal
Such rapid growth, along with continued     also includes authorizing the National      wells and reports of earthquakes near
reports of environmental effects, has       Pollutant Discharge Elimination             some well sites. States such as Arkansas
led to renewed calls for change in the      System (NPDES) permit program, as           and Ohio have placed local moratoriums
regulatory landscape, particularly for      well as requiring tracking of any toxic     on disposal wells in locations where
the federal government to provide           chemicals used in fracturing fluids.        increased seismic activity has been
increased regulation or guidance. This                                                  recorded and Ohio is developing rigorous
pressure led to the introduction to         Outside water use, the Hazardous            new standards for disposal wells.45
congress of the FRAC Act in 2009,           Materials Transport Act and Oil Pollution
which sought to repeal the 2005 SDWA        Act both regulate ground pollution
exemption and require disclosure of         risks relating to spills of materials or
components used in all fracturing fluids.   hydrocarbons into the water table.
The bill was sent to committee but
was not passed to congress for vote. In
the absence of new federal regulation,
states have continued to use existing oil
and gas and environmental regulations
to manage shale gas development, as
well as introducing individual state
regulations for hydraulic fracturing.




19
Figure 9. Federal and state regulation mapped to the shale gas lifecycle.




                               Civil/site prep            Drilling                   Completion/               Flowback                  Production
                               Build access roads,        Drill vertical and         fracking                  Capture, store and        Capture, store and
                               construct and install      horizontal wells           Complete wells with       treat returned            transport gas
                               well pads, prepare site                               steel and cement          fracking fluids
                               for drilling                                          casings
                                                                                     Release gas through
                                                                                     hydro-fracking



Typical
timelines                               60 days                  15-60 days                15-30 days                  20 days
                               • The National Environmental Policy Act (NEPA)        • The U.S. Department • The Clean Water Act (CWA) regulates surface
                                 requires that exploration and production on           of Interior Bureau      discharge of produced water and storm water
                                 federal lands be thoroughly analyzed for              of Land Management      through the National Pollutant Discharge
                                 environmental impacts.                                (BLM) is responsible    Elimination System (NPDES) permitting
                                                                                       for issuing fracking    process.
                               • Under the Clean Air Act, National                     permits on federal
                                 emission standards for hazardous air pollutants       lands.                • The CWA sets wastewater standards for
                                 (NESHAP) are used to limit toxic pollutants.                                  industry, and water quality standards for
   Federal regulatory impact




                                                                                     • Hazardous chemicals     contaminates in the surface water.
                               • Under the Clean Air Act, Engine NESHAP rules          must be recorded on
                                 regulate newly refurbished engines including          material safety data  • The Oil Pollution Act (OPA) enforces spill
                                 monitoring and reporting requirements.                sheets and reported     prevention requirements and reporting
                                                                                       in the event of a       operations.
                               • The US Environmental Protection Agency (EPA)
                                 has proposed new performance standards for            crisis as part of the • The EPA has proposed that drillers use “green
                                 toxic air emissions for oil and natural gas           Emergency Planning      completion” techniques to reduce emissions of
                                 production.                                           and Community           volatile organic compounds from wells.
                                                                                       Right to Know Act.      Green completions are required in Colorado
                               • The US EPA administers most of the federal laws.                                and Wyoming.
                                                                                     • Hazardous Materials
                                                                                       Transportation Act      • Comprehensive Environmental Response,
                                                                                       regulates the             Compensation and Liability Act (CERLA)
                                                                                       transport of              enables the federal government to respond to
                                                                                       hazardous materials.      releases of hazardous substances that threaten
                                                                                                                 human health or the environment.


                               • States are able to implement federal regulations.   • Transportation of       • The Safe Drinking Water Act (SDWA) excludes
                                                                                       water, sand and           fracking from its Underground Injection Control
                               • All states require a permit to drill and operate      additives are             (UIC) program. Instead, the EPA and states
                                 a well.                                               regulated under           implement the UIC program to protect
                               • All states have regulations regarding drilling,       state regulations.        groundwater resources. Forty states have primacy
                                 abandonment and plugging of wells.                                              for this with the EPA implementing the
                                                                                     • Disclosure of             program directly in New York and Pennsylvania.
                               • States regulate the effective casing and              chemicals used in
                                                                                       fracking is regulated   • Groundwater is often protected under State
   State regulatory impact




                                 cementing of wells.
                                                                                       at a state level, but     Pollutant Discharge Elimination System
                                                                                       regulations differ in     (SPDES) permits rather than just discharges
                                                                                       strength. Wyoming,        to surface water, as with the NPDES permits.
                                                                                       Texas and Arkansas
                                                                                       require disclosure of   • In addition to state regulations, the Delaware
                                                                                       all chemicals,            River Basin Commission and Susquehanna
                                                                                       Pennsylvania and          River Basin Commission impose water quantity
                                                                                       Michigan only             laws.
                                                                                       require disclosure      • States regulate hazardous wastes and
                                                                                       deemed hazardous,         implement waste management procedures that
                                                                                       Louisiana and             are exempt from the federal Resource
                                                                                       Colorado are              Conservation and Recovery Act.
                                                                                       expected to
                                                                                       implement disclosure
                                                                                       regulations soon.




                                                                                                                                                                  20
Water and Shale Gas Development - Leveraging the US experience in new shale developments
Water and Shale Gas Development - Leveraging the US experience in new shale developments
Water and Shale Gas Development - Leveraging the US experience in new shale developments
Water and Shale Gas Development - Leveraging the US experience in new shale developments
Water and Shale Gas Development - Leveraging the US experience in new shale developments
Water and Shale Gas Development - Leveraging the US experience in new shale developments
Water and Shale Gas Development - Leveraging the US experience in new shale developments
Water and Shale Gas Development - Leveraging the US experience in new shale developments
Water and Shale Gas Development - Leveraging the US experience in new shale developments
Water and Shale Gas Development - Leveraging the US experience in new shale developments
Water and Shale Gas Development - Leveraging the US experience in new shale developments
Water and Shale Gas Development - Leveraging the US experience in new shale developments
Water and Shale Gas Development - Leveraging the US experience in new shale developments
Water and Shale Gas Development - Leveraging the US experience in new shale developments
Water and Shale Gas Development - Leveraging the US experience in new shale developments
Water and Shale Gas Development - Leveraging the US experience in new shale developments
Water and Shale Gas Development - Leveraging the US experience in new shale developments
Water and Shale Gas Development - Leveraging the US experience in new shale developments
Water and Shale Gas Development - Leveraging the US experience in new shale developments
Water and Shale Gas Development - Leveraging the US experience in new shale developments
Water and Shale Gas Development - Leveraging the US experience in new shale developments
Water and Shale Gas Development - Leveraging the US experience in new shale developments
Water and Shale Gas Development - Leveraging the US experience in new shale developments
Water and Shale Gas Development - Leveraging the US experience in new shale developments
Water and Shale Gas Development - Leveraging the US experience in new shale developments
Water and Shale Gas Development - Leveraging the US experience in new shale developments
Water and Shale Gas Development - Leveraging the US experience in new shale developments
Water and Shale Gas Development - Leveraging the US experience in new shale developments
Water and Shale Gas Development - Leveraging the US experience in new shale developments
Water and Shale Gas Development - Leveraging the US experience in new shale developments
Water and Shale Gas Development - Leveraging the US experience in new shale developments
Water and Shale Gas Development - Leveraging the US experience in new shale developments
Water and Shale Gas Development - Leveraging the US experience in new shale developments
Water and Shale Gas Development - Leveraging the US experience in new shale developments
Water and Shale Gas Development - Leveraging the US experience in new shale developments
Water and Shale Gas Development - Leveraging the US experience in new shale developments
Water and Shale Gas Development - Leveraging the US experience in new shale developments
Water and Shale Gas Development - Leveraging the US experience in new shale developments
Water and Shale Gas Development - Leveraging the US experience in new shale developments
Water and Shale Gas Development - Leveraging the US experience in new shale developments
Water and Shale Gas Development - Leveraging the US experience in new shale developments
Water and Shale Gas Development - Leveraging the US experience in new shale developments
Water and Shale Gas Development - Leveraging the US experience in new shale developments
Water and Shale Gas Development - Leveraging the US experience in new shale developments
Water and Shale Gas Development - Leveraging the US experience in new shale developments
Water and Shale Gas Development - Leveraging the US experience in new shale developments
Water and Shale Gas Development - Leveraging the US experience in new shale developments
Water and Shale Gas Development - Leveraging the US experience in new shale developments
Water and Shale Gas Development - Leveraging the US experience in new shale developments
Water and Shale Gas Development - Leveraging the US experience in new shale developments
Water and Shale Gas Development - Leveraging the US experience in new shale developments

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

  • 1. Water and Shale Gas Development Leveraging the US experience in new shale developments
  • 2. Global development of shale gas resources has the potential to expand significantly outside the United States. However, there continue to be environmental concerns, particularly with respect to water use. As operators outside the United States explore shale gas, there are many lessons that can be taken from the United States’ experience. This paper highlights areas that operators of new shale developments should consider. It also includes an analysis of considerations for Argentina, China, Poland and South Africa focusing on water regulation, water use and management, and water movements during shale gas development. 1
  • 3. Contents 1 Introduction 4 Overview of shale gas life cycle activities 8 1.1 Shale resources outside the United States 9 In Focus: Shale developments in Argentina, China, Poland and South Africa 12 2 Water regulation 18 2.1 Regulatory history and the current landscape 19 2.2 Federal efforts to support regulatory consistency 21 2.3 Key trends 22 In Focus: Water regulation in Argentina, China, Poland and South Africa 23 3 Water management 26 3.1 Water use and production 27 Comparison: Managing produced water: unconventional vs. conventional 30 3.2 Water management options 31 Primer: Water treatment technologies 33 3.3 Key trends 34 In Focus: Water use/management in Argentina, China, Poland and South Africa 35 4 Water movements 42 4.1 Shale gas development life cycle: logistics requirements 43 4.2 Significance of water transportation 45 4.3 Rising to the water transportation challenge 45 4.4 Key trends 46 In Focus: Water movements in Argentina, China, Poland and South Africa 47 Concept Overview: Basin-wide water logistics management model 49 5 Lessons learned for new shale developments 52 In Focus: Implications for Argentina, China, Poland and South Africa 57 6 Implications for operators 60 Overview of the challenges in the shale gas lifecycle 63 2
  • 4. 3
  • 5. 1 Introduction Natural gas production in the United States has grown significantly in recent years as improvements in horizontal drilling and hydraulic fracturing technologies have made it commercially viable to recover gas trapped in tight formations, such as shale and coal. The United States is now the number one natural gas producer in the world and, together with Canada, accounts for more than 25 percent of global natural gas production.1 Shale gas will play an ever-increasing role in this resource base and is projected to increase to 49 percent of total US gas production by 2035, up from 23 percent in 2010, highlighting the significance of shale gas in the US energy mix in the future. Lower and less volatile prices for natural gas in the past two years reflect these new realities, with benefits for American consumers and the nation’s competitive and strategic interests, including the revitalization of several domestic industries.2 4
  • 6. In its “2012 Annual Energy Outlook,” the U.S. Energy Information Administration (74.7 trillion cubic feet), and Barnett (43.4 trillion cubic feet). Activity in Water regulation (EIA) referred to the “enormous new plays has increased shale gas This rapid expansion in shale gas potential” of shale gas, and according production in the United States from production has given rise to concerns to the Institute for Energy Research, 11 billion cubic meters (bcm) in 2000 around the impact of operations in the United States has enough natural to 140 bcm in 2010.4 Such production areas such as water, road, air quality, gas to meet domestic electricity potential has the ability to change the seismic and greenhouse gas emissions demand for 575 years at current fuel nature of the North American energy (GHG). The process of hydraulic demand for generation levels—enough mix and according to the National fracturing (fracking) in a shale gas well natural gas to fuel homes heated Petroleum Council 2011 study, “Prudent requires significant volumes of water by natural gas in the United States Development: Realizing the Potential and causes additional greenhouse gas for 857 years and more natural gas of North America’s Abundant Natural emissions compared to conventional than Russia, Iran, Qatar, Saudi Arabia Gas and Oil Resources,” the natural gas wells. There is already significant and Turkmenistan combined.3 gas resource base could support supply resistance to shale gas development for five or more decades at current or due to these water and emission As Figure 1 illustrates, US shale gas greatly expanded levels of use.5 concerns in many parts of the United reserves are vast and broadly dispersed; States and Western Europe, with France the EIA estimates that the lower 48 and Bulgaria imposing nationwide states have a total of 482 trillion cubic moratoriums on shale gas production feet of technically recoverable shale through fracking. The regulation of gas resources with the largest portions shale gas is an evolving landscape in the Northeast (63 percent), Gulf as the industry has developed so Coast (13 percent), and Southwest rapidly that it has often outpaced regions (10 percent), respectively. The the availability of information for largest shale gas plays are the Marcellus regulators to develop specific guidance. (141 trillion cubic feet), Haynesville Figure 1. US lower 48 states shale gas plays. Niobrara* Montana Thrust Bakken*** Belt Heath** Cody Williston Basin Big Hom Powder River Gammon Hilliard Basin Basin Baxter Mowry Appalachian Mancos Michigan Basin Greater Green Basin Antrim Park Niobrara* River Basin Basin Forest Devonian (Ohio) City Basin Uinta Basin Illinois Marcellus Manning Basin Utica Canyon Piceance Denver San Joaquin Mancos Excello- New Basin Basin Basin Hermosa Mulky Cherokee Platform Albany Monterey- Paradox Basin Pierre Temblor Lewis Woodford San Juan Raton Anadarko Fayetteville Basin Basin Chattanooga Basin Ard Monterey mo Arkoma Basin Black Warrior Palo Duro Bend re Bas Basin Conasauga Santa Maria in Basin Valley & Ridge Ventura, Avalon- Floyd-Neal Province Los Angeles Bone Spring Permian Barnett TX-LA-MS Basins Basin Ft. Worth Salt Basin Barnett- Marfa Basin Tuscaloosa Woodford Basin Eagle Haynesville- Bossier Shale plays Basins Ford Pearsall Current plays * Mixed shale & Western Prospective plays chalk play Gulf ** Mixed shale & Stacked plays Iimestone play Shallowest/youngest *** Mixed shale & Intermediate depth/age tight dolostone- Deepest/oldest siltstone-sandstone Source: Shale Gas and Oil Plays, Lower 48 States, U.S. Energy Information Administration, www.eia.gov. 5
  • 7. At present, the US shale gas industry is regulated by a patchwork of existing Water use and Regarding contamination incidents, the MIT report stated that “with over oil and gas regulations on drilling management 20,000 shale wells drilled in the last 10 and well site activities, combined years, the environmental record of shale One of the most contentious and widely with environmental regulations on gas development has for the most part publicized issues in shale gas production water and air management. This loose been a good one—but it is important is water management. Shale gas regulatory landscape is beginning to recognize the inherent risks and the production is a highly water-intensive to change with growing state and damage that can be caused by just process, with a typical well requiring federal attention. In 2010, the U.S. one poor operation…. In the studies around 5 million gallons of water to drill Environmental Protection Agency surveyed, no incidents are reported and fracture, depending on the basin (EPA) launched a four-year field study which conclusively demonstrate and geological formation.8 The vast on the impact of shale gas hydraulic contamination of shallow water zones majority of this water is used during the fracturing and, in 2011, the U.S. with fracture fluids.”9 fracturing process, with large volumes Department of Energy received a report of water pumped into the well with sand In areas with deep unconventional by the Secretary of Energy Advisory and chemicals to facilitate the extraction formations, such as the Marcellus Board (SEAB) for shale gas providing of the gas; the remainder is used in areas in Appalachia, the shale gas recommendations on how to reduce the drilling stage, with water being the under development is separated from the environmental impact and improve major component of the drilling fluids. freshwater aquifers by thousands of the safety of shale gas production. In Relatively small amounts of water are feet and multiple confining layers. To addition to these reports, numerous also used for dust suppression on site, reach these deep formations where the smaller studies continue to provide and for the cleaning and flushing of fracturing of rock occurs, drilling goes information to support improvements drilling equipment. Although increasing through the shallower areas, with the in regulation and leading practice. volumes of water are being recycled and drilling equipment and production pipe In 2010, New York issued a temporary reused, freshwater is still required in high sealed off using casing and cementing moratorium on additional shale gas quantities for the drilling operations as techniques. A new voluntary chemical development to allow the state’s brackish water is more likely to damage registry (FracFocus) for disclosing Department of Environmental the equipment and result in formation fracturing fluid additives was launched Conservation (DEC) to finish its damage that reduces the chance of a in the spring of 2011 by the Ground Supplemental Generic Environmental successful well. The need for freshwater Water Protection Council (GWPC) and Impact Statement (SGEIS) on issues is a growing issue, especially in water- the Interstate Oil and Gas Compact surrounding natural gas drilling. scarce regions and in areas with high Commission (IOGCC). Texas operators New York published a Revised Draft cumulative demand for water, leading are required by law to use FracFocus. SGEIS on September 28, 2011, which to pressure on sources and competition The IOGCC, comprised of 30 member was open for public comment until for water withdrawal permits. The states in the United States, reported January 2012.6 There has been no pressure to increase efficiencies is high in 2009 that there have been no cases further movement from the DEC on the as industry demand for water grows with where hydraulic fracturing has been moratorium. In June 2011, Maryland the development of more wells. verified to have contaminated water. Governor Martin O’Malley issued an A key objective of the EPA’s ongoing Water contamination is another order calling for a three-year study of study is to better understand the aspect of shale gas production that the economic and environmental effects full life-cycle relationship between has generated significant resistance of drilling the Marcellus Shale before hydraulic fracturing and drinking to current shale production processes. permits to drill can be issued. And in water and groundwater resources.10 According to the Massachusetts August 2011, New Jersey Governor Institute of Technology (MIT) 2011 Gas The movement and disposal of produced Chris Christie placed a one-year report, which reviewed three studies water from fractured wells is also a moratorium on hydraulic fracturing so of publicly reported incidents related part of the debate on the environmental that the Department of Environmental to gas well drilling, there were only 43 impact of shale gas production. Protection “can further evaluate the “widely reported” water contamination After fracturing, each well returns a potential environmental impacts of incidents related to gas well drilling percentage of the injected fracture this practice in New Jersey, as well in the past decade (to 2010) during fluid volume over its lifetime; this water as evaluate the findings of ongoing which time, there were about 20,000 is heavily polluted, creating a risk of federal studies.”7 (Note, however, that shale gas wells drilled with almost all groundwater contamination upon its no hydraulic fracturing operations were of them being hydraulically fractured. return to the surface if not correctly taking place in New Jersey when the Of these, 48 percent of the incidents contained and treated. Concerns around moratorium was issued.) Several other involved groundwater contamination such risks have led to the moratorium states, however—including Wyoming, by natural gas or drilling fluids; 33 on shale gas development in New Pennsylvania, Arkansas, Colorado, percent involved on-site surface spills; York’s Marcellus Shale. In addition to Louisiana and Texas—have passed new 10 percent involved water withdrawal the nature of the produced water, the legislation or regulations in response and air quality issues, and blowouts; and, growing volumes of wastewater are to the increased activity associated the remaining 9 percent involved off-site increasing demand for efficiencies with natural gas development. disposal issues (see Figure 2). in water treatment technologies to improve water reuse and 6
  • 8. recycling. Innovative water management can represent up to 80 percent of Operational performance solutions are required to address the logistics activity. Research into water- Better monitoring and planning long-term sustainability of water use in free fracking, on-site treatment and capabilities will reduce bottlenecks shale gas production. disposal and assessment of alternative and smooth delivery into a site (e.g., modes of transport are all being managed slot windows, dynamic Water movements pursued, but are currently unable to generate significant impact. Within the re-routing to avoid congestion). Availability of accurate operational data The volume of equipment, materials boundaries of current capabilities, the can allow operators to identify issues and water required to support shale adoption and integration of logistics and enable continuous improvement gas operations presents a significant leading practice provide the most in both drilling and transportation. logistics challenge. Given the remote straightforward, technology-ready Logistics costs can be reduced through nature of most locations and the approach to reducing transport cost efficiency gains (e.g., reduction of frequent operations movements across and regulatory and HSSE exposure. waiting time) and automated processes highly dispersed and numerous well site can reduce administrative costs. Past locations, flexibility is required in the Improvements in water movements implementations have shown that transport model making road transport also have an impact on other aspects consistent adoption of logistics leading the logistics model of choice for most of shale operations, specifically HSSE practices can deliver up to 45 percent environments. While pipeline and rail exposure, operational performance reduction in transport costs. movements can be effective for long- and compliance. distance or point-to-point movements, Compliance the final distribution to and from the HSSE exposure The use of a water inventory monitoring well pad is almost exclusively managed Improved transport planning processes tool can support water management via road transport. Road transport and systems can reduce the number regulatory compliance through visibility volumes and types vary significantly of truck moves, while telematics of water draw, usage and movements. depending on the operational phase of systems can provide real-time visibility Automated end-to-end processes and the project, with the majority of demand of truck movements and driver systems enable accurate and rapid during the fracking and completion performance, supporting reduction data capture, storage and reporting. phases, which can account for 60–85 in wait times, less congestion and A cross-operator, basin-wide solution percent of total transport volumes. better driver HSSE compliance. would also confirm consistent basin- Some large operations are required to wide reporting standards across source, plan and manage up to 300 multiple sites and operators. truck movements per day within a single basin, which is the equivalent of a pan-regional transport operation in many other sectors. This concentration creates significant challenges, with on-site congestion causing issues to the Figure 2. Chart of water contamination incidents related to gas well drilling. operations teams and local residents, and leading to significant cost exposure to an already marginal cost operation. 9% The high volume and intensity of road transport associated with shale 10% gas production present some unique challenges for operators. A shortage of transport operators with sufficient 48% knowledge, difficulties in tracking and optimizing delivery schedules, reducing Groundwater contamination 33% burden on strained road infrastructure, On-site surface spills and a lack of standardized reporting Water withdrawal and air quality issues, and regulatory data can all lead to and blowouts high costs, Health Safety Security Off-site disposal issues Environment (HSSE) exposure, and regulatory compliance issues. With up to 30 percent of completion costs Source: Massachusetts Institute of Technology 2011 Gas Report. related to transportation, operators are exploring different options to reduce transport activity, with a key focus on water hauling, which 7
  • 9. Overview of shale gas life cycle activities Civil/site prep Completion/fracking Forest clearing, excavation, building As drilling is completed, multiple of access routes, constructing and layers of metal casing and cement are installing wells pads and preparing placed around the wellbore. After the site for drilling activities. well is completed, a fluid composed of water, sand and chemicals is injected Drilling under high pressure to crack the shale, increasing the permeability of the rock Natural gas will not readily flow to and easing the flow of natural gas. vertical wells because of the low permeability of shales. This can be overcome by drilling horizontal wells Flowback where the drill bit is steered from A portion of the fracturing fluid will its downward trajectory to follow a return through the well to the surface horizontal trajectory for one to two due to the subsurface pressures. The kilometers, thereby exposing the volume of fluid will steadily reduce and wellbore to as much of the reservoir be replaced by natural gas production. as possible. Production The fissures created in the fracking process are held open by the sand particles so that natural gas from within the shale can flow up through the well. Once released through the well, the natural gas is captured, stored and transported away for processing. Figure 3. Shale gas lifecycle. Civil/site prep Drilling Completion/ Flowback Production Build access Drill vertical and fracking Capture, store Capture, store roads, construct horizontal wells Complete wells and treat and transport gas and install well with steel and returned fracking pads, prepare site cement casings fluids for drilling Release gas through hydro-fracking Decommission Typical 60 days 15-60 days 15-30 days 20 days 5–40 years timelines Source: Accenture 2012. 8
  • 10. 1.1 cubic feet for the United States and detailed shale gas resource assessments the other 32 countries assessed. To by the countries themselves, with many put this shale gas resource estimate of these assessments being assisted by in context, the world’s technically a number of US federal agencies under Shale resources recoverable gas resources are roughly 16,000 trillion cubic feet, largely the auspices of the Global Shale Gas Initiative (GSGI) that was launched in outside the excluding shale gas.11 Thus, adding the identified shale gas resources to April 2010. United States other gas resources increases total world technically recoverable gas At a country level, there are two country groupings that emerge where shale gas Although estimates are likely to change resources by more than 40 percent development appears most attractive. over time as additional information to 22,600 trillion cubic feet.12 The first group consists of countries becomes available, the international that are currently highly dependent shale gas resource base is currently The estimates of technically recoverable upon natural gas imports, have at least considered to be significant. The initial shale gas resources for the 32 countries some gas production infrastructure, and estimate of technically recoverable outside the United States represent their estimated shale gas resources are shale gas resources in the 32 countries a moderately conservative “risked” substantial relative to their current gas examined in the EIA’s “World Shale resource for the basins reviewed. Given consumption. For these countries, shale Gas Resources” study is 5,760 trillion the relatively sparse data currently gas development could significantly cubic feet (see Figure 4). Adding the US available and the differences in alter their future gas balance, which estimate of the shale gas technically approaches employed to determine the may motivate development. Examples recoverable resources of 862 trillion resources, these estimates are quite of countries in this group include cubic feet results in a total shale uncertain. At the current time, there Chile, France, Morocco, Poland, South resource base estimate of 6,622 trillion are efforts under way to develop more Africa, Turkey and Ukraine. In addition, Figure 4. Map of 48 major shale gas basins in 32 countries. Legend Assessed Basins with Resource Estimate Assessed Basins without Resource Estimate Countries within Scope of EIA Report Countries outside Scope of EIA Report Source: “World Shale Gas Resources: An Initial Assessment of 14 Regions Outside the United States,” U.S. Energy Information Administration, 2011, www.cia.gov. 9
  • 11. South Africa’s shale gas resource endowment is interesting as it may Argentina’s biggest energy company, YPF, has found unconventional shale oil China – Sichuan and be attractive to use this natural gas and natural gas in Mendoza province, Tarim Basin as a feedstock to its existing gas-to- confirming the extension of the massive In 2011, the EIA estimated that liquids (GTL), coal-to-liquids (CTL) Vaca Muerta area. YPF said exploration China had 1,275 trillion cubic feet plants and combined cycle gas turbine at the Payun Oeste and Valle del Rio of technically recoverable shale (CCGT) currently running on diesel. Grande blocks pointed to an estimated gas. Since then a geological survey one billion barrels of oil equivalent The second group consists of those led by China Ministry of Land and (boe) in unconventional oil and gas in countries where the shale gas resource Resources (MLR) confirmed a total of Mendoza. Energy resources and reserves estimate is large (e.g., above 200 trillion 882 trillion cubic feet of technically in the province, which border the Andes cubic feet) and there already exists recoverable shale gas, excluding Tibet. mountain range in western Argentina, a significant natural gas production The Sichuan Basin, located in south- currently stand at 685 million boe. infrastructure for internal use or for central China, covers a large 211,000 export. In addition to the United States, km2 and accounts for 40 percent of notable examples of this group include Canada – Horn River the country’s shale resources.13 Algeria, Argentina, Australia, Brazil, Shale Basin China hopes to produce between 60 Canada, China, Libya and Mexico. British Columbia’s Horn River Shale billion and 100 billion cubic meters a Existing infrastructure would aid in Formation is the largest shale gas year by 2020—an objective that some the timely conversion of the resource field in Canada and part of Canadian analysts are skeptical can be achieved. into production, but could also lead deposits that amount to as much Royal Dutch Shell has recently signed to competition with other natural gas as 250 trillion cubic feet of natural the first production-sharing contract to supply sources. For an individual country gas. Since 2008, a total of nine explore, develop and produce shale gas the situation could be more complex. companies has ventured into the Horn in China, a move that fits in with China’s Outside the United States there River market, including ExxonMobil, overall strategy to bring technical are certain shale plays that could Apache, Devon Energy and Encana. and operational know-how to the change the energy security of the development of its untapped reserves countries in which they are located. While large-scale commercial of the unconventional fuel. CNOOC These include the following: production of shale gas has not yet been Ltd., China’s biggest offshore energy achieved in Canada, many companies producer, plans to develop new fields, are now exploring for and developing acquire overseas assets and develop Argentina – The Neuquén shale gas resources in Alberta, British unconventional resources such as shale Basin Columbia, Quebec and New Brunswick. Development of shale gas, and other gas to meet output targets. The country is “determined” to learn shale-gas According to the EIA, Argentina has unconventional resources, will help technology from its partners and deploy 774 trillion cubic feet of technically confirm supplies of natural gas it in China, holder of the world’s largest recoverable shale gas, making it the are available to the growing North deposits of the fuel, Chairman Wang world’s third‐largest player in the shale American natural gas market for many Yilin has stated.14 game behind the United States and decades. Encana, Canada’s largest China. Located on Argentina’s border with Chile, the 137,000 km² Neuquén natural gas producer and one of the biggest in North America, is looking Poland – Baltic-Podlasie- Basin is the South American nation’s for a single partner for a package of Lublin Basins largest source of hydrocarbons, holding assets that could include positions in 35 percent of the country’s oil reserves The EIA has assessed that Eastern the Collingwood Shale, the Tuscaloosa and 47 percent of its gas reserves. Europe may hold as much as 250 trillion Marine Shale, the Mississippi Lime Within the basin, the Vaca Muerta Shale cubic feet of shale gas, with Poland’s and the Eaglebine Shale in the United formation may hold as much as 240 Silurian Shale plays boasting 187 trillion States. All have natural gas liquids or oil trillion cubic feet of exploitable gas. cubic feet of that total. The Russia potential and are in the early stages of ExxonMobil has recently entered into Federation currently supplies 25 percent exploration and development. an agreement with Americas Petrogas of Europe’s natural gas, and Poland’s for the Exploration and Production potential shale resources could reduce (E&P) farm‐out of 163,500 gross acres Europe’s dependence on natural gas of its Neuquén-based Los Toldos blocks. imports. Whether these reserves will This area is also being explored and be developed is still to be seen, but the developed by Shell, Apache, EOG, Total 38-million-strong Slavic nation will have and Wintershall, among others. a strong claim to energy independence as its projected reserves equate to 300 years of domestic consumption. 10
  • 12. Several companies including ExxonMobil and Chevron have begun to drill test Other regions wells and more than 100 companies India’s Oil and Natural Gas Corp (ONGC) rushed to grab a share of Poland’s gas and US oil company ConocoPhillips have concessions. Some of those early tests signed an agreement to explore and produced decent flows, but others develop shale gas assets and look for showed quite different results from opportunities in deepwater exploration. wells drilled into US shale deposits. The agreement is for sharing technical ExxonMobil said its two test wells did knowledge on shale gas explorations, not justify commercial production. but ONGC and ConocoPhillips could ExxonMobil said in January 2012 that also jointly bid for shale gas assets two exploratory wells failed to flow overseas. India may still launch the first enough gas to make development shale gas licensing round by the end profitable. In June 2012, ExxonMobil of 2013 even though the government announced it would end its search for pushed back plans to unveil a policy shale gas in Poland.15 Flow rates at on exploration of unconventional sites drilled by 3Legs Resources Plc. and gas resources trapped in rocks. BNK Petroleum Inc. were not as high as similar wells in the United States. South Africa – The Karoo Supergroup Known by paleontologists as one of the world’s most fertile hunting grounds for fossil remains, the Karoo Supergroup (KSG) might also be one of the most plentiful sources of shale gas in the world. The KSG is constituted mainly of shales and sandstones and spans across 88,000 km², underlying more than two-thirds of the entire area of South Africa and containing an estimated 485 trillion cubic feet of technically recoverable gas. Shale gas could reduce the country’s dependence on coal to fuel 85 percent of its energy needs. 11
  • 13. In Focus Shale developments in Argentina, China, Poland and South Africa A key objective of this report is to highlight the trends and lessons learned Argentina in 2011 due to decreasing exploration activities in the past decade.17 from shale development in the United Argentina is the largest natural gas Meanwhile, the demand for natural gas States that can be applied to shale producer in South America with 1,416 in Argentina has increased in recent developments in other geographies. To billion cubic feet (bcf) annual output in years in line with economic growth, emphasize this point, we will present 2010.16 Natural gas prices in Argentina and the country has had to rely on gas four case studies in this report of four were kept low by the government imports from neighboring Bolivia and very different shale developments: since the economic crisis in 2002. Liquefied Natural Gas (LNG) shipments. Argentina, China, Poland and South As a result natural gas production Shale gas has brought new hope for Africa. The following is a detailed dropped almost 15 percent from its addressing energy demands. Based description of these shale developments. peak of 1,628 bcf and natural gas on an EIA estimation, Argentina has tested reserves dropped 50 percent 774 trillion cubic feet of technically to only 13.4 trillion cubic feet recoverable shale gas, which is almost 60 times that of its current tested natural gas reserves.18 To encourage Figure 5. Neuquén Basin Shale Gas Prospective Area and Basemap. domestic natural gas exploration and production, the Argentinian government introduced its “Gas Legend Plus” program in 2008 to allow new Neuquén Basin discovered unconventional gas to be Thrust Fault sold at a higher price based on cost City Water and reasonable profit.19 This incentive program allows approved companies to Cu charge up to $5/thousand cubic feet yo (mcf) for their natural gas production. Ba sin The Neuquén Basin covers the Neuquén province and parts of Mendoza, Rio Negro and La Pampa provinces in central-west of Argentina, holding 407 lt trillion cubic feet of the country’s 774 Agrid Fold & Thrust Be trillion cubic feet estimated resources. Andes Mountains This basin largely overlaps with existing natural gas production regions. The Neuquén province alone currently produces almost half of the nation’s conventional gas.20 The geological formation of the Neuquén Basin is very Productive Area similar to major US shales with the Extensional Structures average depth of the 204 trillion cubic feet of recoverable shale gas in the Vaca Muerta formation within the Neuquén Basin at 2,400 meters. Geological features and existing local natural gas Colorado Basin Neuquén Huincul Arch / n infrastructure make future development Dorsal de Neuque in the Neuquén Basin very promising. h Nort onian Other basins including the San Jorge g Basin and the Austral Magallanes Basin Pata f have 95 trillion cubic feet and 172 i Mass trillion cubic feet reserves, respectively. Source: “World Shale Gas Resources: An Initial Assessment of 14 Regions Outside the United States,” U.S. Energy Information Administration, 2011, www.eia.gov. 12
  • 14. Many shale operators have started exploration activities in Argentina. China Data from a recent Ministry of Land and Resources (MLR)-led geological survey Apache partnered with YPF, previously The recent success of shale gas shows China has 882 trillion cubic controlled by Repsol, but was development in the United States, as feet of technically recoverable shale renationalized in April 2012 by the well as a domestic push to reshape the gas resources, a lower figure than the Argentinian government, to explore energy structure to reduce dependence EIA’s estimate. Figure 6 illustrates shale unconventional resources including on coal, has put shale gas under the gas distribution in China. The Sichuan shale gas in the Neuquén and Austral spotlight in China. In December 2011, Basin in the Upper Yangzi region and Basins. Apache has been awarded the China State Council approved shale southwest China (a region covering 1.6 million gross acres (3,642 km2) gas as a new type of natural resource Sichuan, Chongqing, Yunnan, Guizhou in the Neuquén Basin for shale gas that will be managed separately from and Guangxi provinces) has 10 trillion development and the company drilled conventional gas.23 In March 2012, cubic meters (350 trillion cubic feet) of the first horizontal multi-fracture shale the National Development and Reform shale gas, which equates to 40 percent gas well in South America in 2011.21 In Commission (NDRC) issued its Shale Gas of total national reserves. Unlike US May 2011, one of Apache’s horizontal Development Plan (2011–2015)24 that formations, where most shale seams wells in the Neuquén Basin tested at sets clear targets for the industry by are at depths of less than 3,000 meters a rate of 7 million cubic feet (mmcf)/ 2015 and 2020. However, the shale gas (with the exception of the Haynesville day. Canadian firm America Petrogas industry in China remains at an early Shale), the shale-bearing layers in many joined with ExxonMobil to explore 660 stage with most activity in exploration Chinese formations are between 3,000 km2 of blocks in the Neuquén Basin. and drilling of test wells. to 5,000 meters deep. Therefore, US The company drilled a test well together shale gas development models cannot with ExxonMobil and the result is be simply replicated in China and the under evaluation.22 With undergoing complex geological conditions will exploration activities, EIA’s original increase the cost of drilling wells. estimation on Argentina’s shale gas potential is waiting to be confirmed with new data from the operators. Figure 6. Shale gas distribution in China. Northwest zone 15% North and Northeast zone 26% Upper Yangzi & Southwest zone Lower Yangzi & 40% Southeast zone Sichuan Chongqing 19% Guizhou Yunnan Guangxi Source: China Ministry of Land and Resources, People’s Republic of China, www.mlr.gov.cn. 13
  • 15. The shale gas industry has, for the China CBM has proposed to start The average depth of shale formations first time, been put in a strategically exploring three regions in Shanxi in Poland is from 2,500 to 3,800 meters, important position in the government’s province.26 In the first round of national which is up to twice as deep as the 12th five-year energy plan (2011–2015). shale gas exploration rights auctions, average depth of 2,000 meters observed In addition, the Shale Gas Development organized by the MLR, Sinopec and in the Marcellus Shale.29 30 Variations Plan (2011–2015) states that by 2015, Henan Coal Bed Methane Co won the have been observed among different the government aims to complete an bid. A second round of auctions is due basins, with 1,000–4,500 meters depth investigation on shale gas reserves and to start in late 2012. for the Baltic Basin, 1,000–3,500 meters their national distribution. The plan also depth for the Lublin Basin, and 4,000– estimates annual production reaching International oil majors are actively 5,000 meters depth for the Podlasie 6.5 billion cubic meters (230 billion partnering with NOCs to enter China’s Basin (near Warsaw). These geological cubic feet) and confirmed technically shale gas market. CNPC and Statoil characteristics could likely result in recoverable reserves reaching 600 began test drilling in China in early higher drilling costs, linked to higher billion cubic meters (21 trillion 2011. Sinopec has teamed with BP to demands on water in the drilling stages. cubic feet) by 2015. With almost no explore shale gas in Guizhou in 2010, commercial production today, reaching joined forces with ExxonMobil to Shale gas activities in Poland started such targets will require significant conduct geological research in Sichuan, in 2007; by September 2011, a total of investment at each stage of the value and is also working with Chevron in 101 shale gas exploration authorizations chain in the next couple of years, as Guizhou to carry out risk assessments. had been granted and another 26 well as technology development and Shell is the most active international oil applications were being processed.31 collaboration between national oil company (IOC) in China, and has already International oil majors have entered companies (NOCs) and experienced shale signed the first production-sharing the Polish market in the form of joint gas operators from other countries. contract with CNPC to explore, develop ventures. 3Legs Resources formed and produce shale gas. a joint venture with ConocoPhillips NOCs and state-owned entities have to evaluate shale gas potential in been the first to be allowed to explore and develop shale gas resources in Poland the Baltic Basin and drilled the first exploration well in Poland. PKN and China. So far most activities are in Poland has the most significant shale PGNiG are the most active Polish exploration, with only very limited gas potential in Europe. Poland’s operators. As of August 2011, based commercial production. The three major shale gas resources are located in on square kilometers covered, the top NOCs (CNPC, Sinopec and CNOOC), the Baltic-Podlasie-Lublin Basins (see 10 concession holders in Poland were: Yangchang Petroleum Group, and China Figure 7), creating a strip across the (1) San Leon Energy with 14 licenses United Coalbed Methane Co (China country from northwest to southeast. covering 11,520 km2, (2) ExxonMobil, (3) CBM) are actively involved in shale gas The EIA estimates 187 trillion cubic PKN Orlen, (4) Chevron, (5) Marathon exploration. By the end of 2011, CNPC feet of technically recoverable shale Oil & Gas, (6) BNK Petroleum, (7) had drilled 11 test wells in southern gas resources in the Baltic-Lublin- 3Legs Resources, (8) Nexen, (9) Sichuan and northern Yunnan, four of Podlasie Basins of Poland; of those, ConocoPhillips and (10) Petrolivest.32 which had exhibited industrial-level 120 trillion cubic feet are in the gas flow. Sinopec has its exploration Baltic Basin.27 A report released in activities mainly in Guizhou, Anhui March 2012 by the Polish Geological Sichuan and Chongqing. In Chongqing, Institute was able to confirm 67 trillion Sinopec has shale gas production in cubic feet of technical recoverable Liangping County with an estimated shale gas resources in these three annual output 300–500 million cubic basins after a 16-month research meters (10–18 billion cubic feet).25 project with external support from Yanchang Group is very active in its the U.S. Geological Survey.28 traditional territory of Shannxi province and has successfully fracked the first horizontal well in China. 14
  • 16. With authorizations received, current transforming the coal-based electricity industry activities have moved onto generation sector. A consortium formed drilling of testing wells. 22 exploration with state-owned power utilities wells were started in 2011 and 13 wells companies and PGNiG will co-finance were completed by February 2012. 14 and co-develop shale exploration along new exploration wells were planned the Baltic coast. Utilities will finance for late 2012 and as many as 123 wells exploration activities in exchange are planned by 2017.33 So far, state- for future gas supplies in off-take owned PGNiG, 3Legs Resources, BNK, agreements.35 Poland’s Treasury Minister Talisman Energy, Marathon Oil and said the country may be producing one ExxonMobil have all completed their billion cubic meters (35 billion cubic first batch test wells. ExxonMobil, BNK feet) of shale gas per year by 2014.36 and 3Legs released rather disappointing results, stating that the gas flows in their testing wells are lower than similar prospects in US shale and commercial production cannot be justified.34 Despite this negative news, the Polish government strongly believes shale gas would help to reduce the nation’s energy dependency on Russia and cut greenhouse gas (GHG) emissions through Figure 7. Map of Poland’s shale gas basin. Kaliningrad Gdansk Baltic Basin Szczecin Mazury - Belarus High Bydgoszcz Bialystok Berlin Poznan Warsaw Podlasie Basin Brest Lodz Lublin Legend Czestochowa Lublin Basin Trans-European Fault Zone Faults National Capitals Katowice Major Cities Krakow Ostrava Poland Shale Basins Prospectivity Non-Prospective Prospective Source: World Shale Gas Resources: An Initial Assessment of 14 Regions Outside the United States, U.S. Energy Information Administration, 2011, www.eia.gov. 15
  • 17. South Africa Shale.40 However, the Karoo Basin contains significant areas of volcanic South African regulations, TCPs allow no more than desktop research; with South African electricity generation intrusions that impact the quality further applications required to obtain is currently heavily coal-based. The of the shale gas resources, limit the authorization for physical exploration Department of Energy intends to use of seismic imaging and increase activities. However, the application have 9 percent of energy from open the risk of shale gas exploration. to convert these TCPs into physical cycle gas turbines by 2030 and shale exploration licenses was suspended gas could help to reach this target.37 A number of companies have started over a year to allow the government to According to the EIA, South Africa has pursuing shale gas development in the conduct policy and technical reviews an estimated 485 trillion cubic feet Karoo Basin by obtaining Technical before final decisions.42 On September of technically recoverable shale gas Cooperation Permits (TCPs) from the 7, 2012, the South Africa government located in the Karoo Basin (see map, South Africa Petroleum Agency (see accepted the recommendations from Figure 8). Of this, 298 trillion cubic map, Figure 8). Shell is the biggest the Department of Mineral Resources feet is believed to be in the Whitehill TCP holder with 185,000 square (DMR) and finally lifted the moratorium Shale.38 The real volume of shale gas kilometers of land in the Karoo Basin. on shale gas exploration.43 reserves is still waiting to be confirmed Falcon Oil and Gas has 30,000 square through physical exploration activities. kilometers of TCPs. Sasol, Chesapeake and Statoil have formed a joint venture Unlike Poland and China, where shale and together hold 88,000 square gas formation are buried deeper kilometers of TCPs, but in December than the United States, the average 2011, Sasol decided to put its Karoo depth of shale gas in South Africa shale gas plan on hold.41 Anglo Coal is 2,500 meters (8,000 feet),39 and Australian Sunset Energy also which is quite similar to the Barnett have their own TCPs. According to Figure 8. Map of operators’ TCP coverage in the Karoo Basin. Botswana Pretoria Mbabane Johannesburg Swaziland Namibia South Africa Maseru Sasol/Statoil/ Lesotho Chesapeake Durban Anglo Coal Shell Ecca Group Sunset Karoo Basin Energy Falcon Oil and Gas Operator Anglo Coal East London Falcon Oil and Gas Port Elizabeth Sasol/Statoil/Chesapeake Cape Town Shell Sunset Energy City Source: “World Shale Gas Resources: An Initial Assessment of 14 Regions Outside the United States,” U.S. Energy Information Administration, 2011, www.eia.gov. 16
  • 18. 17
  • 19. 2 Water regulation The topic of shale gas regulation is dominated by hydraulic fracturing, the key feature of shale gas that separates it from well-regulated conventional gas production. However, existing regulations to protect water resources during oil and gas development are also affected by the greater intensity of water, energy and infrastructure used in shale gas operations. This consequence is driving significant uncertainty in the US regulatory landscape, which is still adapting to the new industry. The speed of industry growth has outpaced the availability of rigorous data on its potential impact, which has hindered the ability of government to adequately assess and regulate operations. This situation has led to a patchwork regulatory landscape and to a moratorium on shale gas development in New York State, France and Bulgaria. To resolve this issue, there has been renewed focus by the US federal government on establishing better understanding of the potential impacts of shale gas development, to most effectively regulate this critical new energy resource. 18
  • 20. 2.1 State regulations The current regulatory landscape is comprised of an overlapping collection of federal, state and local Regulation of oil and gas production regulations and permitting systems, has traditionally occurred primarily at Regulatory history implemented by oil and gas, natural resources and environmental agencies. the state level. This level of regulation is also the case for shale gas, with and the current A mapping of current federal and state regulation is shown in Figure 9. These most shale gas-producing states issuing more rigorous standards that landscape regulations cover different aspects of the development and production of a take primacy over federal regulations, as well as additional regulations Hydraulic fracturing of gas wells shale gas well, with the intention that that control areas not covered at began in 1949; however, it remained they combine to manage any potential the federal level, such as hydraulic largely unregulated until significant impact on the surrounding environment fracturing. Within states, regulation unconventional gas production began and water supplies. These combinations is carried out by a range of agencies. around the millennium with the of regulations have long served to Energy or natural resource-focused commercial development of coal- regulate oil and gas development in departments generally set requirements bed methane. As production grew, numerous states; however, the new for site permits, drilling, completion media reports and public complaints process of hydraulic fracturing is and extraction, while environmental of drinking water contamination something that has not previously or water departments regulate water, raised concerns, leading the EPA to been managed by these regulations. emissions and waste management. commission a study into the risks of Therefore, the related intensity in hydraulic fracturing to drinking water. terms of water, emissions and site The specific regulations vary In 2004, this study found that hydraulic activity mean existing regulations are considerably among states, such as fracturing of coal-bed methane being reassessed for their suitability different depths for well casing, levels posed minimal threat to underground for this new production method. of disclosure on drilling and fracturing sources of drinking water, which was fluids, or requirements for water a significant finding in support of the storage. The majority of states in shale industry. In 2005, following the EPA Federal regulations gas-producing regions now have varying report, the federal Energy Policy Act With its exemption from the SDWA, hydraulic fracturing regulations on granted hydraulic fracturing a specific hydraulic fracturing is not directly their books, specifically for disclosure exemption from the Safe Drinking regulated by federal standards. However, of fracking fluids, proper casing of Water Act (SDWA), which regulates all a number of federal laws still direct wells to prevent aquifer contamination underground injection. oil and gas development, including and management of wastewater from shale gas.44 These regulations affect flowback and produced water. Disposal Since the Energy Policy Act passed in water management and disposal, as of wastewater by underground injection 2005, shale gas production in the United well as air quality and activities on has emerged as a point of concern for States has grown significantly, from less federal land. The Clean Water Act state regulators due to large inter-state than one trillion cubic feet in 2005 to is focused on surface waters and flows of wastewater to states with over three trillion cubic feet in 2009. regulates disposal of wastewater and suitable geology for Class II disposal Such rapid growth, along with continued also includes authorizing the National wells and reports of earthquakes near reports of environmental effects, has Pollutant Discharge Elimination some well sites. States such as Arkansas led to renewed calls for change in the System (NPDES) permit program, as and Ohio have placed local moratoriums regulatory landscape, particularly for well as requiring tracking of any toxic on disposal wells in locations where the federal government to provide chemicals used in fracturing fluids. increased seismic activity has been increased regulation or guidance. This recorded and Ohio is developing rigorous pressure led to the introduction to Outside water use, the Hazardous new standards for disposal wells.45 congress of the FRAC Act in 2009, Materials Transport Act and Oil Pollution which sought to repeal the 2005 SDWA Act both regulate ground pollution exemption and require disclosure of risks relating to spills of materials or components used in all fracturing fluids. hydrocarbons into the water table. The bill was sent to committee but was not passed to congress for vote. In the absence of new federal regulation, states have continued to use existing oil and gas and environmental regulations to manage shale gas development, as well as introducing individual state regulations for hydraulic fracturing. 19
  • 21. Figure 9. Federal and state regulation mapped to the shale gas lifecycle. Civil/site prep Drilling Completion/ Flowback Production Build access roads, Drill vertical and fracking Capture, store and Capture, store and construct and install horizontal wells Complete wells with treat returned transport gas well pads, prepare site steel and cement fracking fluids for drilling casings Release gas through hydro-fracking Typical timelines 60 days 15-60 days 15-30 days 20 days • The National Environmental Policy Act (NEPA) • The U.S. Department • The Clean Water Act (CWA) regulates surface requires that exploration and production on of Interior Bureau discharge of produced water and storm water federal lands be thoroughly analyzed for of Land Management through the National Pollutant Discharge environmental impacts. (BLM) is responsible Elimination System (NPDES) permitting for issuing fracking process. • Under the Clean Air Act, National permits on federal emission standards for hazardous air pollutants lands. • The CWA sets wastewater standards for (NESHAP) are used to limit toxic pollutants. industry, and water quality standards for Federal regulatory impact • Hazardous chemicals contaminates in the surface water. • Under the Clean Air Act, Engine NESHAP rules must be recorded on regulate newly refurbished engines including material safety data • The Oil Pollution Act (OPA) enforces spill monitoring and reporting requirements. sheets and reported prevention requirements and reporting in the event of a operations. • The US Environmental Protection Agency (EPA) has proposed new performance standards for crisis as part of the • The EPA has proposed that drillers use “green toxic air emissions for oil and natural gas Emergency Planning completion” techniques to reduce emissions of production. and Community volatile organic compounds from wells. Right to Know Act. Green completions are required in Colorado • The US EPA administers most of the federal laws. and Wyoming. • Hazardous Materials Transportation Act • Comprehensive Environmental Response, regulates the Compensation and Liability Act (CERLA) transport of enables the federal government to respond to hazardous materials. releases of hazardous substances that threaten human health or the environment. • States are able to implement federal regulations. • Transportation of • The Safe Drinking Water Act (SDWA) excludes water, sand and fracking from its Underground Injection Control • All states require a permit to drill and operate additives are (UIC) program. Instead, the EPA and states a well. regulated under implement the UIC program to protect • All states have regulations regarding drilling, state regulations. groundwater resources. Forty states have primacy abandonment and plugging of wells. for this with the EPA implementing the • Disclosure of program directly in New York and Pennsylvania. • States regulate the effective casing and chemicals used in fracking is regulated • Groundwater is often protected under State State regulatory impact cementing of wells. at a state level, but Pollutant Discharge Elimination System regulations differ in (SPDES) permits rather than just discharges strength. Wyoming, to surface water, as with the NPDES permits. Texas and Arkansas require disclosure of • In addition to state regulations, the Delaware all chemicals, River Basin Commission and Susquehanna Pennsylvania and River Basin Commission impose water quantity Michigan only laws. require disclosure • States regulate hazardous wastes and deemed hazardous, implement waste management procedures that Louisiana and are exempt from the federal Resource Colorado are Conservation and Recovery Act. expected to implement disclosure regulations soon. 20