MARCELLUS SHALE IMPACTS ON WATER QUALITY What is know and what needs to be known

Marc Glass Principal Downstream Strategies Morgantown, WV Water Research Conference October 31, 2012 Morgantown, WV

Company background
Environmental consultants Link economic development with natural resource stewardship Started in 1997 Staff of 9 Two locations: Morgantown, Alderson

Outline
1. Potential impacts to water resources 2. DS experiences 3. Other routes for contamination 4. Needed research and data gaps
Fate and transport of HF fluids Natural and man-made migration conduits Fluid disposal challenges

SURFACE SPILLS

Surface spills
Probably the highest probability of human

health exposure pathways This is the pathway that we have witnessed in W.Va.
Drill cuttings and fluids Fracturing fluids Flowback Produced water

Soil pollution (mg/kg)

Background soil sample <8 <8

Sample Sample 1 2 Parameter TPH-DRO 7,970 1,770 TPH-ORO 14,300 4,770

LUST threshold 100 100

Outcome
DEP issued Notice of Violation for torn liner DEP required remediation with targets
500 mg/kg chlorides 100 mg/kg TPH

DEP has not taken action on drinking water

WV LUST Program
Requires site assessment to determine full extent of contamination if evidence that: 1. Groundwater wells have been affected by a release 2. Contaminated soils may be in contact with groundwater, or provide a source for groundwater contamination

PADEP LUST Regulations

Rebuttable presumption that an owner or

operator of regulated storage tanks is liable for all damages, contamination or pollution within 2,500 feet

To overcome presumption of liability, owners

or operators may demonstrate via site assessment or survey

Spill in Buckeye Creek, Doddridge Co.

Marcellus Shale well, no horizontal drilling Permitted and drilled in March, completed in

April, began production in May 2009 Spill into Buckey Creek, August 2009

Buckeye Creek: Ratios between postspill data and historical averages

Parameter Specific conductance Total dissolved solids Calcium Chloride Sodium Sulfate Ratio 8 11 7 15 13 10

Outcome
Notice of Violation issued by DEP for allowing

pollutants to flow into waters of the state in September 2009 Downstream Strategies monitoring, report in October 2009 Consent Order in March 2010
$10,000 fine

Final DEP report in 2010

DEP cannot explain it

To date, there is no definite explanation for the discharge into Buckeye Creek. This does not mean that there is not an explanation, or a person or entity responsible; however, it does mean that all available evidence at this time only allows for theories and conjecture.

Other conduits for migration of fluids may exist

Old gas wells Natural fractures

Source: Scott Detrow / STATEIMPACT PENNSYLVANIA, 2012

Source: Kerry Grens, 2010

Surface leakage of oil or natural gas can contaminate nearby soils as well as local freshwater supplies.

Source: WVDEP, 1997

2011 WVDEP State of the Environment Abandoned Wells

Perhaps the greatest concern is the

uncertainty of what may be occurring below the surface.

Unplugged wells or improperly plugged wells

can lead to groundwater contamination with crude oil, salt water and natural gas.

West Virginia setting

In past seven years, the Office of Oil and Gas

has plugged or reclaimed 252 wells at a cost of $6.2 million ($150) via fees collected with new well permits 13,000 permitted abandoned wells

New legislation provides limited funding

West Virginia currently has approximately

GEOLOGIC CONDUITS ?

Two potential pathwaysadvective transport through bulk media and preferential flow through fracturescould allow the transport of contaminants from the fractured shale to aquifers. The overall system requires from 3 to 6 years to reach a new equilibrium reflecting the significant changes caused by fracking the shale, which could allow advective transport to aquifers in less than 10 years.

most of the rock above the Marcellus consists of shale. And since shale cant pass much water, particularly if it is dry and solid, Myers computer model cannot calculate proper water flow conditions. Water in the Marcellus under the Appalachian Plateau (southern New York and northern Pennsylvania) does not naturally move upward by means of artesian pressure toward the land surface, as Myers assumes. And because of only this error, his model fails on first principles.

We present geochemical evidence from northeastern Pennsylvania showing that pathways, unrelated to recent drilling activities, exist in some locations between deep underlying formations and shallow drinking water aquifers. The strong geochemical fingerprint in the salinizedgroundwater sampled from the Alluvium, Catskill, and Lock Haven aquifers suggests possible migration of Marcellus brine through naturally occurring pathways.

Geysers and wells

Drilling occurs before any casing or cement.

Gas drillers hit aquifer; geysers erupt By The Associated Press, June 6, 2012 Near Sardis, WV, drilling 3,000 feet away.

Source: American Oil & Gas Reporter, Kevin Fisher, 201o

Source: FutureGen Alliance, 2012

West Virginia setting

No mapping or monitoring of potential

pathways Disclosure of additives is now required

Completion Report: actual additives

Water Management Plan: anticipated additives

No groundwater monitoring is required Nothing in this section allows the

department to prevent drilling in naturally occurring karst terrain.

Summary: Research and science

Research is starting to catch up to the facts on

the ground Much fundamental research still needs to be done to quantify risks
Fate and transport of HF fluids Natural and man-made migration conduits Fracture fluid disposal challenges Air quality Radiation

Summary: West Virginia setting

West Virginia law and regulations are starting

to catch up with the facts on the ground

Revised rules not approved yet

Oil and gas operations still benefit from

exemptions from major environmental laws

Source: Griffith, 2012

Marc Glass Principal Downstream Strategies Morgantown, WV (304) 292-2450 mglass@downstreamstrategies.com

O&G exemptions from federal laws

Exemption Hydraulic fracturing exempt from Safe Drinking Water Act regulation Oil and gas E&P wastes are not Resource Conservation regulated as hazardous and Recovery Act (RCRA) substances Comprehensive Environmental Oil and gas wastes exempted from Response, control Compensation, and Liability Act (CERCLA) Oil and gas exempt from Clean Water Act stormwater runoff regulation Environmental law