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Environmental Issues in
Unconventional Exploration and
Production of Oil and Gas
Jim Morriss
Thompson & Knight LLP
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Conventional vs Unconventional
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● August 1859 – Edwin Drake drills the first commercially
successful oil well in Western Pennsylvania
● 1866 Edward Roberts receives a patent for the
petroleum torpedo --intended to “fracture the rock
containing the oil to some distance around the wells,
thus creating artificial seams…”
History of Hydraulic Fracturing in the US
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● November 1946 -Stanolind Oil Company attempts the
first slick water frack with proppant in the Hugoton
natural gas field in Kansas.
● May 1948- Fracking Patent filed.
● By 1955 more that 100,000 wells had been fracked.
● June 11, 1998 -Mitchell Energy and Union Pacific use
hydraulic fracturing and 1.2 million gallons of water to
develop a well in the Barnett Shale
● August 2001 Mitchell sells to Devon
History of Hydraulic Fracturing
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● In 2002 only 1 in 14 wells drilled employed horizontal
drilling
● June and July 2002- Devon drills its first horizontal well
in the Barnett Shale
● June 2002 Devon announces that there is room for five
thousand wells in the Barnett in addition to the 1043
wells already there.
● Number of currently producing oil and gas wells in the
Barnett Shale: over 18,000
History of Hydraulic Fracturing
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Global Shale Oil and Gas Resources
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Top 10 countries with technically recoverable
shale oil resources (billion barrels)
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1. Russia 75
2. U.S. 58
3. China 32
4. Argentina 27
5. Libya 26
6. Venezuela 13
7. Mexico 13
8. Pakistan 9
9. Canada 9
10.Indonesia 8
World Total: 345.
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8
1. China 1,115
2. Argentina 802
3. Algeria 707
4. U.S. 665
5. Canada 573
6. Mexico 545
7. Australia 437
8. South Africa 390
9. Russia 285
10.Brazil 245
World Total: 7,299
Top 10 countries with technically recoverable
shale gas resources (trillion cubic feet)
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Exponential increase in tight oil
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U.S. Tight Oil Production
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Era of cheap natural gas
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Source: U.S. Energy Information Administration
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Total Energy Production
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Source: U.S. Energy Information
Administration
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Future Sources of Electricity
Source: EIA Annual Energy Outlook
2014 Early Release
Trilli
on
kilo
wa
tth
ou
rs
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Failure to address uncertainty may lead to loss
of “license to operate”
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Why the unprecedented attention/concern?
● Location of development
● Scale of operations
● Speed of growth in development
● Public perception of technology
● Stakeholder Communication Issues
● Absence of a consistent and proven regulatory framework in some areas
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What are the Environmental Issues?
● Air
● Water
● Waste
● Induced Seismicity
● Siting- Endangered
Species and Wetlands
● Risk Management and
Spill Prevention and
Response
● Community Response
● Litigation
● Transactions
● Compliance
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Environmental Issues?
Endangered Species? Wetlands?
Surface Water
DischargePotential Chemical
Release
Air EmissionsWater Supply
Traffic?
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● Historical Background on the Regulation of the oil and
gas Industry in the U.S.
● Scope and Source of Regulation Today
Federal
State
Local
Tribal
Legal Framework
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North American Shale Plays- Many
Jurisdictions
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Stage 1 - Drilling
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Anatomy of a horizontal well
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Workover Rig and Completion
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Flow Back
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Production Site
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● Sources
The Completion Process
Storage-tank emissions (breathing losses, flash emissions,
loading/unloading)
Engines
Operations- pneumatic devices, leaks, and liquid unloading
Flaring
● Pollutants
Air Issues
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Emission Sources
Source TCEQ
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Emission Sources
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Permitting
− Permits by Rule, Exemptions, and Standard Permits
− Smaller Sources vs. Major Sources
Technology Forcing Standards
− New Source Performance Standards
− Standards for Hazardous Air Pollutants
Regulatory Approaches
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● Storage Tanks- to control working and breathing losses
and flash emissions
● Standards for Stationary Engines
● Green Completions
Technology Forcing Standards
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Reduced Emission Completions (RECs)or Green Completions
for Gas Wells
Economic and Environmental Benefits:
Gas recovered for sales
Condensate recovered for sales
Reduced methane emissions
NSPS for Green Completions
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October 15, 2012 to January 1, 2015 utilize a combustion device
with continuous ignition or perform “green completions with
combustion at gas wells.
Beginning January 1, 2015: Perform green completion, routing
all “salable quality gas” to the flow line as soon as practicable
and combusting all gas that is not suitable for the flow line
Next step- extend to oil production
Green Completions- New Source Standard
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● GHG Reporting is applicable to specific segments of the
petroleum and natural gas industry that emit GHGs
greater or equal to 25,000 metric tons of CO2Eq per year
● Not a control requirement, rather sources must monitor
and report GHG emissions annually to EPA. Intended
as an information tool to track progress and inform
policy decisions
● Amendments proposed December 9, 2015
● Adds a number of potential sources of GHG emissions
to the reporting requirements
Green House Gas (GHG) Reporting
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● 2013- 2100 Facilities
● 224 Million Metric Tons of CO2e
Green House Gas Reporting –Oil and Gas
Sector
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Flaring in the Eagle Ford
NASA Night Photo of Eagle Ford
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Flaring in the Bakken
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● Flaring of associated gas-Priority action area for EPA
and state regulators
● Reasons for Flaring of Associated Gas:
● Lack of natural gas infrastructure
● Gas plant shutdowns;
● Complications and restrictions on gas line construction
● Proximity to pipelines
● Pressure of the produced gas
● No pipeline capacity
● Inert gas concentrations
Flaring
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● Global Gas Flaring Reduction Partnership
● North Dakota policy on flaring-June 1, 2014
● BLM Proposed Rules on Venting, Leaks, and Flaring
● EPA White Paper on Completions
● Notes the development of new techniques for avoiding the
flaring of gas: Liquification, NGL recovery, gas reinjection,
electrical generation
● Suggestion: Success will ultimately depend on the
availability of gas infrastructure
Activities to Address Flaring
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Methane, CO2 and Climate Change
● White House Climate
Plan- June 2013
Announced that EPA
would commission a
series of white papers
regarding methane
emissions from oil and
gas industry
● White Papers
Completions
Compressors
Leaks
Liquids Unloading
Pneumatic Devices
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● White House Plan to Control Methane Emissions from the Oil and
Gas Industry
● Standards to address additional new and modified sources within
the industry
Proposal in August of 2015 with final rule in 2016
● Efforts to address existing sources
The New Focus on Methane at the Federal Level
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IR Camera
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● Sources of Water
● Disposal, Recycling, and Treatment
● Protection of Groundwater Resources
● Protection of Surface Water Resources
Water Issues
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Uses of Water
● Enhanced recovery
● Drilling and Completion
● Workover and
Recompletion
● Solution of Underground
Salt Formations
● Cooling and Boiler
Water
● Hydrostatic Testing
● Rig wash water
● Coolant for engines and
compressors
● Sanitary purposes
● Laboratory purposes
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● On average 2 to 5 million gallons of water (but as high
as 8) per well to complete a multistage hydraulic
fracture
● The amount of water recovered in flowback can vary
greatly, 15% to 80%
● Increasingly, companies are reusing the flowback and
produced water in fracking
● Substantial volumes of both flowback and produced
waters are still disposed by deep well injection
Volumes of Water Used in Fracking
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● In 2011 water consumption for fracking in the Barnett Shale was
32% of Texas fracking water use and .2% of state water
consumption. Statewide the oil and gas industry accounts for 1%
of overall water use
● In 2013 operators used 19 billion gallons of water for fracking in the
Eagle Ford Shale
● There has been a 60% increase in water use per well since mid
2000’s
● City of Houston loses 22 billion gallons of water each year to
pipeline leaks. Statewide total municipal losses (54% of cities
reporting) equaled 225 billion gallons.
More on Volumes
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● Marcellus: Mostly surface water
● Bakken, Eagle Ford, and Permian: Mostly groundwater
● Barnett: About 50-50
Sources of Water
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Why is water a big deal?
Texas Drought Map 2011 vs. 2016
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● In Texas, use of surface water for oil and gas operations
is limited to areas near major rivers (Rio Grande, Trinity)
● Surface waters are used extensively for oil and gas
operations in Louisiana, Arkansas, and Pennsylvania
● Extensive regulations applicable to Operators obtaining
surface water (Corps permits, state permits)
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Surface Waters and Oil and Gas
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● Reuse technologies are being pioneered in plays
outside of Texas
● 70% of the water in Marcellus is recycled
● Quality of wastewater varies with geography
● Reuse technologies include:
● Reverse osmosis
● Electrodeionization
● Flocculation
● Blending
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Wastewater Reuse
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● Chlorides and TDS – increases friction
● Turbidity and Total Suspended Solids (TSS) – can plug
well and decrease biocide effectiveness
● Water hardness
● Sulfates – can be used by bacteria to create hydrogen
sulfide
● Barium – combines with sulfates to create scale
● High iron – can drop out and create plugging
● Bacteria
● Potential for NORM in solids
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Wastewater Reuse Challenges
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● 2013 Texas Railroad Commission amended its rules to
promote recycling
● No permit for recycling needed if operators are
recycling fluid on own leases or transferring fluids to
another operator’s lease for recycling
● Established five categories of commercial recycling
permits
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Texas Recycling Regulations
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● Halliburton has developed a frack fluid technology that
allows the use of brackish water having solids content
similar to sea water
● Apache Corporation announced late in 2013 that it now
is completely off fresh water for HF in Permian Basin
operations sourcing its water from recycled flowback
and brackish formation water.
● Pioneer Natural Resources struck a deal with the City of
Odessa to take the city’s treatment plant effluent for use
in exploration and production.
Specific Examples
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● Federal Water Pollution Control Act 1972 and Clean
Water Act of 1977
● State and Tribal Laws
Federal Clean Water Act
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● No direct discharge of process waters
● Discharge of uncontaminated storm water
● Discharges to POTWs
● Deep Well Injection of Flowback and Produced Waters
● Recycling, Reuse, and Sourcing
Recycling, Reuse, Discharge
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● Common public misconception in the U.S. - that the oil
and gas industry is not regulated
● A long history of regulation dating back to 1879 in NY,
1890 in PA, 1917 in OK and TX, and 1915 in CA
● Casing and Plug and Abandonment designed to protect
oil from groundwater also protected groundwater from
contamination.
Protecting Groundwater Resources
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State Regulatory Requirements Designed to
Protect Water
● Permitting (all 27
states)
● Prescribed drilling
and construction
methods
● Regulation of
exploration and
production waste
fluids
● Required closure of
wells
● Required
abandonment of well
sites
● Regulation of other
oil and gas activities
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Safe Drinking Water Act (SDWA)
● Enacted in 1974, the SDWA is the primary federal
statute addressing actual injection
● Under the SDWA, the EPA has created the Underground
Injection Control (UIC) program
● Energy Policy Act of 2005 exempts from definition of
“underground injection” fluids or propping agents
injected in hydraulic fracturing related to oil, gas, or
geothermal production
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● Database managed by the Ground Water Protection
Council and the Interstate Oil and Gas Compact
Commission
● GWPC: a non-profit organization of state water quality
regulatory agencies
● IOGCC: a multi-state government agency charged with
balancing oil and gas development with environmental
protection
FracFocus- Information and Transparency
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● FracFocus
The primary purpose of this site is to provide factual information
concerning hydraulic fracturing and groundwater protection. It is not
intended to argue either for or against the use of hydraulic fracturing
as a technology. It is also not intended to provide a scientific analysis
of risk associated with hydraulic fracturing. While FracFocus is not
intended to replace or supplant any state governmental information
systems it is being used by a number of states as a means of official
state chemical disclosure. Currently, twenty-three states use
FracFocus in this manner.
Finally, this site does not deal with issues unrelated to chemical use
in hydraulic fracturing such as Naturally Occurring Radioactive
Material (NORM).
FracFocus and Disclosure Issues
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States Using FracFocus
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● What Chemicals Are Used?
● Access to Records
FracFocus- Ingredients not the Recipe
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● EPA
● BLM
BLM rules apply to 700 million subsurface acres of Federal
mineral estate and 56 million subsurface acres of Indian mineral
estate
98% of all wells on BLM land located in CA, CO, MT, ND, NM, UT,
and WY
Federal Agencies Struggling with Role in
Insuring Access to Information
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Waste
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Water Disposal
● Both flowback and
produced waters are
disposed of through Salt
Water Disposal wells
● SWD wells are regulated
as Class II disposal wells
under the federal Safe
Drinking Water Act
Underground Injection
Control (UIC) program
● We can expect to see
increased attention given
to the use of SWD wells
Scarcity of Water as a
Resource
Concern about
Groundwater Pollution
and Overpressurization
Induced Seismicity
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● Publicly Owned Treatment Works
● Brine Plants - Facilities designed to remove
contaminants from produced water and HF flowback
● Effluent discharged to surface waters under a Clean
Water Act permit
● Questions about efficacy of removal technology
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Treatment Options
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● Oil and gas exploration and production wastes are
exempt from regulation as hazardous waste
Not related to toxicity or other hazardous characteristic but
rather to origin of the waste
• Product of a different time
Solid wastes associated with exploration and production are
subject to state regulation
Waste
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● Possible Sources
Well Sites
Storage
Transportation
Disposal Wells
Casing Failure
● National Contingency Plan
Spills and Releases
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Must Report to the National Response Center the
Discharge of oil in such quantities as ‘‘may be harmful’’
pursuant to section 311(b)(4) of the Clean Water Act.
(a) Violate applicable water quality standards; or
(b) Cause a film or sheen upon or dis-coloration of the surface of the water
or adjoining shorelines or cause a sludge or emulsion to be deposited
beneath the surface of the water or upon adjoining shorelines.
National Contingency Plan
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The Oil Pollution Act of 1990
● Response to Exxon Valdez
● Addresses Spill Prevention, Reporting, and Response
● Requires Spill Prevention, Control, and Countermeasure (SPCC) Plan if the facility has a storage capacity of:
● 1,320 gallons abovegroundWho is covered? Aggregate aboveground oil storage capacity greater than 1320 gallons and there is a reasonable expectation of an oil discharge into or upon navigable waters of the U.S. or adjoining shorelines
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● A mixture of wastewater and oil is “oil” under the
statutory and regulatory definition of the term
● Produced water is a example of an oil and water mixture
● Produced water from a “dry gas” production facility is
not subject to the SPCC rule.
What about produced water?
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● What do you have to do?
Prevent oil spills
Prepare and implement an SPCC Plan:
• Operating procedures at the facility to prevent oil spills
• Control measures installed to prevent oil spills from entering
navigable waters or adjoining shorelines
• Countermeasures to contain, cleanup, and mitigate the effects
of an oil spill that has impacted navigable waters or adjoining
shorelines.
SPCC Plans
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Tanks Within Containment at a Production Site
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Heater Treater and Separators Within
Containment at a Production Site
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● If regulated by the SPCC rule, must report the discharge
to EPA when more than 1000 U.S. gallons of oil are
discharged to navigable waters or adjoining shorelines
in a single event.
● More than 42 U.S. gallons in each of two discharges
within any twelve-month period.
● Don’t forget local and state notification requirements.
SPCC Plans and Reporting
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● Endangered Species Act
● Migratory Bird Treaties Act
● The Bald and Golden Eagle Protection Act
● Wetlands and Other Waters of the United States
Siting Issues
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North American Shale Plays and Siting Issues
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● Mussels in Arkansas and potentially elsewhere
● Dune Sagebrush Lizard
● Lesser Prairie Chicken
● Greater Sage Grouse
ESA Issues in the Oil Patch
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● The Speckled Pocketbook Mussel and the Hills of
Arkansas
● Texas is home to 12 state-threatened freshwater mussel
species that are under review for federal listing as
threatened or endangered
Fresh Water Mussels
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Wetlands and Other Waters of the U.S.
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Environmental Audit - A Definition
A systematic evaluation,
review, or assessment
of a facility or operation
or an activity at a facility
or operation to
determine compliance
with environmental laws
or any permit issued
under those laws
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Why Environmental Auditing?
• Environmental issues can be a significant source of liability
• A primary function of corporate leadership is management and avoidance of risk
• Important to understand the sources of liability and techniques or tools available to control or avoid it
• Auditing is a key ingredient to informed decision making and risk avoidance and a key component of environmental management
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Environmental Issues in Transactions
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Types of Liability
• Liability for conditions on the property
• Liability for offsite conditions caused by the onsite operations
• Liability for offsite shipments (CERCLA or Superfund liability)
• Liability for violations of permits and laws governing operations (air, water, solid waste)
• Third party claims
• Contractual obligations
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Factual Sources of Environmental Risk
Environmental Conditions Activities
Air Emissions
Water Discharges
Waste Management
Hazardous Materials
Handling
Conduct of
Business Activities
Potential Contaminants /
Structures
Asbestos
Lead Paint
Contaminated Soil /
Groundwater
PCBs
Indoor Air Pollution
Vapor Intrusion
Tanks
Specially Protected
Property or Biota
Endangered Species
Historic Sites
Wetlands
Floodplains
Sole Source Aquifer
Protected Watershed
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Benefits of Due Diligence
● Risk Avoidance –
● Remove well sites and facilities that present unacceptable risks of liability due to contamination or significant compliance issues
● Risk Management
● Remediate conditions or bring operations into compliance before closing
● Address known conditions and risk of unknown conditions in deal terms (price adjustments and post closing obligations)
● Use regulatory programs and defenses to address conditions and avoid liability
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Due Diligence – Basic Concepts
● Due Diligence – One size doesn’t fit all.
● Factors influencing the scope of diligence
● Familiarity with properties, past operations, and the conditions
involved
● Level of site development and nature of operations
● Time and cost considerations
● Buyer’s tolerance for risk and dependence on third parties
(lenders)
● Seller’s continued existence and viability
● Representations and warranties
● Disclosures
● Defect process
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Key Environmental Issues
in Transactional Due Diligence
• Onsite conditions and releases (Phase I and II)
• Compliance
• Permits and licenses
• Potential liability for offsite conditions
• Records
• Communications with regulatory agencies
• Environmental management system
• History of prior ownership or operators
• Insurance coverage
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Due Diligence – Be Specific
as to Consequences
● Buyer’s alternatives
● Don’t close
● Remove specific properties
● Condition closing on correction
● Obtain concession on price
● Accept with escrow
● Indemnity? Probably not if deal relies upon a defect process
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Due Diligence – Be Specific
as to Consequences
● Seller’s alternatives
● Fix it
● Deny the problem or contest the cost of the solution in the defect process
● Adjust price
● Exclude asset
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● USGS estimates that there are several million
earthquakes each year
● Many go undetected-microearthquakes
● Naturally Occurring vs. Induced Seismicity or Triggered
Seismicity
● Number of quakes is increasing
● Average number 1970 to 2000=20 per year over 3.0
● Average number 2010 to 2013= 100 per year over 3.0
Seismic Activity
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Seismic Activity
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Increases in Seismic Activity
● Oklahoma
● Ohio
● Kansas
● Texas
● Azle
● Reno
● Cleburne
● Irving
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2011 Prague, Oklahoma Earthquake Damage
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● Mining
● Dam and Reservoir Construction
● Deep Well Injection Through Class 2 Wells
● Approximately 150,000 such wells
● Very small percentage of these wells associated with Induced
Seismicity
● Fracking?
Sources of Induced Seismicity
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Induced or Triggered Seismicity
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● Hired of a State Seismologist
● Provide the results of a survey review of information
from the USGS regarding the locations of any historic
seismic events within a circular area of 100 square
miles centered around the proposed disposal well
location.
● May require more information if necessary to demonstrate that
fluids will be confined if well is located in an area where
conditions exist that may increase the risk that the fluids will not
be confined to the injection interval.
Texas Response
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● The permit may be modified, suspended, or terminated by the
commission for just cause after notice and opportunity for hearing,
if:
Injection is likely to be or determined to be contributing to
seismic activity
● Commission can require more frequent monitoring of the well and
reporting to the commission if it finds that conditions exist that
may increase the risk that fluids will not be confined to the injection
interval. Such conditions may include, but are not limited to,
complex geology, proximity to the basement rock to the injection
interval, transmisive faults, and/or a history of seismic events in the
area as demonstrated by the information available from the USGS.
Texas Response
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● Small quakes
● Lack of adequate monitoring network
● Large number of injection wells
● Texas has over 7500 active class 2 disposal wells
● Other contributing factors- quakes are a natural
process
Difficulty in Making the Connection
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● Further Research Underway- Texas Study
● Multistate Working Group
● Better Monitoring and Information Gathering Process
● “Traffic Light” System
● Dependent upon an improved monitoring system
● Oklahoma Experience
Current Approach
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● Negligence
● Negligence per se
● Nuisance
● Nuisance per se
● Trespass
● Strict Liability-Ultrahazardous or Abnormally Dangerous
Activity?
Tort Theories and Oil and Gas Development
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● Over 80 cases filed nationwide in 10 states including
AR, CO, LA, NY, ND, OH, OK, PA, TX, WV
● 23 dismissed, 21 settled, 30 pending, other status
The numbers
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Local ordinances and regulation
Photo Courtesy TxDOT
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● A person, group or entity that has interest or concern in
an organization and its activities is consider a
stakeholder. Stakeholders can affect or be affected by
the organization’s actions, objectives, and policies.
● Examples: employees, partners, suppliers, investors,
customers, communities, consumers and consumer
associations, mineral rights owners, landowners, media,
special interest groups, and non-governmental
organizations, government (local, state, and federal
elected officials) and shareholders
What is a “stakeholder?”
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● What contributes to NIMBY?
● Conflicting Interests
● Actions by local governments
● Actions by state governments
Not in My Backyard (NIMBY)
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● What is it?
● Are there ways to plan for it?
Boom & Bust Cycle
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HF Studies – Who?
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HF Studies
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HF Studies – a sample
● Government Studies
● EPA
● DOE
● Academic Studies
● Duke
● Colorado School of Public Health
● Interest Group Studies
● Barnett Shall Energy Education Council
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EPA’s 2010 study of HF and potential impacts
on drinking water resources
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EPA Study: Questions being asked
● What is the quantity and quality of well cement in the industry?
● What is the extent of integrity testing?
● What chemicals are used?
● What drinking water resources are located near wells?
● What baseline water quality monitoring is conducted?
● What is the water source for HF operations?
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EPA Study: Questions being asked
● What are the potential impacts to drinking water treatment facilities?
● Does the discharge of treated hydraulic fracturing wastewater contribute to the formation of disinfection by-products?
● How do hydraulic fracturing wastewaters affect the efficacy of activated sludge wastewater treatment processes?
● Does hydraulic fracturing occur more often in counties home to predominantly low-income, minority, young, or elderly populations?
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EPA Study
● Conclusions:
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EPA Study – Pavillion Wyoming
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Pavillion
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EPA Study – Pavillion, Wyoming
● December 2011 EPA published draft report
● Conclusion: Hydraulic fracturing may have led to groundwater contamination; glycol ethers and other compounds detected
● But EPA also stated that improper casing and cementing of wells, or discharges from legacy pits may have caused problem
● Findings disputed by industry groups and Wyoming regulators
● Sept. 2013 – EPA discontinued study
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US Department of Energy Study (2011)
● Task: Identify measures to reduce the environmental
impact and help assure the safety of shale gas
production
● Initial 90-Day Report: 20 recommendations
● Final Report : How to implement recommendations
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US Department of Energy Study (2011)
● Improve public information
● Improve regulator communication
● Reduce emissions of air pollutants, ozone precursors, and methane
● Acquire data regarding overall greenhouse gas footprint of natural gas use
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US Department of Energy Study (2011)
● Encourage efforts to reduce air emissions using proven technologies and practices
● Additional field studies on methane migration from shale gas wells to water reservoirs
● Disclosing fracturing fluid composition
● Elimination of diesel use in fracturing fluids
● Expand DOE, EPA, and USGS funding for R&D
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US Department of Energy Study (2011)
● Measure and publicly report the composition of water
stocks and flow throughout the fracturing process
● Manifest all transfers of water among different locations
● Adopt best practices in well development and
construction, especially casing, cementing, and
pressure management
● Adopt requirements for background water quality
measurements
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Duke University Study – Marcellus GW
● Analyzed water from drinking water wells in PA and NY
● Looked for correlations between methane concentrations in the drinking water wells, and proximity to Marcellus shale gas wells
● Defined “active” drilling area as area within 1 km of gas well
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Duke University Study – Marcellus GW
● Methane detected in 51 of 60 drinking water wells (85%)
● Correlation between methane concentrations in drinking water wells and proximity to nearest natural gas well
● Methane concentration 17X higher in shallow wells in active drilling and extraction areas than non-active areas
● methane in water wells in active areas was consistent with thermogenic (deeper) methane sources
● methane in water wells in non-active areas was consistent with biogenic (shallower) methane sources
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Duke University Study – Marcellus GW
● Did not detect brines or fracturing fluids in any of the water wells
● Possible mechanisms identified to explain presence of thermogenic methane in water wells in active areas
● Physical displacement of gas-rich solutions from deep formations (unlikely)
● Leaky gas well casings
● Fracturing process increases connectivity of historical faults and wells, allowing deep gas to reach shallow aquifers
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● Looked at methane and chloride concentrations in 127
wells
● Asked: Thermogenic or biogenic?
● Groundwater quality is derived from natural processes
and not affected by natural gas production activities
● What is different in Arkansas v. Pennsylvania?
Duke University Study – Fayetteville GW
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● Vertical migration of fracturing fluids unlikely, but not
impossible
● Potential for groundwater contamination from:
− Faulty or inadequate steel casings
− Imperfections in the cement sealing of the annulus
What do these studies show about
groundwater?
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Duke University – Surface Water
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● Water quality and isotopic composition of effluent,
surface waters, and sediments
● Elevated chloride, bromide, barium and radium
● Consistent with Marcellus produced waters
● 226Ra levels in stream sediments at discharge point were
200x greater than background and above radioactive
waste disposal thresholds
Duke University – Surface Water
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● Potential for surface water contamination through
spills and inadequate treatment of flowback
● Potential for surface water quality to be affected by
discharge of treated produced water
What do these studies show about surface
water?
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Studies – Air Quality
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Studies – Air Quality in the Barnett Shale
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TCEQ Air Monitoring Sites
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● No compounds detected above levels sufficient to
create short-term acute threat
● 1,2 dibromoethane present at level considered sufficient
to pose chronic threat at two sites near local airports
● “Shale gas production activities have not resulted in
community-wide exposures to chemicals at levels that
would pose a health concern.”
Barnett Shale Energy Education Council
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● Unconventional O&G operations result in emissions
of VOCs
● Debate about the relative health effects of such
emissions
● Expect greater focus on air quality in plays with
greater urban and suburban populations
What do these studies show about air quality?
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● Methane escapes during well drilling and completion
● Methane escapes from pneumatic controllers and other
equipment
● A number of studies have attempted to quantify fugitive
methane – 2012 NAS paper: 0.42% of gross gas
production
Studies – Climate Change
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Seismic Activity
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● July 3, 2014 Study - Science
● Fluid migration from high-rate disposal wells is
potentially responsible for earthquake swarms
Seismic Activity
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● Broad summary of literature:
● Water supply - Unconventional drilling water demand
can be better or worse than alternatives.
● Drinking water contamination – risk is poor well
integrity and wastewaters
● Induced seismicity – wastewater injection, felt
earthquakes uncommon
● Air – emissions quantities uncertain, but potential to
improve air quality over alternatives
2014 Stanford/MIT
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● More science
● Greater transparency regarding potential biases
● Recognition by industry that establishment of binding
standards may have benefits
● Disclosure laws
● API well construction standards
How should uncertainty be addressed?
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● Proactive approach to address areas of greatest
concern
● Well construction standards
● Water use, reuse, and disposal
● Air quality impacts
● Climate change
How should uncertainty be addressed?
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