The Urgent Case for a Ban Fracking - Europe

8/9/2019 The Urgent Case for a Ban Fracking - Europe

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Food & Water Europe

About Food & Water Europe

Copyright © September 2014 by Food & Water Europe. All rights reserved.

This report can be viewed or downloaded at foodandwatereurope.org.


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The Urgent Case for a Ban on Fracking i

I

n many ways, racking is he environmenal issue o our ime. I’s an issue ha

ouches on every aspec o our lives — he waer we drink, he air we breahe, he

healh o our communiies — and i is also impacing he global climae on whichwe all depend. I pis he larges corporae ineress — big oil and gas companies and

he poliical leaders who suppor hem — agains people and he environmen in a

long-erm sruggle or survival. I is an issue ha has capivaed he hears and minds

o hundreds o housands o people across he Unied Saes, Europe and across he

globe. And i is an area in which, despie he massive resources o he Frackopoly — he

cabal o oil and gas ineress promoing his pracice — we as a movemen are making

remendous srides as our collecive power coninues o grow.

Food & Waer Europe is proud o work shoulder o shoulder wih communiies across Europe and across he world in

his effor. Wih mouning evidence abou he harms o racking and he immediacy o he impending climae crisis,

his repor lays ou he urgen case or a ban on racking.In 2009, we became alarmed abou he hrea ha hydraulic racuring (racking) posed o waer resources across

he Unied Saes. Communiies around he Unied Saes were already raising he alarm abou he ill effecs ha

racking was having, rom increased ruck raffic o spills and even ap waer ha could be li on ire hanks o

mehane leaks rom racking wells ino waer sources.

Meanwhile, many naional environmenal groups were ouing naural gas as a “bridge uel” — a beter means o

producing energy rom ossil uels han coal, a source ha everyone knew we had o move away rom urgenly o

reduce he carbon emissions ha were heaing he plane a a dangerous rae. Communiies ha were already eeling

he effecs o he echnology, or ha were ighing he coming wave o racking, el berayed ha he place hey

lived could become one o he sacriicial zones — wih many environmenaliss’ blessing. Over he nex ew years,

scieniic evidence would moun ha no only is racking no climae riendly, bu i has he poenial o unleashmassive amouns o mehane ha will conribue o climae disaser.

So we began our work on racking wih Not So Fast, Natural Gas , our repor ha raised serious quesions abou

racking saey and he naural gas rush being promoed by indusry and governmen. Tha repor, released in 2010,

called or a series o regulaory reorms, bu he evidence coninued o moun. The nex year, afer looking a even

greaer evidence o he inheren problems wih racking, and realizing how inadequaely he saes were regulaing

he oil and gas indusry and enorcing hose regulaions, Food & Waer Europe was one o he irs European organ-

isaions o call or a complee ban on racking and we released he repor The Case for a Ban on Gas Fracking .

Since he release o ha repor in 2011, more han 150 addiional sudies have been conduced on a range o issues

— rom waer polluion o climae change, air polluion o earhquakes — reinorcing he case ha racking is simply

oo unsae o pursue. In he ace o such sudies, and ollowing he lead o grassroos organizaions ha have been a

he oreron o his movemen, a consensus is emerging among hose working agains racking ha a ban is he only

soluion. No only are decision-makers no regulaing he pracice o racking, i is so dangerous and he poenial so

grea ha i canno be regulaed, even i here were he poliical will.

As his repor lays ou, here is mouning evidence ha racking is inherenly unsae. Evidence builds ha racking

conaminaes waer, pollues air, hreaens public healh, causes earhquakes, harms local economies and decreases

propery values.

And mos criically or he survival o he plane, racking exacerbaes and acceleraes climae change. We are acing

a climae crisis ha is already having devasaing impacs and ha is projeced o escalae o caasrophic levels i we

do no ac now. Our eleced officials ou racked gas as a “bridge uel,” ye mouning evidence suggess ha raherhan serving as a bridge o a renewable energy uure, i’s a bridge o a climae crisis.

Letter from Wenonah HauterExecutive Director, Food & Water Europe


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ii Food & Water Europe

While he environmenal, public healh and ood movemens have looked a mouning evidence and rejeced racked

gas and oil, Presiden Obama and his adminisraion have aggressively promoed naural gas and domesic oil as a

criical par o he Unied Saes’ energy uure. Presiden Obama repeaedly ous domesic gas producion and has

said ha “we should srenghen our posiion as he op naural gas producer … [I] no only can provide sae, cheap

power, bu i can also help reduce our carbon emissions.” His Energy Secreary Ernes Moniz has close indusry ies

and has claimed ha he has “no seen any evidence o racking per se conaminaing groundwaer” and ha “he

issues in erms o he environmenal ooprin o hydraulic racuring are manageable.”

Despie wha he US governmen and indusry claim, here have now been over 150 sudies on racking and isimpacs ha raise concerns abou he risks and dangers o racking and highligh how litle we know abou is long-

erm effecs on healh and our limied reshwaer supplies. I’s ime or our eleced leaders o look a he acs and

hink abou heir legacy. How do hey wan o be remembered? Wha do hey wan he world o look like 20, 50 and

100 years rom now?

We irs made he case or a ban on racking in 2011, bu his new repor shows ha here is an urgen case or a ban.

The evidence is in, and i is clear and overwhelming. Fracking is inherenly unsae, canno be regulaed and should be

banned. Insead, we should ransiion aggressively o a renewable and efficien energy sysem.


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The Urgent Case for a Ban on Fracking 1

Executive Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2

Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2

Water and Land Impacts . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4

Water consumption . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5

Impacts on surface waters, forests and soils . . . . . . . . . . . . . . . . . . . . . . . . . . 6

Aquifer contamination . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8

Mehane and oher hydrocarbon gases . . . . . . . . . . . . . . . . . . . . . . . . . . 8

Hydrocarbon gases in aquiers as a sign o more problems o come . . . . . . . . . . 10

Earthquakes, Lightning Strikes and Exploding Trains . . . . . . . . . . . . . . . . . . 13

Air and Climate Impacts. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14

Silica dust. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .14

Byproducts from combustion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .15

The pollutants that oil and gas companies bring to the surface . . . . . . . . . . . . . . . . 15

Emissions are larger han officials esimae . . . . . . . . . . . . . . . . . . . . . . . . 16

Naural gas dependence causes more global warming han hough . . . . . . . . . . .18

Public Health, Economic and Social Impacts . . . . . . . . . . . . . . . . . . . . . . . 20

Ban Fracking and Usher in a Safe and Sustainable Energy Future . . . . . . . . . . . 22

TABLE OF CONTENTS


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2 Food & Water Europe

Executive SummaryThe erm “racking” has come o mean more han jus

he speciic process o injecing large volumes o various

mixes o waer, sand and chemicals deep underground,

a exreme pressure, o creae racures in argeed rock

ormaions — all so ighly held oil and gas migh low.

We now use he erm racking o represen all ha his

speciic process o hydraulic racuring enails. Allowingmore racking means ha oil and gas companies will

coninue o:

Fragment forests and mar landscapes wih new

roads, well sies, wase pis and pipelines;

Compete with farmers for local water supplies

while consuming millions o liers o waer or each

racked well;

Produce massive volumes of toxic and even

radioactive waste, he disposal o which is causing

earhquakes and puting a risk drinking waerresources;

Cause thousands of accidents, leaks and spills

each year ha hreaen public healh and saey

and pu a risk rivers, sreams, shallow aquiers and

arms;

Pump hazardous pollutants into the air, a he

expense o local communiies, amilies and arms;

Turn homes into explosive hazards by conami-

naing waer wells wih mehane and oher lam-

mable gases; Put vital aquifers at risk for generations by

creaing new pahways or he poenial low o

conaminans over he coming years and decades;

Destabilize the climate on which we all depend

wih emissions o carbon dioxide and mehane and

by locking in uure climae polluion wih new oil

and gas inrasrucure projecs; and

Disrupt local communities, wih broad physical

and menal healh consequences, increased demand

on emergency and oher social services, damage o

public roads, declines in propery value, increased

crime, and losses el in esablished secors o local

economies.

In 2011, Food & Waer Europe called or a ban on

racking because o he signiican risks and harms ha

accompany he pracice. Now, over hree years laer,

numerous peer-reviewed sudies published in scieniic,

legal and policy journals have expanded wha is known

— and clariied wha remains unknown — abou he

environmenal, public healh and socioeconomic impacs

ha sem rom racking. In his repor, Food & Waer

Europe reviews he science and renews is call or a ban.

We ind ha he open quesions amoun o unaccepable

risk, and ha he harms are cerain. Sringen regulaions,

even i pu in place and even i adequaely enorced,

would no make racking sae. Municipal bans, mora-

oria and zoning laws are being passed o ry o proec

communiies across he counry, bu ederal and sae

level acion is necessary o reverse he spread o racking.

The only pah o a susainable economic uure is o

rebuild he our energy sysem and local economies around

sae energy soluions: efficiency, conservaion and renew-

able resources. Fracking akes us in he wrong direcion.

IntroductionHydraulic racuring allows oil and gas companies oarge underground layers o rock ha hold oil and

gas, bu ha do no readily allow he oil and gas o

low up a well. Drilling hrough hese rock ormaions,

hen injecing a blend o waer, sand and chemicals a

exreme pressure, creaes racures propped open by he

sand, exposing oherwise ighly held oil and gas and

allowing i o low.

PHOTO BY HENDRIK VOSS


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In response o declines in convenional producion, and

o he lack o access o many inernaional sources o

oil and gas,1 companies are now racking in he Unied

Saes on an unprecedened scale. (See Box 1.) Acids are

also being injeced, paricularly in Caliornia and perhaps

increasingly in Florida, o ea away new pahways or oil

and gas o low, wih or wihou creaing new racures.2

The oil and gas indusry enjoys avored saus under

he law and an enrenched posiion in U.S. poliics,

economics and insiuions. This creaes an ineria ha

imperils curren and uure generaions, and endangers

our economy, as we ace he consequences o global

warming and he legacy o he indusry’s polluion.

The curren saus quo a he ederal level, and in many

saes, is o encourage as much drilling and racking or

oil and gas as possible. Increased poliical and legislaive

gridlock in Washingon, D.C. has helped o mainain

his saus quo.14 Those wih large sakes in oil and

gas producion — a angle o oil and gas companies,

engineering and consrucion irms, environmenal

consulancies, rade associaions, public relaions and

markeing irms, inancial insiuions and large indi-

vidual invesors — sand o proi rom his saus quo.

Revolving doors and srucural ies beween he indusry

and sae and ederal agencies,15 academic research

groups ha ac as saellie indusry labs and hink

anks,16 and indusry conrol o access o daa and sies,17

as well as echnical experise,18 all illusrae he exen o

he oil and gas indusry’s capure o U.S. energy policy.The oil and gas indusry’s inluence is releced in he

exempions ha i enjoys in key provisions o all o he

landmark environmenal laws, including he Clean Air

Ac, he Sae Drinking Waer Ac, he Clean Waer Ac

and laws regulaing hazardous wases.19

Over a rillion dollars in “sunk” coss in inrasrucure

avors he saus quo o dependence on he oil and gas

indusry, serving as a barrier o he remaking o he U.S.

energy sysem.20 The oil and gas indusry receives abou

$4 billion each year in direc axpayer-unded subsidies.21 The Sierra Club and Oil Change Inernaional recenly

calculaed ha subsidies o he ossil uel indusry in

2009 and 2010 amouned o a 59 o 1 reurn on he

money ha he indusry spen hose years on lobbying

and on inancing poliical campaigns.22 The European

Union should no ollow he energy policies ha have

prevailed in he US

In his repor, Food & Waer Europe summarizes recen

scieniic lieraure on he waer polluion, landscape

changes, air polluion, climae polluion and wasedisposal problems brough on by drilling and racking or

The scale of fracking To hydraulically fracture a modern onshore oil or

gas well, batches of millions of liters of water, tons of

sand and thousands of liters of chemicals get injected

repeatedly, typically in tens of stages along a two and

a half kilometer long, several-inches-wide tunnel,

or borehole, that runs laterally through a targeted

rock formation thousands of feet below ground. Oil

and gas companies are now doing this more than10,000 times each year in the United States to extract

so-called shale gas, tight gas and tight oil.3 Acids are

and this is not always done at pressures high enough

largely unknown, but the practice is clearly on the rise

and a focus of the oil and gas industry.4

In 2012, the U.S. Energy Information Administration

estimated that bringing the projected amounts of

technically “recoverable” — as if recovering some-thing lost — shale gas and tight oil into production

would require drilling and fracking over 630,000 new

onshore wells.5 If this happens, many thousands of

the wells envisioned are likely to have cementing and

casing issues from the outset, and all of them will age

and degrade over subsequent years and decades,

putting at risk underground sources of drinking

water.6 Given that initial fractures release just a small

fraction of the oil or gas held in targeted source rocks,

industry will also seek to re-fracture many thousands

of these wells to try to reverse the typically rapid

declines in production as they age.7

A 2013 analysis from the Wall Street Journal found that

over 15 million Americans are living within one and a

half kilometers of a well drilled after the year 2000,

when large-scale hydraulic fracturing operations

began.8 Many more live alongside other polluting

infrastructure that supports oil and gas production,

including processing plants, compressor stations

passed actions in opposition to drilling, fracking and

supporting infrastructure.9

Oil and gas companies have piled up over $100 billionin debt, in large part to support drilling and fracking

and related infrastructure.10 Data from the major

publicly listed oil and gas companies show that from

2008 to 2012, collective capital spending increased by

about 32 percent, while, at the same time, oil produc-

tion fell by about 9 percent.11 Evidently the industry

is banking that increased drilling and fracking into

the future, coupled with increased oil and natural gas

that oil and gas prices rise.12 Industry’s bubble will

burst, not least because society’s systematic depen-

dence on fossil fuels is posing an existential threat by

destabilizing our climate.13


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oil and gas. These impacs are due in large par o he

oxic naure and pervasive spread o he chemical pollu-

ans ha he indusry brings o he surace. (See Box

2.) Recen research urher reveals how hese and oher

impacs collecively damage public healh and disrup

communiies.

Pu simply, widespread drilling and racking or oil and

gas is inherenly unsae and erribly shorsighed. Thisrepor explains why i is ime or a ban. The oil and

gas indusry’s corruping inluence on American policy

and governmen hreaens o coninue he harm, and

o coninue o supplan proven and sae soluions or

meeing energy needs.

Water and Land ImpactsThe oil and gas indusry’s capure o U.S. energy policy

has colored several high-proile invesigaions o aquier

conaminaion in he afermah o drilling and racking,

namely in Pavillion, Wyoming, in Dimock, Pennsylvania,

and in Parker Couny, Texas.

The pollutants that the oil and gas industry brings to the surface

“Natural gas,” “natural gas liquids,” “crude oil,” “drilling muds” and “produced water” are innocuous-sounding terms

that conceal the nature of all that the oil and gas industry brings to the surface.

of hydrocarbons is called crude oil when the bulk of the hydrogen and carbon atoms that make up the mix are

bound together in large molecules, and the mix is liquid when it reaches the surface.23 The term natural gas liquids

2

6),

3

8

4

10) and other lightweight hydrocarbon chains — that happen to be somewhat wet to

the touch at moderate temperatures and pressures.24 The term natural gas is used broadly to refer to various gases

4),25 a potent greenhouse gas26 and a primary driver of global warming.27

But drilling and fracking brings much more to the surface than just these hydrocarbons.

the chemical compositions vary in time and vary from well to well, but are otherwise not well characterized.28

Many of the hydrocarbons brought to the surface are hazardous pollutants, including volatile organic compounds

aromatic hydrocarbons.29

with ancient salt waters, or brines.30

sodium”31 32), and radioactive material

33

Finally, oil and gas companies bring to the surface various amounts of the chemicals used in fracking, and byproducts

from reactions involving these chemicals.34 Given trade-secret protections in federal and state laws, and otherwise

often even to the company doing the injecting.35

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inducing new fractures.37

With the exception of the fracking chemicals and the byproducts of any fracking

chemical reactions, all of the above chemical pollutants had long been safely

sequestered and immobilized, deep underground. Now, drilling and fracking

brings these pollutants to the surface at baseline levels that risk human health

and environmental damage through water, soil, air and climate pollution. Then

there are the greater-than-baseline levels of contamination: the accidents, leaks,

dangerous to clean up, to the extent that they can be cleaned up.

The liquids, sludge and solids that remain from what the industry does not leak into

the air, spill on the ground, burn or otherwise use, are adding up to create waste

disposal problems. This pollution is part and parcel of the current “all-of-the-above”

approach to U.S. energy policy. All of the above pollutants need to stay underground.

“Mud pit” on a Bakken shaledrilling site.


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In December 2011, he U.S. Environmenal Proecion

Agency (EPA) published a draf scieniic repor on

groundwaer conaminaion in Pavillion, Wyoming,

saing ha wase pis likely conaminaed shallow

groundwaer38 and ha daa on chemicals deeced in

a deeper monioring well “indicaes likely impac o

ground waer ha can be explained by hydraulic rac-

uring.”39 The draf repor called or more monioring

o wells o make he indings o he repor more deini-

ive.40 In he ace o exreme pressure rom he indusry

and rom indusry advocaes in Congress, however, he

EPA decided in 2013 o abandon inalizing he repor.41

Insead, he EPA deerred i o he Sae o Wyoming,

which will rely on he company implicaed in he case o

und a new invesigaion.42 While he EPA claims ha i

sill “sands behind is work and daa,”43 he rerea was

widely repored as a vicory or he indusry.44

In 2012, he EPA similarly rereaed rom is invesiga-

ion o waer conaminaion cases in Dimock, Penn-sylvania,45 which he sae’s environmenal agency had

deermined were due o “drilling aciviies.”46 The EPA

had ound conaminans in several o he waer wells

in quesion, bu simply saed ha “he residens have

now or will have heir own reamen sysems ha can

reduce concenraions o hose hazardous subsances o

accepable levels a he ap.”47 The EPA ailed o evaluae

he reasons or he conaminaion, again leaving he

public wih he alse impression ha affeced residens’

claims o conaminaion had no meri.48

In December 2014, he EPA will issue a draf o a muli-

year sudy on he poenial impacs o racking on

drinking waer resources. In his sudy, he agency is

relying heavily on volunary cooperaion rom he oil

and gas indusry or daa and experise. This reliance on

indusry parly explains he EPA’s rerea on he hird

high-proile case o conaminaion linked o drilling and

racking, in Parker Couny, Texas.49 According o he EPA’s

Inspecor General, a primary reason ha he agency

wihdrew is emergency order agains he company doinghe drilling and racking was ha he company agreed

o paricipae in he EPA’s ongoing sudy.50 This episode,

in paricular, highlighs how he indusry’s conrol over

daa and experise shapes he science and invesigaions

carried ou on behal o he public.

The residens o Parker Couny, Dimock and Pavil-

lion wen o he EPA because hey did no eel ha

heir respecive saes were being responsive o heir

concerns. Texas, Pennsylvania and Wyoming each have

long hisories o promoing oil and gas developmen, in

he name o prevening “wase” o oil and gas reserves,51

and are pary o inersae resoluions o encourage

shale gas exracion and “expansion o naural gas

inrasrucure.”52 The EPA’s unwillingness o complee

invesigaions o hese hree landmark cases o drinking

waer conaminaion means ha he affeced residens

have nowhere else o urn.

Generally, he risks and impacs o waer resources

include he indusry’s compeiion or waer, land and

surace waer polluion, and aquier conaminaion.53

Water consumptionAffordable access o clean waer is a public healh issue,

and a human righ. Public waer sysems already ace

major challenges ha will be exacerbaed by global

warming, in he orm o locally severe droughs, exreme

sorms and oherwise alered rainall, snowall andsnowmel paterns.54 Over a cenury o climae polluion

semming rom he oil and gas indusry conribues

signiicanly o his warming.55

Now, wih widespread drilling and racking, he oil and

gas indusry is no jus adding more climae polluion, i is

adding signiican demand or resh waer in already waer-

sressed regions o he counry. Even worse, i is leaving a

legacy o waer polluion and landscape disurbance.

Waer use per well varies by region, bu companiesypically require abou 20 million liers o waer o drill

and rack a single shale gas or igh oil well.56 Some hori-

zonal wells in he Eagle Ford shale play in Texas have

been racked wih more han 49 million liers each.57

Esimaes vary as o how much injeced luid reurns,

rom beween 5 and 50 percen.58 In he Marcellus

region, beween he irs sage o racking and he ime

he new well is pu ino producion, he liquid ha lows

up he well amouns o only abou 5 percen o he

volume injeced.59 Thus, almos all o he waer used in

racking luids is no available or reuse, and is under-ground indeiniely.

Land is cleared for drilling and fracking in Pennsylvania.


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Oil and gas advocaes claim ha heir waer use is low

relaive o overall waer use, bu saisics ha average

over large regions are decepive. Fracking’s use o waer

can be inensive, happening all in a local hospo or

drilling and racking and all a once or each new well.

Cold-waer sreams in norhern Pennsylvania, where

Marcellus shale developmen is concenraed, have

relaively small low raes,60 ye wihdrawals or rackinghave been primarily rom surace waers, wih wih-

drawals rom public waer sysems indusry’s second

choice.61 Regulaors anicipae increased use o ground-

waer in he region over he coming years i he pace o

drilling and racking coninues.62

A 2014 repor by Ceres looked a indusry-repored

daa on 39,294 oil and gas wells racked beween

January 2011 and May 2013, and deermined ha 39

percen were in regions wih “high waer sress” and

8 percen were in regions wih “exremely high waersress.”63 Waer sress is a measure o waer compei-

ion in a region, and regions wih “high waer sress”

are hose where oal waer wihdrawals (no jus or

racking) make up 40 o 80 percen o he oal waer

available or wihdrawal, while “exremely high waer

sress” means ha more han 80 percen o available

waer is being wihdrawn.64 The repor also deermined

ha over 36 percen o he oil and gas wells included in

he sudy were in regions ha will “experience ground-

waer depleion.”65

To rack he Barnet Shale in Texas, oil and gas compa-

nies used groundwaer and surace waer in equal

measure unil 2006, and increased he use o surace

waer o abou 70 o 80 percen o oal waer use rom

2007 o 2010, bu have since increased groundwaer

wihdrawals.66 The groundwaer wihdrawals are

primarily rom he Triniy aquier, which is “among he

mos depleed aquiers in he sae.”67

A paricular concern is he exen o which oil and gas

companies are compeing wih armers or access o

limied reshwaer resources. In 2012, a a Colorado

aucion o waer righs, oil and gas companies were

he op bidders, driving up waer prices or he sae’sarmers, many o which were enduring severe drough

condiions.68 In New Mexico, some armers affeced by

severe drough condiions are, in lieu o arming, selling

heir righs o irrigaion waer o oil and gas companies.69

This compeiion wih, or ourigh displacemen o,

agriculural waer use will only increase i unconven-

ional oil and gas developmen coninues o expand in

counies ha already ace waer sress, and ha are

likely o experience even larger waer supply problems

as a consequence o climae change.

Impacts on surface waters,

forests and soilsThe consrucion o new well sies and supporing

inrasrucure are jus he irs sage in he indusry’s

harm o surace waers, oress and soils. Each Marcellus

Shale gas well pad sis on abou hree acres o cleared

land, and or each sie anoher six acres is cleared o

build supporing access roads, pipelines and oher

ossil uel inrasrucure.

70

The indusry’s consrucionprojecs increase he amoun o sedimen ha lows

ino rivers and sreams, causing ecological harm ha is

compounded by excessive waer wihdrawals.71

Foress and agriculural lands provide waershed-scale

ilraion as rainwaer and snowmel low ino rivers

and recharge aquiers.72 Widespread shale developmen

in he Marcellus region is expeced o cover hundreds

o housands o acres wih suraces ha are impervious

o rains, signiicanly disruping his ilraion.73 New

indusry sies, pipelines and roads also expose more

ores o more clearing, changing he balance o wild-

lie, harming ores healh and hus urher affecing

waersheds and groundwaer recharge.74 Air polluans,

including ozone, can also harm oress and agriculural

lands ha are downwind o oil and gas operaions.75

Waer qualiy in rivers, sreams and shallow aquiers,

and soil qualiy on agriculural lands, are urher hrea-

ened by spills o racking chemicals and o oxic oil and

gas indusry wases, as well as by inenional spreading

o he wases, or example, o de-ice roads given he

sals in he wases.76 A recen sudy near acive drilling

Water tanks lined up in preparation for fracking.


11/36


and racking operaions in Colorado ound elevaed

levels o known and suspeced endocrine disrupors in

surace waers and shallow groundwaers, consisen

wih wha would be expeced rom spills o he chemi-

cals used by he indusry in racking luids.77

The oil and gas indusry’s wases — primarily he

lefovers o wha’s brough o he surace — conain

corrosive sals, radioacive maerial, oxic meals, hydro-carbons, and racking chemicals, as oulined in Box 2

(page 4). Each year housands o leaks, blowous and

spills rom he oil and gas indusry involve hese wases,

as well as various racking chemicals ye o be injeced,

and/or produced oil and naural gas liquids. (See Box 3.)

In a shining example o he oil and gas indusry’s

capure o regulaory policy, he indusry’s hazardous

wases rom drilling and racking are exemped rom

ederal regulaions on hazardous wase, simply by virue

o having been generaed by he oil and gas indusry.78

Iwases wih similar characerisics were o be generaed

by anoher indusry, hey would be deemed hazardous.79

The liquid wases ha do no ge spilled are ypically

sen o indusrial reamen aciliies, processed or

reuse or injeced back underground ino disposal wells.87

In Pennsylvania, abou hal o he lowback wase is

sen o indusrial reamen aciliies, abou one hird

is reused and increasing amouns are injeced back

underground ino disposal wells, commonly afer being

sen o Ohio or Wes Virginia.88

In Texas, Oklahomaand Norh Dakoa, he dominan pracice is o dispose

o liquid wases by injecing hem back underground.89

In Caliornia, regulaors have recenly haled he wase

injecions a numerous wells ou o concern ha he

wases are being injeced direcly ino aquiers.90

Treamen a indusrial wase aciliies is imperec,

allowing conaminans o low hrough ino rivers and

sreams. In 2013, scieniss repored ess on sedimen

rom he bed o Blacklick Creek, in Pennsylvania, a he

poin where effluen lowed ino he creek rom an indus-rial reamen plan wih a hisory o acceping oil and

gas indusry wases.91 The sedimen conained grealy

enhanced levels o radioacive maerial, wih radiaion

a 200 imes he level ound in background sedimens.92

No only does his pu a risk hose who ea ish ha rely

on he ood chain rom his sream, bu i illusraes ha

reamen is no necessarily effecive. Baseline levels o

polluion, wih some larger polluion evens, are inheren

o drilling and racking or oil and gas.

To he exen ha reamen is effecive, i concenraes

he conaminans and hus generaes solid wase. Toxic

hydrocarbons, heavy meals and radioacive maerial

also become concenraed in sludge a he botoms

o wase pis and in sludge and scale deposis wihin

equipmen, such as wihin pipes and anks.93 Radia-

ion rom hese concenraed wases, or rom he rock

cutings brough o he surace during drilling, is setingoff deecors a he gaes o landills.94 Massive quani-

ies o low-level radioacive wases pass hrough hese

deecors, wheher operaional or no, and ge dumped

in landills,95 i hey are no irs spilled beside a road on

he way o a landill.96 The indusry’s radioacive solid

wases are also being illegally dumped.97

Under a previous governor, Norh Carolina’s Depar-

men o Environmen and Naural Resources warned

ha layers o cutings could resul in plugging o he

landill and o evenual spills o luid, known as landill

Accidents and spillsare business as usual

In 2008, ProPublica examined local and state govern-

than 1,000 cases of leaks and spills at oil and gas

industry sites.

80

According to the Denver Post , theoil and gas industry has reported about 2,500 spills

6 percent having contaminated surface water and

17 percent having contaminated groundwater.81 In

North Dakota in 2011, the oil and gas industry also

reported over 1,000 spills.82 An analysis by Energy &

Environment looked at available data and counted

over 6,000 “spills and other mishaps” in 2012 alone

from oil and gas industry operations throughout

the United States, and found that the incidents

83 A subsequent analysis found

“at least 7,662 spills, blowouts, leaks and othermishaps in 2013 in 15 top states for onshore oil and

gas activity.”84 In Pennsylvania, the Department of

Environmental Protection has recorded 209 incidents

in which the oil and gas industry either contaminated

85

All of these estimates are conservative, given that

that actually get reported. Indeed, some mishaps are

-

neering, completed in May 2014 at Louisiana State

University, explains that underground blowouts may just appear to occur less frequently than those that

underground.86


12/36


leachae, ha is enriched wih diverse conaminans,

including he radioacive maerial.98 Given ha he hal-

lie o radium-226 is 1,600 years, such spills would ain

he surrounding soil and waershed or cenuries.

99

Surace-waer conaminaion also resuls when

convenional wasewaer reamen aciliies ha are

no equipped o rea racking wasewaer noneheless

receive i. The conaminans can pass righ hrough

hese aciliies and be discharged ino rivers, causing

problems or waer sysems downsream, as well as

or aquaic lie.100 When downsream waer uiliies

disinec river waer wih elevaed levels o chloride or

bromide — wo sals ha characerize racking wase-

waers101 — he resuling chemical reacions can orm

harmul byproducs ha are linked o cancer and birh

deecs and ye are difficul o remove once presen in

drinking waer supplies.102

Raher han simply no allow surace disposal, he EPA

is drafing rules ha would require “pre-reamen” o

shale gas wasewaers beore hese wases could be sen

o convenional reamen aciliies ha serve public

waer sysems.103 And since racking is also occurring in

non-shale ormaions, guidelines or only shale orma-

ions are inadequae. However, as is he case wih

rounds o wasewaer recycling and indusrial reamen,

his sole pre-reamen concenraes he oxins, creaing

new disposal problems.

Aquifer contaminationIn addiion o conaminaing armland and waersheds,104

plumes rom leaks and spills o liquids a he surace can

seep down ino soil and can conaminae shallow aquiers,

as a signiican racion o spills have done in Colorado.105

Bu aquiers also ace unseen hreas rom below, boh

immediae and over he long erm.

Disproporionaely high levels o arsenic, as well as

sronium, selenium and barium, have been ideniied in

groundwaer in areas o he Barnet Shale region in Texas

ha have seen more oil and gas aciviy.106 The presence

o hese conaminans was believed o be due o heir

increased mobiliy, as a consequence o eiher nearby

waer wihdrawals or mechanical disurbances, such as

vibraions inroduced during drilling and racking.107

In a handul o incidens, oil and gas companies have

injeced racking luids or oil and gas indusry wases

very close o, i no direcly ino, underground sources o

drinking waer.108 Beyond hese cases o direc conami-

naion, a nework o differen pahways can allow

conaminans o indirecly seep ino and conaminae

groundwaer rom below, in he afermah o drilling and

racking.109 The pahways include new racures creaed

by hydraulic racuring, exising naural racures and

auls, and openings along wells wih compromised

consrucion, or inegriy.110

Methane and other hydrocarbon gases

A sudy published in 2000 esimaed ha ens o

housands o oil and gas wells in Norh America were

leaking gas, including ino he amosphere and ino

shallow aquiers.111

In 2011, scieniss observed ha mehane concenra-

ions in samples rom waer wells locaed in regions o

acive Marcellus and Uica shale gas developmen were

17 imes higher, on average, compared o samples romwaer wells in regions wihou drilling and racking

aciviy.112 The auhors concluded ha “leaky well

casings” were he mos likely cause.113 In 2013, several

o he same scieniss sudied 141 wells in Pennsylvania

and ound higher mehane concenraions — by a acor

o six on average — in waer wells locaed less han

abou 3,200 ee (i.e., 1 kilomeer) rom a naural gas

well, compared o waer wells locaed arher away rom

any naural gas well.114

While mehane isel may no be oxic, is presence inaquiers indicaes he presence o oher hydrocarbons

ha are oxic. (See Box 2, page 4.) When a mix o

hydrocarbon gas eners unvenilaed spaces hrough

conaminaed waer wells, i can cause suffocaion and

even resul in explosions.115 Mehane ha conaminaes

aquiers may also, hrough geochemical reacions or

oher mechanisms, increase levels o arsenic and oher

harmul oxins in waer brough o he surace.116

Ulimaely, he mehane and oher hydrocarbons may

or may no originae rom he rock ormaion beingargeed, bu he resul is he same: he mehane and


13/36


oher hydrocarbons are presen a increased levels as

a consequence o drilling and racking. There are many

well-sudied reasons why, and he scale o he problem

derives rom he scale o widespread drilling.

Abou 2.6 million onshore oil and gas wells have been

drilled in he Unied Saes since 1949,117 and abou 1.1

million o hese are acively producing.118 More han

20 years ago, he EPA esimaed ha abou 200,000 ohe over 1 million abandoned oil and gas wells in he

counry were inadequaely plugged, meaning ha hey

provide pahways or hydrocarbon gases, i no oher

luids, o low up o he surace or o underground

sources o drinking waer.119

Addiionally, over 30,000 wells have been drilled or he

purpose o disposing o oil and gas indusry wases, via

injecion.120 A gray area lies in how he indusry akes

brines brough o he surace and hen pumps hem

back underground ino wells o improve he low o oilou o adjacen wells; here are more han 110,000 o

hese injecion wells or “enhanced oil recovery.”121

Consruced o concree and seel, all o he above

wells age and degrade over ime.122 Moreover, rom

he beginning o heir consrucion, a signiican rac-

ion o oil and gas wells — several percen — have

well inegriy problems, meaning ha injeced luids,

hydrocarbons and ancien brines may no be conained

wihin he inner ubing, or casing, o he well.123 Once

ouside o his casing, hese conaminans give rise opolluion when hey escape o he surace or move ino

underground sources o drinking waer ha were drilled

hrough in order o consruc a well.124

Due o a variey o reasons, including cemen shrinkage

and/or poor bonding, space can orm beween he ouer

shell o cemen and he various rock ormaions hrough

which an oil and gas well passes, creaing a pahway or

he poenial low o conaminans.125

A PhD hesis in peroleum engineering, compleed in

May 2014, explains ha highly pressurized luids duringhydraulic racuring can direcly cause such separaion,

resuling in “underground blowous” — evens in which

racking luids ravel back along he pah o he well

beween he concree and he rock ormaion, raher han

ino he argeed ormaion.126 Compared o blowous ha

spew luids ino he air a well sies, hese blowous are

more difficul o deec, or obvious reasons.127

Fluids may also leak rom oil and gas wells hrough small

racures or channels ha orm wihin he inerior o

he consruced well, eiher wihin he cemen isel or

beween concenric cylinders o cemen and meal pipe,

or casing, used o build he well.128 Improper cenering o

casings gives rise o less uniorm lows o cemen during

he consrucion o he well, and his in urn is anoher

acor ha increases he risk o well inegriy ailures.129

Gradual setling over ime due o he exracion o oil

and gas also applies sress ha may evenually break, or

crack, consruced wells, leading o ailure.130

As he many differen mechanisms o well ailure sugges,

he problem o leaky wells, and ourigh well ailure, is

he opic o a large number o sudies by indusry and

academic scieniss. The botom line, however, is ha

many oil and gas wells leak, and ha he causes o leaks

are difficul o deec and ix, given ha hey occur or

so many differen reasons, subjec o diverse geological

condiions and o diverse indusry pracices.

A major concern is ha, as a given year’s newly drilled

and racked wells decline in producion and degradephysically, he percenage ha develop inegriy prob-

lems is likely o increase over ime.131 Ye daa on he inci-

dence o well inegriy problems as wells age are severely

limied, no leas because shale gas and igh oil wells are

relaively new. A 2003 sudy looked a ederal daa on he

over 10,000 wells drilled ino he ouer coninenal shel

o he Gul o Mexico a he ime, and ound ha more

han 40 percen o hose ha were over 10 years old

displayed “susained casing pressure,” meaning ha he

wells were no conaining hydrocarbon gas wihin he

inner ubing, or casing, used o channel hydrocarbons upor producion.132

A well head after fracking equipment has beenremoved from the drilling site.


14/36


Now, according o a 2014 sudy, iniial daa on shale

gas well inegriy in Pennsylvania do no bode well or

he uure.133 In he Marcellus Shale region o Pennsyl-

vania, shale gas wells have proven o be more prone

o well consrucion “impairmens” linked o well

inegriy problems, compared o convenional wells,

especially in he norheasern par o he sae, where

over 9 percen o shale gas wells have indicaions o

compromised well inegriy.134

Conaminaion o aquiers rom mehane and oher hydro-

carbon gases alone warrans precauion over widespread

drilling and racking. However, anoher major concern is

ha “evidence o sray gas conaminaion could be indica-

ive o uure waer qualiy degradaion, similar o ha

observed in some convenional oil and gas ields.”135 One

reason is ha such conaminaion could be a harbinger o

conaminaion rom he migraion o oher luids, no jus

he relaively buoyan hydrocarbon gases.136

Hydrocarbon gases in aquifers

as a sign of more problems to come

I oil and gas companies drill and rack he hundreds

o housands o new shale gas and igh oil wells envi-

sioned, he legacy o aging, degrading and increasingly

compromised wells will grow subsanially. This legacy

may lead o long-erm, region-wide changes in how

luids mix and move underground over he coming

years and decades. How hese changes migh impac

he qualiy o underground sources o drinking waer

remains unknown, highlighing he enormous risks

inheren o widespread drilling and racking.

Aquiers are immediaely pu a risk when he leading

edge o injeced racking luid propagaes new rac-

ures arher han anicipaed, reaching nearby oil andgas wells, or injecion wells ha have compromised

cemening and casing.137 These “rack his,” or so-called

well-o-well communicaion evens, someimes give rise

o surace spills,138 and hey are occurring or a leas

wo reasons. Firs, predicing he acual lengh o rac-

ures is a nooriously difficul mahemaical problem,

sensiive o parameers ha are speciic o he geology

surrounding each individual well, and his sensiiviy

leads o some racures propagaing arher han

expeced.139 Second, he locaions and dephs o many

housands o he more han 1 million abandoned oil andgas wells in he Unied Saes are no known.140

The issue o rack his is oreshadowed in regulaions

se orh by he EPA under he Sae Drinking Waer Ac,

and exposes a complicaed sory abou he oil and gas

indusry’s capure o U.S. regulaory policy. (See Box 4,

page 11.)

In addiion o he immediae risks o conaminaion

rom rack his, he incidens clearly illusrae how wide-

spread drilling and racking can change he conneciviyo a nework o conaminaion pahways on a regional

scale. Several recen sudies have begun o approach he

larger concerns abou long-erm impacs on a regional

scale, highlighing he severely limied scieniic under-

sanding o he issue, and underscoring he simple-

mindedness o he curren regulaory approach o oil

and gas indusry injecions. (See Box 4.)

A 2012 sudy used a simpliied mahemaical model o

explore how preerenial pahways or luid low, such as

auls and naural racures, can inluence he ime scale

in which injeced conaminans migh reach under-

ground sources o drinking waer under a wors-case

scenario.163 The model suggesed ha slow conamina-

ion could occur wihin a decade.164 A second 2012 sudy

ound evidence o a mach beween he geochemical

proile o saliniy in shallow groundwaer in norheas

Pennsylvania and ha o Marcellus brine, suggesing

a “preexising nework” o pahways (i.e., unrelaed

o racking) beween he Marcellus Shale and shallow

groundwaer.165 In 2014, anoher sudy demonsraed a

way o reduce he complexiy o modeling he slow lowo conaminans hrough naural auls,166 wih an aim


15/36


Oil and gas industry injectionsUnder authority from the Safe Drinking Water Act, the U.S. EPA’s

141 In 1989, the U.S.

sources of drinking water via nearby abandoned wells that had

integrity problems.142 These were frack hits, without the fractures.

143

operations, in 1949.144

that would require addressing the issue of frack hits, were it not for

this loophole.145 The loophole thus explains how the issue of frack

hits has remained beyond regulation, and highlights how the oil and

gas industry, through its capture of U.S. energy policy, has erected

barriers to protecting public health and the environment.

-

tory safeguards are triggered.146

simplest option being to just use a circle with a 400 metre radius.147 Alternatively, applicants for permits can use a

an AoR.148

149

In 2004, a panel of exper ts convened by the EPA noted that these options were “adopted even though much existing

source of drinking water] and actual injection rate).”150

AoR is based on operational assumptions made in the early 1980s,”151 and concluded that “enough evidence exists

sources of drinking water]... .”152

The EPA, despite these strong statements, has kept the simplistic protections in place, having deferred action

experts that data show that the 400 meter approach is inadequate.153

of interest.

Most of these state agencies, as regulators of oil and gas development in their respective states, are party to the

154 so as to prevent “physical waste of oil or gas or loss in

the ultimate recovery thereof.”155

FracFocus.org, which has created a platform for the oil and gas industry that gives the illusion of transparency.156

This episode illustrates how longstanding alignments between the oil and gas industry and state governments

(continued on page 12)

Fluid awaits injection at a fracking site.


16/36


oward modeling ha approaches a regional scale.167

This effor o incorporae numerous wells and auls

a a regional scale is preliminary, based on simpliying

assumpions abou he geomery and parameers ha

conrol low hrough hese conaminaion pahways.168

The EPA, as par o is muli-year sudy o he

poenial impacs o hydraulic racuring on drinking

waer resources, has conraced researchers o modela handul o simplisic conaminaion scenarios.169

However, he preliminary models are ar rom being

employed o predic and poenially reduce he likeli-

hood o uure conaminaion evens semming rom a

single racked well, much less o address he prospec

o conaminaion on a regional scale ha communiies

wih widespread drilling and racking may ace.170

A he same ime, he oil and gas indusry’s capure o

U.S. energy policy is also on display in he resuls o

he conraced research. The scieniss modeling heconaminaion scenarios or he EPA view using heir

novel compuaional mehods o invesigae he likeli-

hood o conaminaion as somewha o a side noe,

and pu equal i no greaer emphasis on he poenial

uure use o heir mehods o increase he producion o

hydrocarbons rom hydraulically racured wells.171

The EPA’s recen guidance on he use o diesel uels

in racking luids merely noes ha modeling o acu-

ally calculae he poenial exen o he migraion o

injeced luids “ofen requires a signiican body odaa.”172 This saemen is a reerence o he ac ha

acually deermining when and where conaminaion

evens are likely o occur requires deailed inormaion

ha is speciic o he geology surrounding individual

wells across a region, including he presence o nearby

naural auls and racures, induced racures rom

racking, and compromised wells. Ye his inormaion

is no always available.

Acually deermining when and where conaminaion

evens are likely o occur would also require knowledgeo he parameers ha conrol low hrough hese poen-

ially conneced pahways, over long periods o ime.

These parameers are highly uncerain, and vary by

locaion. Ye he oupus o he models are likely sensi-

ive o he parameers used, and o he assumpions ha

hese parameers embody. For example, assuming ha

here is no naural aul providing a poenial pahway

or conaminaion, when in ac here is one, unda-

menally changes he model. The resul is ha crucial

inormaion o ensure proecion is no available.

compromise between the industry and regula-

approach) or, alternatively, on an overly simplistic

calculation using a decades-old mathematical

formula that is divorced from modern geological

understanding and modern computational science.

With wells now tunneling horizontally more than

three kilometers through rock formations and

being hydraulically fractured in tens of stages, and

— with or without diesel — injected at each stage,

much has changed since the “operational assump-

tions made in the 1980s” that led to the AoR criteria.

Yet fracking injections that do not contain diesel

protections of the standard AoR approach, thanks

fracking injections that do involve diesel fuels have

disclosure of whether or not companies are using

-

atic. The Environmental Integrity Project revealed

that many companies had edited their previous

submissions to FracFocus.org, thereby rewriting

history and concealing their use of diesel fuels in

157

158

While the guidance acknowledges that the simplistic

assumptions for the formula approach do not apply,it merely recommends that regulators use one of

approach.159 The guidance is most remarkable in

that it still does not draw on decades of progress

in the mathematical and computational sciences,

emphasizing only that such modeling “often

160 Moreover,

the guidance does not mention the modeling

ongoing study of contamination pathways related to

hydraulic fracturing.

In June 2014, in unspoken disapproval of the EPA’s

guidance on diesel fuels, a GAO report pointed to

“new” risks to underground sources of drinking

water presented by hydraulic fracturing with diesel

a panel of experts to review the risks.161 The

report also notes that the surge in the volume and

-

tions are “overpressurizing” rock formations, leading

to surface spills162 — events that are akin to the

surface spills from frack hits.

(“Oil and gas industry injections”

continued from page 11)


17/36


As one ederal scienis old journaliss a ProPublica ,

“[]here is no cerainy a all in any o his … You have

changed he sysem wih pressure and emperaure and

racuring, so you don’ know how i will behave.”173 The

uncerainy over how he hydrogeological sysem will

respond raises he specer o long-erm aquier conami-

naion as a icking ime bomb, wih grave implicaions

or waer availabiliy, and or local economies, across he

counry. This risk is simply unaccepable.

Earthquakes, Lightning Strikesand Exploding TrainsScieniss now believe ha, by pumping large amouns

o luids underground, he oil and gas indusry

is largely o blame or he signiicanly increased

requency o earhquakes observed in he Unied

Saes in recen years.174 For decades, he cenral and

easern Unied Saes consisenly regisered abou 20

magniude 3.0 or greaer earhquakes per year. 175 In hemid-2000s, his rend broke, and earhquake requency

increased, direcly coinciding wih he expansion

o modern drilling and racking.176 In 2010, 2011 and

2012 combined, here were abou 300 earhquakes o

magniude 3.0 or greaer.177 In jus he irs hal o 2014,

Oklahoma alone regisered abou 200 magniude 3.0 or

greaer earhquakes.178

In a handul o cases, he evidence suggess ha he

speciic process o hydraulic racuring has also induced

earhquakes, mos recenly in Ohio.179 Mos o he oiland gas indusry earhquakes, however, are evidenly

occurring when high-volume wases ha are injeced

ino UIC Class II wells lubricae auls, or increase pres-

sure beyond he srengh o inersecing auls.180 A 2014

sudy has repored evidence ha injecion o oil and

gas indusry wases is riggering earhquakes cenered

up o over 20 miles away rom he injecion well, in par

because o “modern, very high-rae injecion wells.”181

A magniude 4.7 earhquake was among he swarm o

1,000 smaller earhquakes all measured in Greenbrier,Arkansas, in 2010 and 2011, again atribued o injecions

o wases.182 Among he oil and gas indusry earh-

quakes ha have shaken Oklahoma, none was larger

han he magniude 5.7 earhquake in 2011 ha sruck

Prague, Oklahoma, resuling in injuries o wo people

and he desrucion o 14 homes.183 Now, a 2013 sudy

has suggesed ha large remoe earhquakes — ar rom

he Unied Saes — may acually be riggering earh-

quakes wihin he Unied Saes, including he magni-

ude 5.7 earhquake ha hi Prague, Oklahoma.184 Tha

is, oil and gas indusry injecions appear o be bringing

auls o near-criical hresholds, and hen seismic waves

rom large bu remoe earhquakes can hen rigger he

movemen o hese auls.185

Ideniying when and where criical hresholds are

nearly reached requires monioring ha can only be

done remoely, and hus imprecisely, given ha auls

are buried deep underground. This phenomenon o

criical hresholds being remoely riggered emphasizes

he large uncerainies ha cloud he quesion o when

and where he nex oil and gas indusry earhquake will

srike. Jus how srong and poenially desrucive and

cosly he indusry’s earhquakes migh become also

remains an open quesion.

In some cases, he luids injeced by he oil and gas

indusry have evidenly enered and acivaed previously

unknown auls.186 The ac ha here are unknown

auls urher highlighs undamenal limiaions o

undersanding, and predicing, when and where he

nex oil and gas indusry earhquake will occur. This ac

likewise highlighs ha assumpions abou he nework

o waer conaminaion pahways wihin a neighborhood

o a given injecion well can change.

More generally, he seismic waves ha make up earh-

quakes — wheher unleashed naurally or induced by

he oil and gas indusry’s injecions — may exacerbae

he problem o leaky oil and gas indusry wells. The

seismic waves pass hrough a differen dephs a

differen speeds, owing o differences in he densiy (and

Residential damage from the magnitude 5.7 earthquake in 2011

that struck Prague, Oklahoma.


18/36


elasiciy) o he underlying layers o rock ormaions

peneraed by an oil and gas well. As a consequence,

seismic waves do no uniormly shake he consruced

wells, resuling in physical sresses ha can only

increase he likelihood o cemening or casing ailures.

Oil and gas indusry earhquakes have aken many

by surprise, bu scieniss have long known ha injec-

ions (and wihdrawals) o luids beneah he suracecan induce earhquakes.187 Few, i anyone, however,

anicipaed he recen incidens in Norh Dakoa in

which anks holding oil and gas indusry wases have

been sruck by lighning, resuling in explosions ha

spilled conaminans ono surrounding lands and burned

or days.188 The sorage anks are evidenly exploding

because, in an effor o avoid corrosion, he meal anks

are lined wih iberglass, which has much lower conduc-

iviy han meal and hus overheas.189

Trains carrying igh oil rom drilling and racking in heBakken region o Norh Dakoa are also exploding.190

The surge in igh oil producion in Norh Dakoa and

Texas has led o a rapid expansion in he ranspor o

oil by rain o reineries, in par because producion

has oupaced pipeline consrucion.191 Energy Secreary

Ernes Moniz has noed ha he oil indusry has acu-

ally begun o preer ransporing oil by rain, or he

lexibiliy i offers.192 However, several oil rain explo-

sions — mos caasrophically in Lac-Méganic, Qebec,

which desroyed several blocks o he own and killed 47

people — have brough he so-called bomb rains o heoreron o public atenion.193

The our high-proile explosions hus ar — in Qebec,

Virginia, Alabama and Norh Dakoa — relec ha

he oil conains relaively large amouns o naural gas

liquids, which are highly explosive.194 The explosions also

relec ha large quaniies — ofen more han 10 million

liers per rain — are now being sen very long disances

by rail o reineries, ypically abou 1600 kilomeers.195

The oil rain explosions have brough he issue o

racking o regions ha are no acively argeed or

racking, including Minnesoa, Washingon, D.C.,

Alabama and he Paciic Norhwes.196 For example,

abou 250 oil rain cars pass hough downown Seatle

each day, and recenly several o hese cars deraileda low speed, wihou inciden, serving as a poenial

wake-up call or he ciy.197 An analysis o planned

projecs or expanding reinery capaciy in he region —

ironically including he conversion o aciliies inended

or renewable liquid uels — would add as many as 12

one and a hal-kilomeer-long oil rains each day o he

Norhwes railway sysem.198

Taken ogeher, he earhquakes, lighning srikes and

exploding rains are a reminder ha widespread drilling

and racking now means many differen hings o hecommuniies ha are affeced in differen ways. Bu

nohing affecs residens o hese communiies living

alongside oil and gas indusry sies more viscerally han

he oil and gas indusry’s air polluion, which lows

along wih he indusry’s climae polluion.

Air and Climate ImpactsIn essence, drilling and racking gives rise o hree

differen sreams o polluans lowing ino he air: he

clouds o silica dus rom mining or and managing he

sand used in racking luids; he plumes o combusionbyproducs rom engines, lares and explosions; and he

sream o polluans ha he oil and gas indusry boh

brings o he surace and leaks ino he air.

Compromises wih he indusry call or more monioring

o beter undersand precisely wha he risks o oxic

exposures are or everyone living alongside drilling and

racking operaions, bu calls or prolonged monioring

and more sudies jus guaranee urher polluion, and

urher harm. Even assuming ha srong regulaion

and oversigh can be pu in place, and ha negligence,accidens and explosions can be eliminaed, he baseline

level o he indusry’s air and climae polluion will

guaranee cerain harm o public healh and will lock

in unaccepable climae risks. The indusry’s air and

climae polluion is bes avoided alogeher wih a ban

on racking.

Silica dust Clouds o silica dus orm a well sies as sand is managed

and prepared or mixing ino racking luid.199 Silica dus

clouds also emanae rom silica mining and processing Aftermath of the Lac-Mégantic, Quebec, oil trainderailment in July 2013.


19/36


sies. As wih he issue o exploding oil rains, silica sand

mining has broadened he reach o racking’s impacs

beyond regions argeed or shale gas and igh oil exrac-

ion, wih large amouns o silica mined rom or processed

in Wisconsin, Minnesoa, Illinois and Iowa.200

A recen review o he public healh impacs o drilling

and racking summarizes ha “[r]espirable silica can

cause silicosis and lung cancer and has been associ-

aed wih uberculosis, chronic obsrucive pulmonary

disease, kidney disease, and auoimmune disease.”201

The Naional Insiue o Occupaional Saey and

Healh measured silica levels a 11 well sies, as silica

sand was being managed, and ound ha exposures

exceeded hresholds se o proec worker healh, in

some cases by a acor o 10.202

Residens living nearby operaions may also ace serious

healh risks. “The breahing par o i isn’ good. You can

jus eel i in your hroa, eel i in your nose,” explained

an individual living across he sree rom a Wisconsin

sand-washing plan.203 Bu he speciic consequences

or hose living nearby sand mines and drilling sies

remain unknown, and largely unsudied.204 A school in

New Auburn, Wisconsin, siuaed near our silica sand

mines, has ound silica on air ilers used in he school’s

air sysem, suggesing ha low-level exposure in hecommuniy may be he norm.205

Byproducts from combustionExhaus rom he diesel generaors and large rucks ha

crowd well sies, and smoke rom laring a well sies,

processing plans, and compressor saions, no o menion

explosions, creae a second sream o oxic air emissions.

Along wih carbon dioxide rom combusion, hese

plumes conain variable amouns o hazardous

air polluans, including nirogen dioxides, carbonmonoxide, pariculae mater, and volaile organic

compounds (VOCs), such as he hydrocarbons benzene,

oluene, ehylbenzene and xylenes (BTEX) and various

polycyclic aromaic hydrocarbons (PAHs).206

Hundreds o heavy-duy ruck rips per well are

required, largely o ranspor waer, chemicals, and

equipmen, as well as he wases ha resul rom drilling

and racking.207 Geting he indusry o conver o lees

o rucks and generaors ha burn naural gas wouldlessen he air qualiy problems rom diesel exhaus, and

he respiraory and cardiovascular healh problems asso-

ciaed wih such exhaus,208 bu no wihou he ill effec

o locking in demand or more drilling and racking.

Smoke rom lares a well sies and processing plans adds

o he baseline levels o engine exhaus in much less-

deined ways, dependen on he efficiency o combusion

and he makeup o he wase gases being burned. O

course individual explosions are unoreseen, bu hey have

become an expeced consequence o business as usual,and hey can lead o oxic smoke billowing or days.209

The pollutants that oil and gascompanies bring to the surfaceThe hird sream o oil and gas indusry polluion orms

ou o he plumes o well- or sie-speciic mixes o

hydrocarbons and oher air and/or climae polluans,

as discussed in Box 2 (page 4). These are he polluans

ha come rom below ground, and ha are mobilized

ino he air in he afermah o drilling and racking.

Now, based on a handul o sudies in 2013 and 2014,

i has become clear ha he oil and gas indusry emis

more air and climae polluans han officials esimae.

The air and climae polluans ha oil and gas compa-

nies bring o he surace include: mehane and oher

VOCs, such as he BTEX hydrocarbons and oher

“aromaic” hydrocarbons, including PAHs; hydrogen

sulide; radon derived rom radium presen in argeed

rock ormaions; and any chemicals rom racking

suspended in he air as vapor or aerosol, such as gluar-

aldehyde, ehylene glycol and mehanol.210

Varying amouns o hese polluans low rom a vas

array o sources a successive sages wihin he indusry,

including: during drilling, cemening and casing;

immediaely afer racking luid injecion; rom sored

wases; rom any accidens, spills and explosions; and

rom inefficien lares and leaky valves, langes, seals,

pneumaic devices, pipes and oher equipmen used o

manage, process, compress and ranspor he payoff

hydrocarbons — he crude oil, naural gas liquids and

naural gas.211


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Again, mehane is a poen greenhouse gas and a

primary driver o global warming.212 The BTEX air oxics

irriae skin and can cause respiraory and nervous

sysem problems wih shor-erm exposure, and can

cause greaer harm wih long-erm exposure, including

cancer.213 In he presence o sunligh, BTEX and oher

VOCs also combine wih combusion byproducs o

orm ozone, a respiraory irrian ha can prove aal or

hose wih ashma.214 PAHs ha all on land and surace

waers can accumulae in he ood chain, poenially

resuling in harmul levels o exposure or humans

who consume conaminaed ish.215 Hydrogen sulide

is highly poisonous, and oil and gas indusry workers

a well sies may be advised o wear personal moniors

equipped wih alarms.216

The chemicals in racking luid, as well as largely

unknown byproducs o chemical reacions during

racking, are mobilized along wih hydrocarbon gases

and oher polluans, and emited ino he air o varying

degrees.217 This pus he issue o racking chemical

disclosure ino proper perspecive as a signiican bu

noneheless singular componen o he indusry’s pollu-

ion. Full chemical disclosure would no pu an end o

he indusry’s waer and air polluion.

The issue o racking chemical secrecy noneheless reso-

naes wih he public, in par because i is an example o

he deerence ha policymakers regularly gran o oil and

gas companies, and because i illusraes how such deer-

ence holds back scieniic invesigaions o he indusry’simpacs on public healh and he environmen. Indeed,

some in he oil and gas indusry have worked wih he

American Legislaive Exchange Commission (ALEC), and

ALEC has in urn helped o see ha sae legislaures

only consider disclosure requiremens ha are accepable

o he indusry.218 Even when disclosure is required in

he even o emergencies, as is he case in some saes, a

company can be slow o comply.219

While regulaions vary by sae, rade-secre proecions

graned in he Toxic Subsances Conrol Ac mean haracking companies ypically do no have o disclose

all he chemicals hey pump underground.220 In ac, in

many cases, oil and gas companies old off-he-shel

producs ino he racking luids ha hey make on-sie,

wihou acually knowing he chemicals conained in

hese producs.221

I is known ha oil and gas companies have injeced a

wide variey o oxic chemicals o racure wells, and

have injeced many more chemicals or which oxici-

ies are no well sudied.222 For example, among hechemicals ideniied, over 100 are known or suspeced

endocrine disrupors.223 Numerous known or suspeced

carcinogens also have been used since 2005 as addiives

in hydraulic racuring luids.224 Many o he known

chemicals used are volaile, meaning ha hey escape

readily ino he air.225 Very litle is known abou healh

risks posed by mixures o all he chemicals brough o

he surace, and he exen o chemical reacions ha

orm dangerous byproducs.226

Beyond inadequae requiremens or disclosure o

racking chemicals, here are many oher undamenal

challenges o quaniying he oil and gas indusry’s

releases or each o he above polluans.

The challenges begin wih he number and diversiy o

sources, and how he consellaion o sources changes

over ime as he oil and gas indusry operaes, arges

new areas and adops new pracices.227 Geological

differences rom well o well, and differen sages wihinhe oil and gas sysem — rom producion o disribuion

— give rise o differences in he chemical composiions

o wha ges released ino he air.228 The low rae and

chemical composiion o he plumes rom a single source

can also change over ime, under normal operaions,229

and can increase quickly, and unexpecedly, as a conse-

quence o equipmen ailures.

These acors make he size and chemical composiions

o he plumes in he hird sream o emissions variable,

or well- and sie-speciic. Imporanly, undersandingo he indusry’s emissions is blocked by lack o access

o sies and o daa held by oil and gas companies,

presuming ha hey have daa. As noed already, hese

companies are empowered by rade-secre proecions

and by key exempions graned o he oil and gas

indusry under he landmark environmenal laws. A

PhD hesis compleed in 2014 reveals anoher obsacle

o ull inormaion: sources no couned a all, such as

abandoned oil and gas wells leaking mehane and oher

hydrocarbon gases.230


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Agains hese challenges, he EPA esimaes emissions

using a botom-up approach, beginning wih an inven-

ory o all o he differen indusry aciviies underaken

in a given year.231 The EPA hen uses largely daed esi-

maes o average emissions o each aciviy o arrive a

an esimae o oal emissions rom he oil and naural

gas sysems.232 This approach relies heavily on volunary

sel-reporing rom he indusry.233

In 2013, he EPA Inspecor General ound many oil and

gas indusry emission acors o be o “low or unknown

qualiy” due o insufficien daa, leading o a resul ha

“likely underesimaes acual crieria polluan emissions

rom oil and gas producion sources.”234 For example,

here are no emission acors or air oxics and VOCs

emanaing rom wase pis, rom produced waer anks,

rom seps in he well compleion process including he

speciic process o racking, and rom pneumaic devices,

or pressure valves.235

Daa on he acual levels o various hydrocarbons in

he amosphere, aken rom aircraf lighs and/or rom

surace monioring locaions, make possible an alerna-

ive, op-down approach o esimaing indusry emis-

sions. Using amospheric chemisry, scieniss ake hese

daa and hen combine hem wih daa on wind paterns

o esimae, working backward, wha he dynamic

sreams o mehane and oher hydrocarbons were ha

lowed ogeher over an oil and gas play and gave rise o

he hydrocarbon levels ha were measured.236

Scieniss using his aircraf measuremen approach in

Uah, Colorado and Pennsylvania sugges ha much

more mehane and oher air polluans are lowing rom

oil and gas sies han botom-up esimaes based on

daed emission acors and indusry sel-reporing.237

Flying over an oil and gas ield in Uah one day in

February 2012, Karion e al. measured very large levels

o mehane — he equivalen o beween 6.2 percen

and 11.7 percen o naural gas producion ha monh,

assuming ha he day was represenaive o dailyemissions ha monh.238 In April 2014, Caulon e al.

published a sudy o mehane emissions during he

drilling sage a well sies in Pennsylvania and ound

several super-emiters, each releasing 100 o 1,000 imes

he EPA’s esimae o emissions during he drilling phase,

as uilized in is botom-up, invenory esimaes.239 In

May 2014, Péron e al. looked a mehane emissions in

he Denver-Julesberg basin in Colorado over a wo-day

srech in 2012 using monioring equipmen on owers

and on aircraf lown above he play, and concluded

rom he measuremens ha mehane emissions

were “close o 3 imes higher han an hourly emission

esimae based on EPA’s Greenhouse Gas Reporing

Program daa or 2012.”240

Because o variabiliy rom sie o sie, mehane emis-

sions can be used only as a crude indicaor o emissions

o oher polluans brough o he surace by he oil

and gas indusry. Noneheless, hese resuls are consis-

en wih he EPA Inspecor General’s conclusion ha

curren invenory esimaes undersae he oil and gas

indusry emissions o air oxics and oher VOCs, no jus

mehane.

Imporanly, Péron e al. esimaed ha benzene

emissions were abou seven imes larger han he

Colorado invenory esimaes would sugges.241 The

ac ha benzene emissions were evidenly no jus

approximaely hree imes larger, consisen wih he

inding on mehane emissions, bu closer o seven imes

larger, shows how simple, generic (i.e., linear) ormulas

or inerring non-mehane VOC levels rom mehane

levels can mislead. Simple inerence o non-mehane

VOCs rom mehane can hide poenially crucial — and

harmul — differences in he composiions o he raw

hydrocarbon gases rom well sies, as well as hide differ-

ences in he composiions o he differen sreams onaural gases managed a differen sages in he naural

gas sysem. In oher words, ar more harmul gases han

have been esimaed may be lowing rom some wells in

some regions, no jus rom he Denver-Julesberg basin.

This highlighs ha widespread drilling and racking is

a large, unconrolled experimen, and ha he conse-

quences or human healh remain largely unknown.242

Top-down sudies based on aircraf measuremens only

provide a look a emissions over a shor ime span, and

rom sources wihin relaively small areas o indusryaciviy. A paper published in December 2013 by Miller


22/36


e al. has suggesed ha, naionally, in 2010, leakage o

naural gas rom he oil and gas indusry in he Unied

Saes amouned o he equivalen o over 3 percen oend-use naural gas consumpion ha year; ha is, he

auhors suggesed ha acual emissions were more han

30 percen higher han he EPA’s esimae a he ime.243

In a review published in February 2014, Brand e al.

surveyed he scieniic lieraure on oil and gas indusry

mehane emissions and likewise concluded ha he

botom-up, invenory approach used by he EPA signii-

canly underesimaes naional mehane emissions.244

Natural gas dependence causes

more global warming than thought

Because undersanding o naional mehane emissions

is lacking, he climae impacs o widespread drilling and

racking are a mater o curren debae.245 Bu he over-

whelming ocus o his debae on he climae impacs o

using naural gas insead o coal o generae elecriciy

loses sigh o he oil and gas indusry’s role as a major

source o climae polluion.

Abou wo hirds o U.S. climae polluion sems rom

he oil and gas indusry, wih a litle under 30 percen

semming rom naural gas producion, processing,

ranspor and use.246 However, he esimaes o mehane

leakage used o arrive a hese igures are based on he

official underesimaes discussed above.247 The above

igures on climae polluion semming rom he oil and

gas indusry also hinge on comparisons o he relaive

conribuions o he differen greenhouse gases o global

warming.248 Now, according o he consensus science

ha is presened in he mos recen Inergovernmenal

Panel on Climae Change (IPCC) assessmen, i is clear

ha officials have also been grealy underesimaing hepoency o mehane as an agen o climae change.249

The IPCC now saes ha, pound or pound, a pulse

o mehane rom he oil and gas indusry raps 36

imes more hea han a pulse o carbon dioxide, over

a 100-year ime rame, and raps 87 imes more hea

over a 20-year ime rame.250 Remarkably, since he irs

IPCC assessmen repor, each subsequen repor — in

1996, 2001, 2007 and mos recenly 2013 — has increased

he esimae o mehane’s “global warming poenial,”

relaive o carbon dioxide.251 The mos recen increase

was he larges,252 raising he quesion o wheher more

increases are in sore as climae science progresses.

Nowihsanding he signiican climae polluion rom

he naural gas sysem, advocaes o naural gas have

oued he uel as a ool or addressing he challenge

o global warming.253 Debae over he climae impacs

o swiching o naural gas rom oher ossil uels has

become conroversial, in par because i is based on a

alse choice: burn naural gas or burn oher ossil uels.

Framing he climae impac o racking in his way losessigh o hree crucial poins.

Firs, mos recenly, racking is being done primarily

o exrac oil. Since he end o Augus 2012, abou 75

percen or more o drilling rigs have argeed primarily

oil, no naural gas, and abou wo hirds o all he

drilling rigs operaing in he Unied Saes are he sor

capable o drilling horizonally hrough shale and igh

rock ormaions.254 Fracking makes i possible o bring

o he surace and burn much more oil han previously

imagined, and here has never been any preenseha such oil consumpion is anyhing bu bad or he

climae.255 Second, increased naural gas use in he

elecriciy secor does no jus displace oher ossil uels,

i displaces cleaner soluions, such as solar, wind and

efficiency.256 Third, much o he coal displaced, insead o

saying underground, is jus being expored and burned

in oher counries, offseting, a an inernaional level,

he U.S. reducions in carbon dioxide emissions ha

come rom swiching o naural gas.257 The claim ha

hese oher counries would jus burn coal rom else-

where anyway258 relecs he excepionally low sandards

or U.S. leadership on he issue o global warming.

These hree caveas se aside, Food & Waer Europe

ook a close look a he condiions and assumpions

under which using naural gas insead o oher ossil

uels migh acually mean marginally less global

warming. Burning naural gas does produce abou hal

as much carbon dioxide as burning coal, wih less poen-

ial or carbon dioxide reducions when using naural

gas insead o heaing oil, gasoline or diesel.259 However,

hese poenial carbon dioxide reducions are offse by


23/36


he leakage o mehane rom he naural gas sysem,

and jus how much hey are offse remains an open and

conroversial quesion.260

There are a variey o ways o compare mehane emis-

sions o carbon dioxide emissions, in order o begin o

quaniy he climae impacs o burning naural gas

insead o coal, or heaing oils, or gasoline or diesel.261

Mehane does no persis in he amosphere or as longas carbon dioxide, so merics used o compare emissions

o he wo greenhouse gases depend on he ime rame

considered. 262 Focusing on he nex ew decades, a ime

rame in which mehane raps much more hea han

carbon dioxide does, pound or pound,263 is necessary or

hree undamenal and pressing reasons.264

The irs reason is ha we ace he risk ha climae

ipping poins will be surpassed in he near erm,

meaning ha naural posiive eedbacks could kick in

and lead o irreversible changes.265

For example, reducedArcic ice coverage means more absorbed sunligh

and warming.266 Furher, any warming ha haws ice

crysals ha had rapped mehane will give rise o

more mehane emissions, and hus more warming.267

Indeed, hawing o permaros in he Yamal Peninsula

in Russia, and he subsequen release o massive

amouns o mehane, likely explains he ormaion o

seemingly botomless craers in July 2014.268 Second,

even discouning he risk o climae ipping poins, he

changes o he climae ha are already expeced o

accompany 2 degrees Celsius o pos-indusrial warmingpromise o be dangerous and cosly.269 Third, curren

climae science warns ha o have a “good” chance —

ha is, signiicanly beter han a 50-50 chance — o

keeping warming rom going beyond 2 degrees Celsius

requires a very rapid ransiion off o all ossil uels,

leaving mos underground.270

Reurning o he quesion o mehane leakage, a 2012

sudy ound ha naural gas leakage ha amouns o

more han abou 3.8 percen o naural gas consump-

ion means ha swiching rom burning coal o burning

naural gas o generae elecriciy would be worse or

he climae or abou 20 years, a wash a 20 years, and

marginally less damaging hereafer.271 The auhors

urher deermined ha leakage a abou 7.6 percen

would make such a swich worse over a 100-year

horizon.272 These breakeven leakage raes were calcu-

laed, however, using he now oudaed esimaes o

mehane’s poency as a driver o climae change.273

Now, looking over he 20-year horizon, he breakeven

leakage rae is closer o 2.8 percen or elecriciy

generaion, when accouning ully or he new IPCC

esimaes o mehane’s poency.274 Similarly, on he

20-year ime rame, he breakeven leakage raes are

also lower, now a abou 0.9 percen when naural gas

displaces diesel in heavy rucks and 1.7 percen whennaural gas displaces gasoline in cars, alhough boh o

hese breakeven leakage raes do no incorporae several

acors ha would make hem even lower.275 As saed

already, naural gas leakage in 2010 amouned o more

han 3 percen o consumpion in 2010.276 I remains

o be seen how much more naural gas han 3 percen

leaked hen, and wheher much more han 3 percen

coninues o leak.277

Thereore, a bes, i will ake decades beore swiching

rom coal o naural gas in he elecriciy secor willranslae o moderaely less climae damage — ha is

he realiy o he “climae benei” presened by advo-

caes o drilling and racking or naural gas. Crucially,

his presumes ha srong regulaory and enorcemen

regimes can be pu in

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The Urgent Case for a Ban Fracking - Europe