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e-book Hydraulic Fracturing: Chemical Disclosure Requirements

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Public disclosure requirements vary widely from state-to-state. Some states have no disclosure requirements at all. Of the states that do, most have included trade secret exception provisions allowing oil and gas companies to refuse to disclose the chemicals they use in fracking. More importantly, very few state laws that have trade secret exceptions also require that the company provide any substantiation that the trade secret is legitimate.

Without some kind of uniform factual substantiation requirement, what is to keep oil and gas companies from abusing trade secret exceptions? A possible solution has emerged.

The results revealed that larger firms were more likely to voluntarily submit information to the FracFocus website, regardless of whether the firms were operating under specific state regulations. How should we interpret these findings? The results also hint at a number of mechanisms that may be behind the relationship between firm size and engagement, and it would be interesting to further investigate what they are and how they influence corporate behaviors.

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Although a complete risk assessment is beyond the scope of this study, evaluation of the frequency of chemical use and the mass of chemical used can provide context for the potential risk associated with the use of hazardous chemicals. Quantities of the most toxic chemicals used varied.

Seven of the toxic chemicals were used in median quantities of less than 10 kg per treatment, while nine were used in larger amounts. The complexity of toxicity information, paired with data on frequency of use and quantities applied Table 3 , suggest that while hazard assessments such as this as useful for characterizing chemical-use, more detailed risk assessments are needed. Propargyl alcohol and naphthalene were used in small quantities median masses of less than 5 kg per treatment although hydrochloric acid and ammonium chloride were used in much higher amounts median masses of 1, and kg per treatment.

The higher number of chemical additives posing ecotoxicity issues and the frequent use of these chemicals, suggests that the ecosystem risks need to be fully evaluated in produced water reuse projects.


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  4. To further investigate the potential hazards associated with chemicals used in routine oil and gas development activities, six regulatory lists were referenced S4 Table. The result of the comparison with these regulatory lists was that twenty-two of the chemicals were on the California Toxic Air Contaminant List [ 41 ], 12 were on the California Proposition 65 List [ 40 ], 10 were on the U.

    These results demonstrate that some of the chemicals used in routine oil and gas development activities are chemicals of concern, as identified by multiple state, federal, and international environmental agencies due to their toxicities. However, the actual risk proposed by these chemicals would need to be determined in the context of their use and potential release into the environment. It should be noted that comparison with regulatory lists also indicate that many of the chemicals used in the SCAQMD are expected to present little or no human health or ecotoxicity hazard, even if discharged into the environment.

    These chemicals include inert minerals e. In this study we compared routine oil and gas field chemical use, which is not typically subject to disclosure regulations, with chemical use for hydraulic fracturing and other well stimulation techniques that are subject to regulation mandating chemical disclosure. Our results indicate that there is substantial overlap between the chemicals used in well stimulation and those used in routine oil and gas development activities. Similarities were observed in the numbers of chemicals used, the masses in which they were applied, the frequency of use, and their toxicological profiles.

    Our analysis shows that hydraulic fracturing is just one of many applications of hazardous chemicals on oil and gas fields and suggests that limiting disclosure requirements for oil and gas field chemical-use to hydraulic fracturing and other well-stimulation events may not be fully protective of human and environmental health, especially in the context of beneficial reuse of produced water for irrigation, wildlife, livestock watering, and groundwater recharge.

    Browse Subject Areas? Click through the PLOS taxonomy to find articles in your field. Abstract The potential hazards and risks associated with well-stimulation in unconventional oil and gas development hydraulic fracturing, acid fracturing, and matrix acidizing have been investigated and evaluated and federal and state regulations requiring chemical disclosure for well-stimulation have been implemented as part of an overall risk management strategy for unconventional oil and gas development.

    Download: PPT. Table 1. Number of chemicals used and their summed masses per event for oil and gas development does not include water a. Comparison of chemical-use between routine activities and well-stimulation treatments within the SCAQMD Overall, a large number of constituents were used in both routine activities and well-stimulation activities and chemicals were applied in large masses Table 1.

    Fig 1. Venn diagram showing number of chemicals used in oil and gas production. Fig 2. Venn diagram showing number of chemicals used for acidizing operations routine and well stimulation. Fig 3. Concentrations of hydrochloric acid HCl used in acidizing. Fig 4. Concentrations of hydrofluoric acid HF used in acidizing.

    Comparison of chemical-use between routine oil and gas development activities in the SCAQMD and hydraulic fracturing throughout California The number of chemicals used in routine oil and gas development activities in the SCAQMD is as high or higher than the number of chemicals used for hydraulic fracturing throughout the State of California [ 21 ].

    State Comparison Charts

    Table 2. Data availability for chemicals used in routine oil and gas development. Comparison of chemical-use between routine oil and gas development activities in the SCAQMD and other oil and gas fields throughout the U. Analysis of chemical hazards using data science approaches One of the important requirements of regulations directed at oil and gas development and production is the disclosure of the types and amounts of chemicals used on-field [ 1 , 2 , 4 , 11 , 46 ].

    Table 3. Chemicals used in routine oil and gas development that are classified by the United Nations Globally Harmonized System GHS Categories 1 and 2 for acute mammalian toxicity a. Table 4. Evaluation of chemical hazards using regulatory lists To further investigate the potential hazards associated with chemicals used in routine oil and gas development activities, six regulatory lists were referenced S4 Table. Conclusions In this study we compared routine oil and gas field chemical use, which is not typically subject to disclosure regulations, with chemical use for hydraulic fracturing and other well stimulation techniques that are subject to regulation mandating chemical disclosure.

    Supporting information. S1 Table.

    Fracking Companies Fight EPA's Proposed Chemical Disclosure Rules - Scientific American

    Constituents used for routine oil and gas development activities exclusive of well stimulation in the SCAQMD, June 4, to September 2, , sorted by frequency of use. Total number of events is 1, S2 Table. S3 Table. S4 Table.

    Wyoming to strengthen chemical disclosure requirements for fracking operations

    Chemicals reported to the SCAQMD and used in routine oil and gas development activities considered chemicals of concern based on six reference lists consulted. References 1. California Department of Conservation. Environmental Protection. Washington, D. Water resource impacts during unconventional shale gas development: The Pennsylvania experience. Int J Coal Geol. View Article Google Scholar 4. Bureau of Land Management. Washington, DC Fink J. Burlington, MA: Elsevier Science; View Article Google Scholar 6.

    Kelland M. Production Chemicals for the Oil and Gas Industry. Hudgins CM. Chemical treatments and usage in offshore oil and gas production systems. J Pet Technol. View Article Google Scholar 8. View Article Google Scholar 9. Petroleum Production Systems, 2nd ed. National Research Council. Science and Decisions: Advancing Risk Assessment. Doman L. United States remains largest producer of petroleum and natural gas hydrocarbons. Energy Information Administration; May Denver, CO: U. Department of the Interior, Bureau of Reclamation; Veil J.

    Produced Water Volumes and Management Practices in Heberger M, Donnelly K. Recovery rates, enhanced oil recovery and technological limits.