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The Ground Water Protection Council (GWPC) and IOGCC have implemented a voluntary chemical disclosure website, www.FracFocus.org, where oil and gas exploration and production companies can disclose the additives used in the fracking process on a well-by-well basis starting with wells drilled in 2011.
We fully support the public disclosure of fracking fluid additives, and we have provided a description of the fracking additives we use on www.FracFocus.org. In addition, we submit information on these additives to the necessary regulatory agencies. We obtain Material Safety Data Sheets for every chemical we use in the fracking fluid.
Type of Water Used in Fracking
We use non-potable water sources wherever feasible. We also build frack ponds where we dig and collect rainwater to use in our fracking operations.
Disposal of Fracking Fluids
Once the well has been fracked, most of the sand introduced while fracking remains underground and holds open the fissures in the rock formation so that the oil and gas can be retrieved. Some of the water and additives that comprise the fracking fluid eventually flow back up through the well.
In 2011, we began to use predominately a closed loop drilling system where the flowback fluids are temporarily stored in steel tanks, rather than lined pits. In Texas, the steel tanks we use are open top for the first two to three days and then we use steel tanks that are covered and have pressure relief vents. In all other areas, we use only covered tanks with pressure relief vents.
When possible, we recycle the flowback fluids and use them again in other fracking operations. This reduces our fresh water consumption. Where it is not possible to recycle the fluids, we dispose of them underground into permitted injection wells that are drilled and maintained in accordance with the Environmental Protection Agency’s Underground Injection Control regulations or dispose of them at other permitted facilities that are approved to accept such fluids.
Well Operations Air Emissions
We have installed emission reduction devices on our compressors, and, where practical, our loading and storage tanks and other equipment, and we use BTEX controllers on our dehydration units to reduce air pollutants. We make every effort to put the well in line promptly after completion so that we can further reduce emissions from the well site. Our emissions are disclosed annually in every state where we operate.
Beginning with the first quarter of 2012, we intend to start using green completion practices on each well we drill where the infrastructure is in place. “Green completions” take place during the clean-up stage of the completion, after the well has been fracked. The clean-up involves removing the water necessary to frack the well. During this flowback, natural gas is produced with the water. What makes the well completion “green,” or environmentally friendly, is that the gas is separated from the water and contained and transported through a pipeline instead of being released to the atmosphere, thereby reducing emissions from the well site.
Where infrastructure is in place, we use pipelines for the transportation of production to reduce transportation emissions. Currently, we sell or transport almost all of our production in West Virginia, Mississippi, Pennsylvania and East Texas via pipeline. Infrastructure is currently being constructed and expanded in the Eagle Ford Shale. Once that is completed, we expect to use pipelines for the transportation of our Eagle Ford Shale production.
Solid Waste and Sludge Residuals
It is our policy to dispose of drill cuttings and other solid waste and sludge only in licensed disposal facilities.
We also monitor and track NORM (naturally occurring radioactive materials) in our waste streams and, if necessary, we treat it and dispose of it properly at licensed facilities.
After completing the well, we retain a certified third party laboratory to collect and analyze water samples from the same water sources we collected from prior to drilling. We have not had any negative outcomes when comparing pre-drilling and post-completion water samples. We share the post-completion water testing results with the landowner once we receive them.
End of the Life of the Well
Approximately one year after the well starts producing, the well site is reclaimed and the size of the disturbed land necessary to produce the well is significantly reduced.
After the well has ceased producing, we plug the well in accordance with local regulations and take care to restore the land to leave it as close to the way we found it as is reasonably possible.
Contractor Safety
Our operations are handled by trained personnel, and we routinely conduct on-site safety reviews to ensure compliance with best practices. We have also adopted, in accordance with local regulation, emergency response plans so that we are prepared to respond quickly and effectively in the unlikely event of an unplanned incident. Each year in Texas, Pennsylvania, West Virginia and Mississippi, we have a picnic dinner with first responders to educate them on our activities and to discuss how best to respond to any potential issues that may arise.
Our contractors are routinely audited:
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before they can commence our work, our Environmental, Health and Safety group audits our contractors to ensure the adequacy of their environmental, health and safety training;
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if we find their training is deficient, we require them to attend our training sessions; and
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in addition, in 2012, our outside independent internal auditing firm will complete a specific environmental, health and safety audit. |