3rd edition
Authors:	Duncan Kenyon, Nikki Way, Andrew Read, Barend Dronkers, Benjamin Israel, Binnu Jeyakumar, Nina Lothian
Publisher:	Pembina Institute
Publish Date:	October 2016
PDF Download:	[Landowners' Guide]              [Landowners' Primer]
Initiation Phase
Exploration Phase
Development Phase                 Overview of Oil and Gas Wells                 Before Drilling                 Questions About Lease Agreements                 Sour Oil and Gas and Emergency Response                 Hydraulic Fracturing                 Environmental Considerations of Hydraulic                  Fracturing
Pipelines and Other Infrastructure
Environmental Impacts
Abandonment and Reclamation
Compensation, Rights, and Hearings
Appendices

Environmental Considerations of Hydraulic Fracturing

Water use

Hydraulic fracturing operations typically use more water than conventional operations. This water can be drawn from surface, groundwater sources or alternative sources such as reused/recycled water, wastewater, and saline sources. In most cases, because water is only needed during the initial fracture stage, operators typically apply for Temporary Diversion Licences (TDLs) to access water.

The AER posts TDL applications when they are received, which provides an opportunity for landowners who believe that they may be directly and adversely affected to submit a statement of concern. If the operation meets the low-risk criteria specified by AER technical staff, a license is automatically issued; for example, diversions of small volumes of water from borrow pits which have captured water would be automatically approved. Otherwise, the AER conducts a technical review of the TDL application.

If water is to be sourced from a groundwater aquifer that also supplies your domestic or agricultural water, it is important that you request that a company demonstrate that sufficient water is available so that the aquifer is not depleted from the additional use. Further information related to groundwater use at oil and gas operations in general can be found in Water.

If surface water is to be used, the licence will stipulate the operational requirements to withdraw the water. It is standard for a TDL to require use of a fish screen in fish- bearing water bodies, and to limit withdrawals from watercourses to specified rates that are established to protect other users and the aquatic environment. Operational requirements exist for groundwater use as well, such as limiting downdraw on a pumping well. If you suspect that licence requirements are not being met, you should notify the AER and provide any supporting evidence.

Surface water and soil contamination

Water supplies must be protected through proper storage and disposal of fracturing fluids, as well as strict wastewater storage and treatment methods. However, surface water or soil contamination can occur if fracturing or flowback fluids are not managed properly. Spills can occur during day-to-day handling of fracture fluid, when flowback fluid production exceeds storage capacity, or when fracturing fluid or wastes are being transported to and from the site. Leaks occur if equipment is damaged or improperly operated.

The responsibility to remediate surface water or soil contamination is the same as discussed in Water.

Groundwater contamination

A primary concern for landowners is the potential contamination of a water aquifer that may result if a fracture, fault, or damaged well creates a pathway between the fracture formation and the aquifer. A number of ways have been identified for groundwater to become contaminated, including the upward migration of natural gas and saline waters from moving along leaky well casings, natural fractures in the rock, old abandoned wells, or permeable faults; the fracturing itself may also damage existing well casings. These pathways may allow for fluid and gas movement over long time frames and have the potential to cause substantial cumulative impacts on subsurface water quality. The known remediation techniques to remove the contamination are expensive and long- term, and therefore the risk of groundwater contamination has received significant public attention.

To reduce this risk, the AER requires that any hydraulic fracturing operation operating above or within 100 metres of the base of groundwater protection (BGWP) must perform an additional risk assessment to evaluate the potential for contamination from the operation. If the fractures are found to encroach on the BGWP, the operation must only use fracturing fluids that will not contaminate the water aquifer. While there are substantial requirements around well construction, integrity monitoring, etc. to further reduce the risk of groundwater contamination, some concerns have been raised by landowners that these regulations do not apply to deeper fractures in certain higher risk geology (e.g. sandstone) that can result in ground water contamination.

To minimize the adverse effects on water wells, hydraulic fracturing operations cannot operate within 200 metres of water wells and within 100 metres vertically from the final depth of any water well.

Air quality

After each fracture, the pressure is dropped and the injection fluids along with some reservoir fluids and gas flow back to the surface. The fluids are separated from the gas and stored on the surface, and usually reused in subsequent fracturing stages (see Disposal wells and CO₂ storage). The gas that flows to the surface at this stage must also be managed. As discussed in Fracturing and well completion, the lack of infrastructure with new developments can create some issues with respect to managing the produced gas. Venting, flaring and/or incineration can still release contaminants into the air. If venting, flaring or incineration are occurring or planned for in a development near you, you should discuss with the developer about the plans for collecting produced gas. Economic, environmental, and health outcomes are best if produced gas is captured and collected into pipelines.

Multistage hydraulic fracturing wells produce, vent, flare and incinerate much more solution gas during well testing than conventional operations do. Other additional sources of air emissions include leaks of methane and VOCs from operating equipment; emissions from diesel-powered trucks and machinery; road dust; and evaporation from storage pits and silica dust. If multiple operations in a region are fracturing simultaneously, the cumulative production of air pollutants can result in nuisance problems or, in extreme cases, health impacts.

There is emerging research about the health impacts associated with exposure to this unique mixture of gases. However, the challenge is that the complexity of the research as a result of the subsurface reactions of these chemicals and the resulting cumulative risk to the public through different routes of exposure. There also remains an ongoing lack of baseline monitoring that has made it difficult to distinguish between ambient pollution and the additional pollution from these operations. You should considering asking the company to complete comprehensive tests on your water supply, local airsheds etc as part of your lease.

Earthquakes

A number of earthquakes (also known as seismic events) have been linked to wastewater disposal and hydraulic fracturing operations, including operations in Alberta and B.C. As both wastewater disposal and hydraulic fracturing increase pressure in the sub- surface, there is a risk that they can trigger an earthquake.

Starting in 2013, the Alberta Geological Survey measured unexpected and persistent patterns of earthquakes west of the community of Fox Creek. By comparing the timing of the events with local operations, the earthquakes were determined to be associated with hydraulic fracturing. As these operations continued and earthquake activity intensified, the AER issued Subsurface Order No. 2 in 2015 to establish new seismic monitoring and reporting requirements for hydraulic fracturing operations only in the Fox Creek area.

This Order requires operators to monitor earthquake activity within 5 km of their wells and to develop response plans to address potential events. If an operator measures an earthquake event greater than a 2.0 local magnitude (ML) they must report the event to the AER. If an operator measures an event greater than a 4.0 ML they are required to immediately cease operations. Operations are not allowed to recommence until the AER approves.

In British Columbia, there were so many concerns with earthquake activity resulting from oil and gas activity that the B.C. Oil & Gas Commission conducted two studies (the 2012 Horn River study and Montney Study). As a result of the studies’ outcomes and increasing public concerns, the B.C. Oil & Gas Commission changed the permitting rules to require presence of ground motion monitoring during hydraulic fracturing activities and a ground motion monitoring report within 30 days of completing those activities.

Additional questions for hydraulic fracturing operations

Background

What equipment will you use to store and manage flowback fluids?

There are a few different ways of storing fluids on-site. Double-walled tanks provide the best containment, while single-walled tanks with a berm or simple lined pits provide less protection. Storage also must be the proper size to contain all fluids produced.

What is the expected level of vehicle traffic to and from the fracturing site?

Moving additional equipment and materials (as compared to conventional development) to the production site results in more truck traffic . This can cause a nuisance, safety concerns and damage to roads not designed for heavy truck traffic.

Land

Should I expect seismic activity resulting from your operations?

Fracturing has resulted in seismic activity in Alberta, and there are operational methods to reduce the frequency and severity of these events.

Air

How will your flaring or incineration operations affect air quality in combination with other operations in the area?

Fracturing operations tend to produce larger volumes of air pollution than conventional operations. When operations are concentrated together, the cumulative air pollution can reach levels that can create odour, nuisance or potentially health impacts.

How frequently will you inspect the wells and associated infrastructure for leaks?

Methane leaks from the operations can have negative impacts on the local air quality as methane contributes to the creation of VOCs. Leaks can also contain other hazardous air pollutants.

It may be valuable to negotiate in your lease agreement that the operator follow the Best Practice guidance from EO100 on leak detection and repair:

“Operator ensures that all equipment on the well pad is equipped for minimizing methane and other air emissions, and conducts quarterly* checks of this equipment to ensure it is working properly as part of a systematic Leak Detection and Repair Program.”

Water

What chemical additives will you be using in your fracturing fluid?

A wide variety of different additives are used in fracturing, all with different toxicity. You should review these chemicals (information is available at fracfocus.ca) to determine what you might be exposed to.

How will your operation impact my water well?

Operations must take all measures to protect groundwater resources, especially when those resources are currently being used.

It may be valuable to negotiate in your lease agreement that the operator follow the Best Practice guidance from EO100 on water testing:

“Operator conducts baseline and post-completion sampling of individual wells and surface water within a minimum radius of 2,500 feet, or regulator limit, whichever is greater, prior to drilling of wells and installs monitoring wells to monitor the quality of water in aquifers in productive use that are being drilled through. Testing includes levels of hydrocarbons, arsenic, mercury and total dissolved solids in aquifers and surface streams.”

Will you provide baseline monitoring for my water well quality?

You should require in the lease that a company provide baseline monitoring for your water well to ensure any changes in water quality from the operations are recorded

Will you provide ongoing monitoring of the level of water in water well?

You should require in the lease that the company provide regular annual measurement of the level of the water in your water well. Dramatic changes in your water well level can indicate that issues have occurred as a result of fracturing activity.

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