Hydraulic Fracturing Chemical Disclosure: Too much information?

As you’ve probably already heard, the Texas Railroad Commission (the oversight agency for the Texas oil and gas industry, for the non-Texians in the audience) today approved a regulation that will require the public disclosure of chemical ingredients used in hydraulic fracturing of oil and gas wells permitted on or after February 1, 2012 [read the RRC’s news release]. This is a groundbreaking (no pun intended) move that, among other things, demonstrates that the industry can work in harmony with traditionally adversarial groups when it wants to. These regulations were widely supported not only by environmental and public advocacy groups, but also by oil and gas operators.

The report from the hearing [PDF] in which the final rules were approved makes for interesting reading, especially the sections documenting the public comments regarding the proposed regulations. (One item of note is Exxon’s hearty approval of the rules, despite the fact that they are not one of the companies [PDF] who is currently voluntarily providing the information.) Update: Sorry; I just noticed that Exxon is actually listed under the entry for XTO Energy.

Many people may not realize that about eighty oil and gas companies doing business in Texas have already been voluntarily making these disclosures via a website called FracFocus. Not every well fracked by these companies is listed, but there’s a big database already being built, and a very user-friendly interface for searching for wells in a given geographic area to find out what’s being pumped into the ground to make the wells more productive. This same website will become the vehicle for the required reporting under the new regulations. 

I think it’s safe to say that the Texas regulations will become a model for other states to follow as they deal with concerns over hydraulic fracturing (which, by the way, has been around for 60 years, has been applied to more than a million completions, and which has never – in Texas, anyway – been linked to groundwater contamination, regardless of what propaganda like the “documentary” Gasland would have us believe). This action will also probably head off federal intervention which would undoubtedly be more onerous and less logical.

I expressed support for public disclosure on this site a year ago. I thought it was a wise idea then, while I was a non-industry worker, and I still do, as an oil and gas company employee (a company that is already voluntarily disclosing frac ingredients via the FracFocus website).

However…

I doubt that disclosure of the list of chemical ingredients is going to be of much practical use to most people. A list of obscure compounds simply won’t be meaningful to the layperson. For example, let’s look at the Hydraulic Fracturing Fluid Product Component Information Disclosure sheet [PDF] for SM Energy’s University 7 Berkley #6 well located in Andrews County, just north of Odessa. SM Energy is my employer, by the way; it’s only fair to use one of our own wells in this example.

The Berkley #6 is an oil well with a vertical depth of almost two miles. During the completion process, the formation was fractured using a solution of over 700,000 gallons of water (an Olympic-sized swimming pool holds only about 600,000 gallons), into which was mixed a combination of 27 additional substances, ranging from the mundane (citric acid) to the exotic (dodecylbenzenesulfonic acid, cytclohexene, and alkylaryl ethoxylate). Some of these substances comprised as little as .0005% of the total injected volume, or the equivalent of less than four gallons. I don’t know about you, but I really can’t assess whether this concentration of 2-butoxyethanol or sodium metaborate is a bad thing or not. This stuff is 10,000′ underground, with several million (billion?) tons of rock on top of it. How can I assess the risk of having a chemical that, for all I know, occurs naturally elsewhere, pumped in relatively minute quantities into a deep hole in the ground?

If you looked at the above-linked PDF, you may have noticed a column labeled “Chemical Abstract Service Number (CAS #).” The CAS is a division of the American Chemical Society, and it maintains a database (registry) of more than 60 million substances. If you can access this database, you can learn a bit about the nature of these substances. Unfortunately, you have to be a paid subscriber to access the official CAS registry; fortunately, other organizations are more altruistic and offer alternative methods of access. The best CAS search engine I’ve found is provided by the National Institute of Health’s PubChem service. Simply type the CAS # into the search box, click “Go,” and on the resulting page, click the “Full Report” link to get more information about the chemical than you probably ever wanted to know.

I’m of the opinion that giving the public more information is almost always better than giving it less, even if that information might be subject to misinterpretation or even misuse. Our industry stands to lose a lot more than it might gain by continuing to keep fracking contents secret.