“The question is, did you create an environmental problem by using it, and the answer is ‘no,'” said Lee Fuller* of the Independent Petroleum Association of America.
That quote from Fuller comes from Friday’s E&E article:
Diesel still used to ‘frack’ wells, FracFocus data show
Mike Soraghan, E&E reporter
EnergyWire: Friday, August 17, 2012
Dear Mr. Fuller, the proof of environmental harm is all wrapped up right here:
Because baseline testing is not required nationwide before fracking occurs, there is no way for landowners to prove culpability when their water ends up contaminated after fracking.
When a landowner does have proof, operator hands them a non disclosure agreement (NDA) that takes away their 1st Amendment rights and a check to buy their property so they can leave. All proof is hidden behind the NDA, and since the operator now owns the property no further testing is possible.
Only, one time the landowners did get baseline testing and they gave me the results. Shortly before fracking their water was clean and safe.
Shortly after fracking they had follow up testing that showed their water was contaminated with high levels of MTBE an additive in diesel fuel. The landowners also gave me the the follow up test results.
Just like the tobacco mafia did any time new tobacco regulation was enforced, the oil & gas mafia finds a way to circumvent attempts to force it to be more responsible.
Industry is trying to use a very narrow definition of diesel while EPA wants to use a broader definition that would include things like kerosene and petroleum distillate. (I see petroleum distillate on FracFocus quite often.)
At first I thought the oil & gas mafia was using the tobacco mafia‘s playbook as a blueprint. Now I’m finding that many of the players are the same. Maybe it’s really one big mafia that we should call the Frackbacco Mafia.
Tell the EPA to Ban Diesel in Fracking Fluids!
Comment before August 23 on EPA’s Guidance on Diesel
The EPA, until August 23rd, is welcoming comment on their guidance to states and regional offices over how to regulate the use of diesel fuel in fracking fluids. Our guidance to EPA is simple. Ban diesel.
This all started back in 2005 when the newly re-elected Bush/Cheney Administration began hosting secret, closed-door meetings at the White House with Halliburton and other drillers. The meetings resulted in the Energy Policy Act of 2005, which exempted fracking from our bedrock environmental laws.
But Congress recognized the cancer-causing dangers of usingdiesel fuel in fracking and specifically chose to ensure EPA still has the authority to regulate diesel use.
But the industry ignored the law. From 2005-2009, drillers illegally injected 30 million gallons of fracking fluids containing dieselwithout a permit.
That brings us to today. The EPA needs to hear from us.
They already heard from the industry. At a recent hearing, the American Petroleum Institute actually argued that the EPA dieselguidance was a “solution in search of a problem”. The solution need not search very far for a problem when the industry is violating the law.
Only completely banning diesel use will create certainty and help enforcement and compliance.
TAKE ACTION: Tell the EPA to ban diesel before August 23rd!
Energy In Depth (EID)
Independent Petroleum Association of America
Vice President of Government Relations
About Sharon Wilson
Sharon Wilson is considered a leading citizen expert on the impacts of shale oil and gas extraction. She is the go-to person whether it’s top EPA officials from D.C., national and international news networks, or residents facing the shock of eminent domain and the devastating environmental effects of natural gas development in their backyards.
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Chip Northrup says
diesel fuel in frack fluid ? still ?
that’s one of the mystery ingredients ?
Andy Mechling says
I think your questions are right on the money.
These seem like simple questions. But this whole thing is an unbelievably cloudy mess at this stage. The devil is very much in the details here. I am still working on my comments to EPA. In the meantime, there are a few key points I would like to share with the Bluedaze readers. I am going to try to keep this simple. Thank you all for bearing with me here if you can.
First, it is clear that EPA got played like a fiddle here. Somehow agreeing to a plan which allowed them to regulate only diesel, without ever first defining diesel. What an absolute farce from the onset.
In the draft guidance document . . . which is the “new rule” that we are being asked to comment on . . . the term “diesel” is interpreted broadly, and includes Kerosene (diesel #1) All diesel fuels, including Hi and Lo Sulfur blends (diesel #2) as well as “Fuel Oil” grades #1,2,4 and 6. This is seemingly good news.
6 CAS Regsitry Numbers (CASRN) are provided – which are designed to encompass all of these products. This is one of the specific subjects EPA is asking for feedback on. (there are 63 million and counting CASRN sequences)
I think EPA means well. I think they’ve pretty much got “diesel” covered here. I don’t think the problem is in their interpretation of what is and what isn’t diesel.
The problem is that the new rule will be completely unenforceable, as written, because there will never be any way to independently verify that any of these products are what they claim to be.
The CASRN system simply was not designed to provide regulators with the type of detailed compositional breakdown that would be reauired to enforce such a scheme. What is being proposed is really no more than a further extension of “the honor system”. I do not think this is appropriate.
One obvious problem is that, if regulation is only “triggered” by the inclusion of one of these 6 CASRN sequences. Drillers could simply mix their own blends and acheive exactly the same fluids to pump downhole, as none of the individual components of diesel are included in the regulation.
Many of the toxic components of diesel fuel (i.e. benzene, xylene, napthalene, hydrogen sulfide) naturally have their own CASRN sequences. None of these sequences are listed by EPA in the draft guidance document.
In my opinion, it would make much more sense if EPA were to decide to regulate the toxic ingredients of diesel fuel. At least if they did, there might be some hope of someday being able to enforce such a rule, as, unlike diesel, these components can be analyzed for, positively identified, and quantified.
For example: If EPA has a problem with xylene – EPA should regulate xylene content. If EPA has a problem with sulfur content – then EPA should regulate sulfur.
EPA has never made it clear why they feel the need to regulate the underground injection of diesel, or at least not to me. Is this about protecting the price of diesel at the pump? Is it about toxicity to humans? Fish? Soil? Air? What is the chief concern?
Here is the really screwed up part in my view: Many of the fluids blended for use in hydraulic fracturing or other EOR activities are far more toxic and hazardous in every respect than diesel ever was. These fluids will be exempted from regulation specifically because they cannot be considered “diesel”. Never mind that they might look, smell, taste, and behave, very much like diesel. These are custom blends, and quite exempt.
But this is only the start of the confusion.
Chip; if you take a close look at some of the commercial products listed on the frac focus sites, I think you will see that many of these “additives” (in the form of friction reducers, corrosion inhibitors, emulsion breakers, etc) list CASRN sequences representing complex hydrocarbon solvent mixtures as part of those disclosures.
Nobody would call these mixtures diesel. These are custom hydrocarbon blends, engineered for downhole use before they ever left the refinery (in Rotterdam). Would these power a diesel engine? Oh hell yes, but why should this matter anyway? What does that have to do with Anything?
The biggest problem in my view, is that EPA seems to be turning a blind eye to the types of products that are ACTUALLY being injected into the subsurface in high volumes. These are refinery streams, they are liquid. This much we know. These substances probably won’t be covered under the new rule. It makes very little sense.
The problem with diesel fuel is that it floats on water. If it floats on the water, it won’t work for downhole use in an oil well. This has been much discussed in the oil journals and literature over the past 70 years or so.
We know which “rheologic” properties tend to make a fluid attractive for downhole use. EPA must be playing dumb here or something, because there has never been much mystery as to what works and what doesn’t. The literature is extensive, and the patents are explicit.
By the mid 1940s, oilfield engineers had figured out that by blending ultra-heavy solvents such as carbon disulfide and carbon tetrachloride into kerosene, these modified hydrocarbon formulations would then sink through the water in a well bore, and “achieve close contact with the rock”.
In the overall scheme of things; not that much has really changed. Water is still water. Kerosene and Diesel still lack the density, or “specific gravity”, needed for downhole use, unless they are heavily modified by additives. The same additives that worked then are the same additives that work now.
So what works downhole?
First, all of these fluids must be heavier than water. This is true of hydrocarbon based mixtures, as well as saltwater “brines”. Notice that all drilling fluids, friction reducers, corrosion inhibitors etc. will display specific gravities just slightly greater than 1.00. This is not by accident.
Viscosity matters. Low viscosity is what they are looking for. Light oils are easier to inject and retrieve through pipelines and wellbores.
Organic sulfur content matters. More is better; essentially. CS2 remains the king of solvents for oil recovery. Concentrations of CS2 above 1% present an explosion hazard however, and this continues to present problems.
Long-Chain Hydrocarbons, like those which comprise diesel mixtures, are generally not ideally suited for downhole use, as these require more energy to compress into liquid form, and may cause other problems downhole, (especially by precipitating asphaltene solids) when compared to the smaller molecules like propane, butane, ethane, etc.
Much like CO2, these Natural Gas Liquids (NGLs), are now in high demand out west, both as components of EOR fluids and as diluent in pipelines.
Some producers are no longer choosing to clean these liquids up, or to even bring NGLs to market at all, as these products have so much value right there in the oilfields and pipelines. This has led to some hurt feelings. We do like our propane out here. We were hoping the price would go down.
I’m not sure many people saw this coming, but in any case, I think EPAs guidance needs to reflect today’s realities. The use of NGLs in fracking operations is rapidly expanding, and this highly dangerous practice clearly needs to be regulated or banned outright.
The rest of my comments here all represent some degree speculation on my part.
Diesel and Kerosene blends lack the specific gravity required of downhole solvents. Also, these middle distillate streams are in record demand. No one wants to pay $4/gallon for a product destined to be pumped underground.
Residual Fuels, including Bunker Fuels, represent High Sulfur and Sulfur- Added diesel blends. Some of the Bunker-type fuels ( Fuel Oil #6) do list specific gravities >1, and therefore will be expected to sink through water, however, most of these heavier fuels will be too thick, or too viscous, for use as downhole solvents.
Unwanted suspended solids might also represent an issue with the Bunker-type fuels. Complicating the issue is that these are the fuels that nobody wants right now. New York City finally outlawed heating oil no. 6 only this year . . . isn’t that right? Cargo Ships and Cruiselines operating offshore are just now getting cut off from the worst Bunker fuels also.
If these heavy bunker fuels worked well as fracking or EOR fluids; the oilies would love it, as there are very few markets left for these nasty residual streams. For good or bad though, these products don’t seem to be quite what the frackers are looking for.
During my review of MSDS information, I did locate one refinery product-or type of product that I believe might be very attractive for use as a solvent for hydrocarbon recovery. These are the products known as “Decant Oil” , “Clarified Oils”, or “Slurry Oil”.
These seem to have all the right characteristics; including relatively low viscosity, dangerously high sulfur content, and a specific gravity just over 1.0.
My immediate concern is that these products might not fall into any of the categories as outlined in the guidance document. Diesel is nowhere in the name or description. This is not diesel fuel. It is clearly intended for other purposes. This is slurry oil.
So: this stuff is more toxic than diesel, more explosive than diesel, and exponentially more hazardous to marine life – as it will sink to the bottom. Slurry oil might make a better candidate for EOR use than diesel or kerosene . . .but still won’t be regulated under the new rule because its not diesel.
I believe that these “Clarified Oils” are “clarified” in much the same manner that naturally occurring brines are “clarified” . . . . by the addition of various thiocarbamate “salts” as floatation agents and the subsequent use of “skimmers” to remove the captured solids.
When first introduced for oilfield use in the early 1990s, these “salts” were touted and patented as a “safer” form of CS2, providing a “safer” way to deliver CS2 downhole.
Under the proposed new rule, carbon disulfide, carbonyl sulfide, and hydrogen sulfide come away completely unscathed. Completely unregulated. Same As it Ever Was.
Presently, there are Acid Gas Injection (AGI) projects permitted and operating in Texas, Wyoming, and Michigan in which acid-gas streams with H2S concentrations (reportedly) as high as 80% are being injected at high volumes and high pressure into producing formations for the purposes of Enhanced Oil Recovery. 800,000ppm hydrogen sulfide.
And here we are worrying about how to define diesel fuel.
I simply don’t get it.
Fracking Crazy says
Thanks for the very informative comment.
I’ve known for some time about the high sulfur concentrations in the air around oil and gas well drilling sites.
I knew that they were used heavily in this industry.
I’m glad to have a better understanding why, besides separating the H2S from the gas, why they are using, especially Carbon Disulphide.
I feel strongly that as we move forward with this devastating technology there will be a rise in population who, like myself, have developed full blown sulfur allergies.
This is not an easy allergy to handle, or to get away from.
With sulfur concentrations so high, American’s physiological systems will become overloaded and reactionary to it.
I sure do miss my onions and garlic, my guacamole, my wine, washing my hands in public places….just to name a few of my modern day inconveniences.
Why? Enhanced recovery is one reason. http://www.texassharon.com/2012/05/01/carbon-disulfide-in-the-barnett-shale/
This so called “diesel” can consist of a hodge-podge of many chemicals and materials for use in fracking. Much of the stuff is nothing but chemical waste from chemical plants and is “sold” or given away to the fackers for cheap disposal.
Everyone understands diesel is a refined product from oil, right? Every one driving diesel automobiles also know it’s not a “cheap by-product” of oil. So, step back & ask..Is it bad to inject a petroleum product into a petroleum reservoir? You are mixing one petroleum product with petroleum and coming out with a petroleum mixture. Assuming the casing was cemented properly (which has nothing to do with the use of diesel but, it’s the only way to get any petroleum into our underground fresh water reservoirs), how is a mixture of petroleum any worse than petroleum?
The advantage of using diesel is that it is lighter than water & can still “carry” the sand needed to hold open the fractures created in the rock then, when pumping ceases & the pressure drops, it is light enough to drop out that sand in the fractures and flow back to the wellbore. Having a lighter column of fluid requires less pump horsepower to get it in the reservoir ie. fewer trucks on the surface. One of the disadvantages is it’s not as cheap as water from underground sources.
The industry is phasing out diesel and has only used it when needed. It may not be reasonable to expect an industry as big is this one to move as quickly as we all would like but, it is happening.
What’s bad is when that petroleum product ends up in our drinking water which seems to be happening with a greater frequency these days.
That kind of thing plays hell with our patience.
Andy Mechling says
Communities all across the gas patch are being exposed to highly toxic organic sulfur compounds that were not formed naturally.
The toxic brews being injected into the wellbores are clearly more hazardous than the crude oils being extracted. Exposure to these chemicals will generally pose a greater health risks than being exposed to crude products alone. Carbon disulfide is highly explosive.
We don’t like this. We don’t want our families exposed to explosive neuropoisons.
Is any of this really so hard to understand? Your argument makes no sense.
It’s not the use of diesel that is contaminating your water. It’s either the improper isolation of the fresh water aquifer with the required steel & cement OR improper operations that put too much pressure on the pipe & cement across the water zone which can split the protective layers put there. Either of these situations can be detected from the surface as soon as they happen BUT, the operating company has to do something about it when/if it happens.
A simple monitoring of the initial fresh water isolation process by an educated regulator can help prevent the 1st situation, ASSUMING the company can’t be trusted, (I know no one trusts any oil company regardless of their work product these days), there must be a monitor. Cutting the budget of field inspectors is not the right way to save a buck & MANY states have done just that.
Improper operations that split the pipe at shallow depths is MUCH less common. If that happens, profits drop to slim & none and operational problems begin. You know the company man doesn’t want that to happen.
Everyone understands fresh water is more important than oil & gas. IF someone pollutes that water they need to pay for the delivery of fresh water to all impacted all the while they are remediating the damage caused. How that gets done is left to the states. If your state can’t handle that responsibility, you need new representatives that can.
If diesel or one of it’s constituents ends up in our water then we don’t really give a $hit how it got there. All we know is that we no longer have a viable source os drinking water and without that we have nothing. The fact that we have nothing is NOT our fault, it’s YOURS.
As you know, operators do not pay for the delivery of fresh water when they have contaminated water sources. They will do ANYTHING it takes to keep from doing that. All of them are the same. They never admit responsibility. If that is not true, please name ONE time an operator has admitted they contaminated drinking water.
States are not handling this responsibility and it’s doubtful they ever will.
Andy Mechling says
Are you then in favor of EPA’s proposed requirement for “green completions”?
Are you prepared to address concerns over emissions to air?
Do you support the various exemptions from reporting that oilfield operators work under? Is the Halliburton loophole a good thing?
It sounds to me like you are suggesting more regulation on the state level, and stepped up monitoring by the agencies. Can you give us an example of legislation that you have supported that would enable or fund heightened monitoring and enforcement efforts? Please be specific.
Can you name politicians that you support that have been trying to fix the problems? Initiatives? Ballot measures? Trade groups? Community groups? Anything?
Please give us something tangible we can work with here.
My point is the frac’ing process is barking up the wrong tree FOR WATER CONTAMINATION. If fresh water contamination is going to ever exist, it will be a result of poor completion techniques &/or poor regulatory compliance which COULD result in faulty fresh water protection, not the frac’ing process itself. I don’t know of any caused by frac’ing, do you?
Green completions are being tried. Shows good possibilities.
We are all prep’d, submitted and awaiting approval on our EPA air emission permit.
I don’t know of any exemptions of reporting. We report how often we change the latrine water on our rigs. Anything lesser MAY have been allowed to go unreported but, I doubt it.
I am not suggesting more regulation necessarily but, enforcement of existing would be a good thing. Some states may need to consider looking at the oil states commissions to get ideas (sounds like good & bad?) but, enforcement of what is on the books would go a long way to trying to do the best possible job for everyone involved. Some of us are human.
I am trying to be as tangible to the discussion as I can.
I suppose my politics aren’t yours, sorry.
Yeah, you’re right.
Fracking is not responsible for water contamination the same way that sex is not responsible for pregnancy.
Andy Mechling says
Sharon is right Nick. Your argument is weak.
Aquifer contamination is caused by “poor completion techniques” and “poor regulatory compliance”, but not by fracking? Do you seriously expect us to buy this argument?
I asked if you supported requirements for “green completion” techniques, as proposed by EPA.
You answered with “Green completions are being tried. Shows good possibilities.”
Thanks for that Nick. I take that to mean you do not support the proposed rule. But you say you support increased enforcement? Enforcement of what? Let’s start right here.
If you oppose the requirement for “green completions”, please elaborate as to why. We are listening.
OK, so you’re getting ready to frack a well, and your permit for air emissions is all ready to go. Wonderful news.
From your responses, Nick, I am assuming that you are one of those operators who chooses not to utilize “green completion” techniques at all. Would you care to elaborate here? Some operators have been pro-active in this regard.
You say “I don’t know of any exemptions from reporting”. I am having a hard time believing this statement; but I will try to take you at your word.
The rest of us up here are quite aware that fracking operations are exempted from reporting requirements under the Clean Air Acts, as well as the Safe Water Drinking Acts. Many operators still refuse to disclose fracking chemicals via sites like Frac Focus. Operators that are participating only disclose those chemicals which they choose to disclose. Some of us don’t think this is right Nick.
Now you know.
How about you? Would you care to disclose the chemicals you are fracking with? All the chemicals? Somehow I’m doubtful. Hopeful, but doubtful.
From your statements earlier, about diesel being used because it is lighter than water, and the sand dropping out to prop open fissures, . . . it seems that you are either very confused, not especially well informed, or just completely full of baloney.
You left out the part about the gels and the breakers and the additives and the various strategies for introducing these mixtures – down through the water layer – and into the producing formation; so that fracturing can commence. It is only subsequent to this that the gels are broken, and the sand is released.
Without extensive modification, diesel fuel will float on top of the water in a well bore, and never do anybody any good. Surely you must know this.
Lastly Nick, I would like to thank you for hanging in, and engaging us in this way. You are not on friendly turf here, and I appreciate your tenacity. Thus far, I haven’t found much in your comments that I can agree with, but I very much appreciate the conversation; and continue to believe that it needs to start somewhere.
Whatever you do though, please don’t apologize for your politics.
I will never apologize for mine. Thanks for asking. I am staunchly pro-American, and I am staunchly pro-democracy. I will fight to see this country stay together as the United States of America. I hope Texas doesn’t really try to secede from the Union. I wish many in Texas did not view the United States Government as some kind of foreign power.
I hope that if Texans do decide to remain part of our Union, that the framework will allow for citizens of Texas will be able to enjoy the same constitutional protections that the rest of us do.
Yes I’m talking about protections under Federal Law. Yes, I’m talking about Federal regulations. Yes, I am talking about the basic human rights that are access to clean air, and access to clean water.
If you are about to commence on a project that will burp millions of gallons of highly toxic liquids to the surface . . . and if you are not attempting to capture the emissions associated with this practice. . . .
. . . then in my book, you are a big part of the problem Nick. Please become part of the solution instead. Please clean up your act, and try to become that responsible steward you purport to be. Here’s hopin. Thanks again.
Andy, Yes I expect the truth will eventually be understood. IF water contamination would occur, it won’t be from frac fluid coming up through thousands of feet of pressurized rock. It will have to be from leaks in the several strings of casing & cement that were either improperly installed or compromised during the completion process. Frac jobs are not designed to break up rock other than the rock of the oil & gas deposit. There isn’t enough horsepower available to produce the thousands of feet of fractures you may envision. HP cost money & no one wants to spend what they don’t have to spend to get their job done.
I misunderstood your reference to green completions..The promising part I was talking about are new mixtures of chemicals based on “friendlier fluids” (for lack of a better term) that will do what the original chemical was doing, whether it be gel the fluid to “hold” the sand longer, or a chemical to reduce the friction of the fluid to allow it to be pumped away at a lower pressure or kill the bugs that are found in the fluids used, etc. The air emission part we have found, because the EPA has required us to test for it, we were abiding by those requirements already. I believe, at least in most cases, the EPA may have over estimated the amount of hydrocarbons actually released into the air but, these regs will hopefully, help determine if that proves true or not.
No frac fluid, diesel or otherwise, travels “down thru the water layer”. It is pumped down the wellbore through tubing & displaced into the oil & gas reservoir through perforations in the pipe across the interval. I wasn’t sure the technical aspects of the fracturing procedure were necessary since I am trying convey that is not the potential source of contamination. I must take exception to your attempt to discredit my understanding of the process & wonder where your expertise lies.
I am actually trying to become part of the solution. It’s tough when I have worked in the business for as long as I have, done everything asked of me to protect everything around me BUT, many people don’t seem to believe you know the business or aren’t qualified to talk about the business because it’s your business?? Confused? I agree, it’s very confusing. Who can discuss differences of opinion, educators & politicians?
I have a hard time believing you are sincere about trying to become part of the solution especially when you ask me questions like you did on this post http://www.texassharon.com/2012/08/17/several-oilfield-workers-killed-or-injured-this-week/
“It’s easy to use the word loophole..can you actually explain one of them? Not just the catch phrase names of the evil deeds but, actually explain what one of them is & why it’s considered a loophole?”
In one comment you claim you did not mean to be condescending then in the nest you continue to condescend.
As a longtime, regular reader of my blog you must know the answer to that. Just recently I addressed the RCRA loophole.
Because alternate energy production doesn’t produce thousands of jobs & I suggest that, I’m not sincere? Lost me there.
You guys are much more educated than I am on the reg’s you believe will solve the problems perceived . As an operator, I have never been or ever will be regulation free, as you want everyone to believe.
AGAIN, I was trying to address the subject of this blog string. That diesel isn’t the problem you seem to want it to be for several reasons mentioned. The actual source of any pollution to fresh water aquifers, that you may have found, is not from the frac. but wellbore integrity.
Comprehension can be improved with careful reading and even a second read.
The well known lack of wellbore intergrity that is meant for protection against contamination allows frack fluids to escape and pollute our water.
Think of it this way: If you use protection but the condom breaks, you are still the daddy.
Andy Mechling says
My expertise lies in the field of air pollution monitoring. Specifically, I have significant expertise with Open-Path FTIR monitors, and a strong operating knowledge of open-path systems, and air monitoring technique in general.
My understanding of fracking, and fluids used in the fracking process, is derived primarily from my own research, mostly into patent claims filed by outfits such as Mobil, Texaco, Shell, Halliburton, Baker Hughes, Exxon, Chevron, Unocal, and etc.
As such, my understanding of the fracking process is largely academic in nature. I am fully aware that there are aspects of this process that have not been fully disclosed; and/or that I do not understand fully, If you are an operator, I am certain that you know more about the process than I do; and I very much appreciate your continued input here.
My exception with your previous statements has to do with rheology. My point is that diesel fuels, if used, will need serious modifications with additives to address the problems posed by their notable lack of Density, or Specific Gravity.
OK, so fracking fluids are “pumped down the wellbore through tubing & displaced into the oil & gas reservoir through perforations in the pipe across the interval.” I believe you. My assertion is that these liquids still need to be heavier than water. Otherwise, they will float right back up to the surface of whatever water is present, and potentially lose that “close contact” with the rock which is so desirable.
Specifically, my assertion is that ALL of these fluids are heavier than water. This is true whether we are talking about drilling muds, friction reducers, corrosion inhibitors, or the gel mixtures with suspended sand. I have yet to find any of these commercial products which discloses Specific Gravity of less than 1.0 Please correct me if I’m wrong – and include examples.
I hold bachelors degrees in History and Communications. I do not have any type of formal scientific credential. Everything I have learned in this field, I’ve had to learn the hard way.
My first foray into air toxics monitoring came as my family and I were repeatedly driven from our home in California – eventually to the point where we were forced to default on that home – by a series of criminal, and sometimes intentional, toxic releases from a nearby industrial neighbor. Yes I can’t talk about this in any detail. Yes I signed extensive non-disclosure documents related to the settlement of legal action.
Since that time, I have done contract work involving Open-Path monitoring projects with US EPA, and US DOD, among other clients. I take my work seriously. I will no longer perform work for personal injury attorneys. I will never again enter into confidentiality agreements of the type which might prevent me from freely sharing the results of my work with potentially affected citizens.
I’m sure you can understand this part.
Trying to keep Politics out of Science can be a very difficult thing to do. This is true from your side, and its true from this side as well, unfortunately.
When it started for me, I was just another pissed-off dad trying to get some answers as to what my kids had just been exposed to. All we got from local regulators was platitudes and bullshit, and it was scary. When I started, I had a fire in my belly, and I wanted revenge in the worst way. I wanted to put that international corporation out of business. I freely admit this.
I am no longer that guy. Truth is all I’m after at this point. Advocacy and Science do not mix well. Somebody needs to do the science at this point. Someone needs to remain neutral.
But here’s the problem, and I’m going to cut right to the chase:
I don’t give a damn about your hydrocarbon emissions. Hydrocarbon emissions are not the problem, in my estimation. You wont hear me railing about Global Warming or the fate of Polar Bear cubs.
I worry about the Polar Bears, but I am far more concerned with the fate of human children residing in proximity to industrial operations. Specifically, I am gravely concerned about perceived ongoing and widespread human exposure to organic sulfur species in this country; and in this century.
And this is what my experiences have taught me. Carbon disulfide and carbonyl sulfide are the chemicals which keep being detected near NG activities. See the TITAN study. See the FWNGAQ study. See Kleinfelder. etc.
These are the very same chemicals which are added to fracking fluids in large volume, whether that occurs in the form of various refinery liquid “sweetening” wastes, or as CS2 precursors in the form of dithiocarbamate “salts” added to brine mixtures, or whether these chemicals are manufactured on-site specifically for use downhole.
The patent claims are explicit in this regard, and they date back more than 70 years. These are the chemicals that work downhole. Diesel mixed with enough CS2, will now sink past that water layer and achieve close contact with the rock. Or at least this was once true. Look it up.
In any case, these are the chemicals we keep detecting; and these are the chemicals we know that you are using. These substances are not only highly neuro-toxic and explosive; they also stink really really bad.
What I would like to see is a day in time when we can all speak about this subject like adults. Will you deny that your outfit is utilizing CS2 downhole? Please do. In writing here. If not, will you confirm it for us?
I didn’t think so, in either case.
Nick, I do appreciate you engaging me here. I do not aim to put you out of business. I emplore you to do some sampling -on your own- of the headspace above those fluids . . . . or on the other end . . . . get a downwind / downhill sample of some of those flowback emissions. Just for your own use. On the sly if need be. I think you will see why I am so concerned.
The only other question I have for you at this point is this: What the hell happened at Magna-Blend? What are we being asked to believe about that incident? Can you straighten me out on this as well?
Thank you again.
I understand your drive for a solution. I also understand the emissions from petroleum operations (now that we have run representative sampling tests on our operations) and have said many times, even on this blog, oil & gas development is not good around residential areas. The workers on location wear protective gear, when needed. That can not be good for the next door neighbor to a 20-30 stage frac job that can last a week.
I know nothing more than the frac companies will allow. They have patents on some of their fluids & I thought they were required to provide a list of those chemicals but, not necessarily the amounts or maybe vise versa if pollution is found? Patent law is not my expertise.
I only know what we have all read about the Magna Blend explosion. http://thescoopblog.dallasnews.com/2012/03/osha-issues-penalties-in-magna.html/
The oil business will be around for several more years until alternate sources can be developed. They need to do a better job considering the people they affect and how to deal with all of it. Drilling in town is not new but, at the scale of the Barnett under Dallas/Ft. Worth it has taken on a much more concentrated area affecting everyone there.
No one likes to admit it but, protecting the environment costs money. Until we can achieve several breakthroughs needed in the many alternate energy sources we will be using in the future, we need to understand the cost & get on with it, in my opinion.
According to the industry and even your own company, they have never polluted anything so they don’t have to tell anyone what chemicals they use.
Because the industry gets so many favors in the way of exemptions, tax breaks and incentives, it is crushing the alternative sources. They are the ones who need the exemptions, tax breaks and incentives NOT the fossil fuel industry. In Texas you can get a permit for a gas well in about 24 hours but it takes 6 months or more for a solar panel. That’s ridiculous.
I’ve said many times: I would be most happy if you could operate in a safe manner causing no harm to the environment or people because I can get royalty money. After all the mounting opposition, I have come to the conclusion that you can’t operate safely or you would be doing so.
It makes me angry because all people want is to be treated fairly. Instead you guys use counter insurgency and PSYOPS methods against us. I like that you admit there are problems but it’s not good enough. Your company has caused great harm and not made adequate restitution. Just do the right thing.
not my company.
are you sure we aren’t propping up any alternate energy companies with more than incentives?
You get royalty money already. The business has never been environmentally neutral. None are. Mounting opposition doesn’t make it fact, only important to operate prudently & to the best of our ability.
You confuse me with someone I do not know.
“not my company.” To what are you referring in that statement.
The Fossil Fuel industry gets far more in the way of incentives/corporate welfare, tax breaks and loopholes than alternate energy. Look it up.
Right now I advocate against my best financial interest. It would be nice to turn that around. I can’t morally do that with the kind of suffering your industry causes.
Do you really think I don’t know who you are?
Your statement: “According to the industry and even your own company, they have never polluted anything so they don’t have to tell anyone what chemicals they use.”…My company has never said this.
“Instead you guys use counter insurgency and PSYOPS methods against us….Your company has caused great harm and not made adequate restitution. Just do the right thing.”….Leads me to believe you don’t know who I am. We have not done harm or have any use of the methods you say I use?
Actually, you have. But, I won’t out you.
i am not in hiding. I would be surprised if you didn’t know who I was. Your comment below, that I can’t respond to (?), seems to accuse me & my company of some sort of pollution event. You may have made an incorrect assumption or connection. Please be more specific.
Andy Mechling says
I asked you directly if your outfit utilized carbon disulfide in downhole operations. Yes or No
And I openly expressed doubt that you would engage me on this subject.
You have responded, but you have once again dodged my question, except to say “I know nothing more than the frac companies will allow”.
Please understand that this is not good enough. On any level. Do you have kids Nick? I thought you were trying to convince us of how responsible you were. This doesn’t work.
I’d like to give you one more chance to answer a direct question.
Are you knowingly using carbon disulfide mixtures for the purposes of hydrocarbon recovery in your operations?
This is a Yes or No question Nick. Choose carefully.
I know of no fluid mixture that would be used in any of our downhole operations that would contain carbon disulfide.
From reading about the compound, I see that it can be formed from carbon & sulfur under high temperature. Many times oil & gas deposits contain hydrogen sulfide. I can envision, under the right conditions, it could be naturally formed in the reservoir.
There is also a lower temperature “creation path” which includes natural gas as the carbon source in the presence of silica gel or alumina catalyst. Silica is the major part of sand. Silica gel & aluminum are used in artificial proppants.
t sounds like the ingredients to produce your compound are either already in the reservoir fluid or might be formed by interaction with sand or proppants if the contact time, temp & press are sufficient but, it was not put into the fluid as an additive for any reason, that I am aware of.
I am not a chemist nor do I work for a completion company & do not know if any of the above could be true or not.
Five kids, four grandkids. How about you?
Andy Mechling says
Two kids in college.
I was encouraged to see your opening statement:
“I know of no fluid mixture that would be used in any of our downhole operations that would contain carbon disulfide.” Welcome News!
And all of this seems pretty incredible to me . . . as in, . . . not especially credible; but again, I am inclined to take a man at his word. And I found myself wondering how in the world could such a sharp oil company executive open himself up to potential future litigation like that . . . wow . . .?
and then I read all the way through to the part where you qualify by saying:
“II . . . do not know if any of the above could be true or not.”
That’s pretty slippery Nick; and pretty much the sort of thing we have come to expect from Indsutry PR. I had hoped for better, and don’t find this particularly helpful at all.
Please know Nick that if I make a statement here; it’s because it is true. Or at least, I believe it to be true. I stand ready to defend my claims, and in any event, will freely admit when I’ve been corrected. I think that’s how this is supposed to work. The rest of us here have been trying to adhere to a set of rules like this.
None of us comes here for pleasure reading. The Bluedaze isn’t a place to sample the latest in historical fiction or read poetry. This isn’t some sitcom where a team of writers scramble to come up with some new implausible story line for each new episode.
If you don’t know “if any of the above could be true or not” please don’t bother bringing it to this site next time.
Yes, there is plenty of organic sulfur underground, but even in the more sour deposits, not much of this will exist in the form of unbound carbon disulfide, according to EPA. 1974. H2S, Yes, You should know this. Now you do.
According to EPA, CS2 and COS present in refinery streams are formed primarily as unwanted byproducts of catalytic cracking or “coking” processes. Removing these two contaminants from various process streams and end products has been a major focus of the oil and gas industries, especially over the past decade. Billions and billions have been spent cleaning up these compounds specifically.
Coking itself is very much the order of the day. Oil Refiners who lack Coking capabilities – and cannot process the heavier sour crudes – are feeling a big pinch right now, and this has been widely reported. Billions and billions is being spent building Cokers. This means more and more CS2 is being generated.
It surprises me that you don’t know about this; or about the enormous difficulties surrounding the disposal of waste streams containing concentrated organic sulfur contaminants associated with these operations.
Sulfur emissions from oil and gas operations are also a real problem, as you must know. I assume you know that American gasoline is still far too contaminated with sulfur to allow either Mercedes or VW to include their newest, most fuel efficient gasoline engines in the cars they sell here.
These new motors are up to 10% more fuel efficient; but we cant get them at all. I think this is truly unfortunate. How about you?
I assume you have some opinion regarding the proposed tightening of sulfur limits for gasoline, recently postponed again by EPA, that would bring our gas closer in line with the cleaner standards European governments adopted several years ago. Yes, tighter sulfur standards will require billions in new investments. That’s jobs for you guys Nick.
American refineries are the envy of the world right now. Can we agree? All those billions and billions invested in cleanup have been paying off. This has been widely reported and discussed. Pressure from regulators brought the consent decrees which necessitated the investments . . . . and some of those billions got spent rather quietly. But those investments are paying off. This is my point Nick.
I assume you know that sulfur emissions are believed responsible for hundreds of thousands of premature deaths every year in this country. Coal is nasty. Agreed. Natual Gas burns cleaner. Agreed.
I encourage you to reconsider your opposition to EPAs proposed requirements for Green Completions for fracked gas wells. Until operators can adopt more responsible practices in the Gas patch; Natural Gas Production will remain Nasty.
But don’t ask me. I encourage you to ask the folks living in the gas patch how they might feel about proposed Green Completion techniques as alternatives to your current practices.
I personally think your industry would be smart to leap to accept the current proposal as written. You guys are getting an unbelievably sweet deal in my book.
John J. Carrol, with Gas Liquids Engineering Ltd. in Alberta, has written extensively about the disposal of sour liquid wastes through underground injection. I would like to recommend the following article to you:
DESIGN CONSIDERATIONS FOR ACID GAS INJECTION , is available on-line and was originally presented in Norman Oklahoma at the Laurance Reid Gas Conditioning Conference in 1999, This article provides an easy to grasp, yet detailed discussion of large scale disposal of sulfur-bearing liquid wastes through deep well injection projects.
In that 1999 article, Carrol warns against utilizing these same streams for EOR purposes, saying something to the effect of “the idea is to dispose of waste sulfur, not to recycle it”. As it turns out, he was close: the idea is to make money.
In some of his more recent work, Carrol acknowledges that the market for acid gas injection (& his own employment) was being driven by EOR activities, but makes plain his assertion that any operators utilizing these highly toxic organic sulfur solvent compounds as part of EOR operations need to be prepared to encounter elevated organic sulfur content in any oil and gas recovered at the wellhead.
I don’t have that citation right here handy, I could probably dig it up for you, but I think that reference was from abstract written in 2010 or so. In any case, the other reading I would like to direct you to are a series of recent patent documents, and pending patent applications by Shell Oil, including this one:
“PROCESS FOR THE MANUFACTURE OF CARBON DISULPHIDE AND USE OF A LIQUID STREAM COMPRISING CARBON DISULPHIDE FOR ENHANCED OIL RECOVERY” Carolus Matthias Anna Maria Mesters, Amersterdam et. al , Shell Oil Company, Houston TX. U.S. Patent 8097230 issued 1/17/2012.
Hopefully, a careful reading of these and related articles should give you a good basic idea as to how and why and where carbonyl sulfide and carbon disulfide are being used underground.
If you have any further questions for myself or the other Bluedaze contributors; Please know that we are always here to help.
Thank you Nick, once again for your prompt reply, and congratulations on the grandkids.
The not knowing if true is in reference to the pontifications of the creation of CS2. We do not pump CS2 in our wells.
I am unable to keep up with all things you discuss. My initial involvement was to suggest that diesel in frac fluid isn’t the problem. You may be confirming that suggestion by going off topic so often.
I am but a lowly engineer trying to do my best at finding and producing all things hydrocarbon, while handling the environmental impact to the best of my ability. It must not seem like that to you & your contributors. I apologize & will refrain from expressing any opinions or explanations on topics I thought I knew something about on this blog.
Feel free to comment anytime.
Andy Mechling says
Thanks for the clarification.
You and I are in agreement that diesel in the frac fluid is not the problem.
If I lived near one of your operations; diesel would be least of my concerns.
I’m still a little nervous about what happened over at Magnablend though. You’re not sourcing your frac fluids from that facility are you?
Diesel damn sure IS a problem. My friends ended up with some in their water well after fracking.
In this grand experiment called frackong there are many chemicals that are huge problems.
Andy Mechling says
Sharon you are right, of course.
But this has been my point; we have all been too willing to accept, and then to repeat, misleading oilfield terminology.
If they’re using diesel in their downhole operations, then they are using DIESEL FROM HELL, and I am trying to call them on it here on your blog,
There is no test for diesel in water because there is no test for diesel. I haven’t seen your friends water well results, but my guess is they’ve got diesel-range components showing up in the lab results.
Let me guess: benzenes, toluene, all the xylenes, pentanes, carbon disulfide, long and short chain hydrocarbons, etc. I do not mean to imply that I want any of that stuff in my drinking water. I do not want any of that in my water. I just don’t call this diesel, that’s all.
Unless EPA bans the components that make up diesel, there will be no realistic way to ban “diesel”. This is the point I have been trying to make.
We can test for xylene. We can test for carbon disulfide, We can test for vinyl chloride. We can’t test for diesel. Why should we continue to play their game?
What good is banning diesel going to do if we don’t ban the ingredients?
I totally get your point. But, IJS we don’t need any of that shit in our water!
My friends has MTBE in their water. MTBE is a diesel additive. All that crap needs to be banned. If they can’t get gas out of the shale without poisoning us, they need to go on to something else.
It would be great if there was something else. The reality will be “someplace else” for “their needs”. This will also need to go on for “a bit” longer before any alternate could even begin replacing fossil fuels.
If we didn’t need the energy source why is it so economic to extract?
If it is regulated/taxed/outlawed/ whatever, THEN alternates will become more economic BUT, the price of that “economic” alternate will be unaffordable by the very people that can’t afford the increase in the first place.
Seems to me spending more time & money on alternate energy research & development AND working to make the oil industry less intrusive & more responsible for changes would be our best plan.
When you say: “This will also need to go on for “a bit” longer before any alternate could even begin replacing fossil fuels.
I hear: We need to continue contaminating water and air and ruining family well-being.
If your industry would truly admit responsibility and make the victims whole you would have much less resistance. Instead you externalize your costs and pass them on to us.
This doesn’t work: “working to make the oil industry less intrusive & more responsible for changes would be our best plan.”
Because your industry spends billions lobbying and schmoozing with our lawmakers and trying to intimidate people like me.
On this post http://www.texassharon.com/2012/09/02/energy-in-depth-messed-with-the-wrong-goat-farmer/ I said this:
“The fracking mafia is spending billions on lobbying, propaganda, advertising campaigns, harassment, and intimidation to “whack” an opposition that would not exist if they could operate in a more responsible manner. Since it would be much cheaper to operate responsibly, the only conclusion I can draw is that responsible fracking is not possible.”
That is the cold, hard reality.
The reality is that we have committed ourselves to fossil fuels & it won’t be easy to kick it that addiction.