The Virginia Oil and Gas Association (VOGA)[i] supports the role of the Virginia Department of Mines, Minerals and Energy (DMME) in regulating natural gas production in Virginia, including production methods involving hydraulic fracturing. Virginia’s regulations are among the toughest in the nation and for many years have been fully and consistently enforced by DMME for the protection and benefit of Virginia’s citizens and in a manner that has allowed the successful and safe production and development of this resource which is increasingly crucial in meeting the significant energy needs of the Commonwealth and our nation.
VOGA recognizes and respects the increasing public desire for transparency regarding the chemicals used in the hydraulic fracturing process. VOGA supports full disclosure of the chemicals used in hydraulic fracturing and therefore recommends that DMME adopt a requirement that all operators using a hydraulic fracturing process in Virginia be required to participate in FracFocus, the national hydraulic fracturing chemical registry.
FracFocus is a publicly available website created to provide public access to location specific information on chemicals used for hydraulic fracturing.[ii] To help users put this information into perspective, the site also provides objective information on hydraulic fracturing, the chemicals used, the purposes they serve and the means by which groundwater is protected. The primary purpose of this site is to provide factual information concerning hydraulic fracturing and groundwater protection.
FracFocus is managed by the Ground Water Protection Council and Interstate Oil and Gas Compact Commission, two organizations whose missions both revolve around conservation and environmental protection.
FracFocus is already used by ten states as a means of official state chemical disclosure: Colorado, Oklahoma, Louisiana, Texas, North Dakota, Montana, Mississippi, Utah, Ohio and Pennsylvania.
A requirement that Virginia operators participate in FracFocus will ensure the availability of information valuable to Virginia citizens and others without cost to the Commonwealth and without taxing the resources and staffing of DMME which can be better put to use in fulfilling its other regulatory responsibilities.
DMME has overseen the permitting and regulation of natural gas extraction in Virginia, including hydraulic fracturing processes, in a manner that has protected Virginia and its citizens while also promoting the economic benefits arising from the development of this valuable natural resource. DMME, in coordination with other state and Federal agencies, is uniquely qualified to regulate all aspects of the permitting and enforcement programs including hydraulic fracturing.
A requirement for operators to participate in FracFocus is entirely consistent with DMME’s ongoing efforts to ensure that best practices are incorporated into Virginia’s regulations, as has been its practice since the agency was formed. VOGA supports such a requirement.
[i] The Virginia Oil and Gas Association is a non-profit trade association representing the interests of companies, partnerships, individuals and other entities having an interest in the oil and gas industry and who are primarily engaged in the exploration, production, development, transportation and distribution of natural gas and oil in Virginia. These clean, dependable, affordable and domestic energy resources are vitally important to our nation’s energy independence and economy. The Virginia Oil and Gas Association supports and encourages the development of these resources in a safe and environmentally sound manner and its member companies daily demonstrate the ability to do so.
[ii] FracFocus contains the following information as to each reported hydraulic fracturing site:
1. Fracture date: This is the date on which the fracturing associated with the record occurred.
2. State: The name of the state in which the surface location of the well is located.
3. County: The name of the county within the state.
4. API Number: This number is assigned under a system developed by the American Petroleum Institute. API numbers are formatted as nn-nnn-nnnnn-nn-nn with the first 2 numbers designating the state, the second 3 numbers designating the county within the state and the next 5 numbers designating the particular well within the county. When present, the next 2 numbers are a directional sidetrack code to designate the number of horizontal or directional offshoots from a single vertical borehole and the final 2 numbers are an event sequence code used to designate multiple activities conducted at a single well such as recompletion, treatment etc… (A list of the state and county codes can be found at http://www.spwla.org/technical/api-codes) ‡
5. Operator Name: This is the name of the company.
6. Well Name: This is typically the name of the property owner on whose land the well is located. In the case of multiple property owners pooled under a single unit, the name of the majority property owner is often used. The number on the well may designate the chronological sequence of wells drilled. (Example: The Smith #2 might designate the second well drilled on the Smith lease). However, this is not a universal naming convention.
7. Longitude: This the east-west coordinate location of the well on the earth in degrees, minutes and seconds.
8. Latitude: This is the north-south coordinate location of the well on the earth in degrees, minutes and seconds.
9. Latitude/ Longitude Projection: This is the particular projection method for the Latitude/ Longitude (e.g. North American Datum (NAD) 27 or 83).
10. True Vertical Depth: This is the absolute depth of the well measured from the surface to the deepest point of penetration.
11. Total Water Volume: This is the total amount of water in gallons used as the carrier fluid for the hydraulic fracturing job. It may include recycled water and newly acquired water.
12. Production Type: This designates the well type (e.g. Oil, Gas) In addition to the general information shown above, each record contains information about the specific chemicals used during the fracturing process.
The following is a list of the chemical information shown on the fracturing record:
1. Trade Name: This is the name of the product designated by the supplier.
2. Supplier: This is the name of the service company that supplied the product (e.g. Schlumberger, Halliburton).
3. Purpose: This is the function served by the additive (Trade Name) in the fracturing process (e.g. surfactant, biocide etc…).
4. Ingredients: This is the scientific name of the chemical (e.g. Ethanol, Naphthalene etc…)
5. Chemical Abstract Service ‡ or CAS Number: This is a number assigned by a division of the American Chemical Society for the purpose of identifying a specific substance. You can learn more about the toxicity characteristics of chemicals by searching for the chemical using the name or CAS number on the USEPA National Center for Computational Toxicology ‡ website. USEPA also maintains a Drinking Water Hotline that is available Monday-Friday from 8:30 AM-4:30 PM Eastern time at 1-800-426-4791.
6. Ingredient Percentage in Additive by % Mass: This describes the amount of ingredient within the additive (Trade Name) as a percent of the total mass of the additive7. Ingredient Concentration in HF (Hydraulic fracturing) fluid % by mass: This describes the amount of ingredient as a percent of the total mass of the HF fluid including carrier fluid and additives.
7. Ingredient Concentration in HF (Hydraulic fracturing) fluid % by mass: This describes the amount of ingredient as a percent of the total mass of the HF fluid including carrier fluid and additives.
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