Laying the Foundation
Regulatory compliance and operational efficiency are closely intertwined in the hydraulic fracturing industry, and frac pad liners are essential in meeting both goals. However, navigating complex regulations like these can be a distinct challenge. This chapter will review and summarize key federal requirements established by the Clean Water Act for environmental and safety compliance. The next chapter will explore state-by-state regulations in the three major US shale plays.
Federal Regulations: A Nationwide Framework
While specific state regulations often take center stage, fracking operations across the US are, first of all, bound by fundamental federal environmental laws. These laws provide a baseline for protecting natural resources and guiding energy development. Frac pad liner requirements, for example, are established by the Clean Water Act and the Safe Drinking Water Act.
Clean Water Act (CWA)
The CWA was established in 1972 to restore and maintain the chemical, physical, and biological integrity of the nation’s waters. It affects a broad range of industries, from agriculture to manufacturing to wastewater treatment and the energy sector.
In the context of fracking, the CWA is primarily concerned with preventing surface water and groundwater contamination. The Spill Prevention, Control, and Countermeasure (SPCC) rule is a critical component of the CWA. It requires facilities with a potential for oil spills, including fracking operations, to develop and implement SPCC plans: these plans detail procedures and measures to prevent spills from occurring and contain them if they do. As primary containment systems for fluids used in fracking, frac pad liners are a central focus of SPCC plans.
Safe Drinking Water Act (SDWA)
The SDWA, passed in 1974, focuses on protecting drinking water quality in the US. It established the Underground Injection Control (UIC) program as part of its effort to create and maintain nationwide drinking water standards. The UIC regulates underground fluid injections (including those used in fracking) to shield underground water sources from contamination. The UIC program spells out well construction, operation, and closure requirements, focusing on using liners to prevent fluids from migrating into underground aquifers.
Other Relevant Federal Regulations:
In addition to the CWA and SDWA, other federal agencies and regulations may also come into play. The Environmental Protection Agency (EPA) has the authority to regulate air emissions and hazardous waste generated from fracking operations. The Occupational Safety and Health Administration (OSHA) also sets standards for worker safety on frac pads, which can indirectly influence liner requirements related to safe handling and installation.
Tailoring Solutions for Regional Challenges
While federal regulations provide a foundational framework, remember that fracking operations don’t exist in a vacuum. Each region has unique geological, hydrological, and environmental characteristics influencing frac pad liner selection, installation, and management.
Texas (Permian Basin)
Arid Climate
The Permian Basin’s arid climate and intense sunlight can accelerate the degradation of certain geosynthetic materials. Liners with high UV resistance and durability should be selected to ensure reliable long-term performance. XR geomembranes, for example, are specifically engineered to withstand harsh environmental conditions.
Water Scarcity
Water resources are precious in West Texas, so it’s critical to prevent any possibility of groundwater contamination. Fracking operators are required to adhere to strict fluid management practices and employ liner systems with exceptional impermeability.
Soil Erosion
Loose sandy soils and the potential for wind erosion can jeopardize liner stability. Careful site preparation and, in some cases, the use of nonwoven geotextiles beneath the liner can help mitigate these risks.
North Dakota (Bakken Formation)
Clay-Rich Soils
The Bakken region often features expansive clay soils, which are prone to shrinking and swelling as moisture content changes. Since this movement can place stress on liner systems, site preparation and accommodation for soil properties must be a central focus to maintain liner integrity.
Extreme Temperatures
North Dakota experiences a wide range of temperatures, from scorching summers to frigid winters. Frac pad liners must be capable of withstanding these temperature fluctuations without becoming brittle or leaking.
Remote Locations
Many well sites in the Bakken Formation are located in remote areas, which can present logistical challenges for liner transportation and installation. Site operators should plan accordingly and select liner materials that are easy to transport and handle.
Pennsylvania (Marcellus Shale)
Abundant but Vulnerable Water Resources
While Pennsylvania boasts abundant surface water and groundwater resources, the region's hydrogeology features such intricately interconnected waterways that contamination in one area can spread through rivers, streams, and underground aquifers to affect a wider region. Accordingly, the state has enacted stringent regulations regarding water management, wastewater disposal, and spill prevention to protect water quality and vulnerable ecosystems.
Karst Topography
Parts of the Marcellus Shale region feature karst terrain characterized by caves, sinkholes, and underground streams. This geological feature can increase the risk of significant groundwater contamination if spills occur. Therefore, state regulations demand careful assessments of site conditions and robust primary and secondary containment systems.
Community Considerations
Population density is higher in many parts of the Marcellus Shale region compared to the Permian Basin or Bakken Formation. Accordingly, state regulations require operators to be mindful of community concerns and communicate transparently about their operations and environmental protection measures.
Industry Standards: Best Practices for Performance and Safety
While federal and state regulations set the minimum requirements, responsible operators often look to industry standards for best practices that bolster performance, safety, and environmental protection. The American Petroleum Institute (API) develops standards and recommended practices for the oil and gas industry, including those relevant to frac pad containment systems.
API’s Role in Frac Pad Liner Management
Material Selection
API standards can be used as a guide to select appropriate liner materials based on their chemical compatibility, puncture resistance, and long-term durability.
Installation Practices
The API provides detailed recommendations for liner installation, including subgrade preparation, liner deployment, seam welding techniques, and leak detection.
Environmental Protection
API standards emphasize the importance of environmental protection throughout the fracking process. These standards include guidance on spill prevention, fluid management, and site reclamation to minimize the impact on water resources, air quality, and surrounding ecosystems.
Safety
API prioritizes worker safety during all phases of fracking operations. Their standards include guidelines for the safe handling and installation of liner materials and procedures for managing potential hazards associated with chemicals and equipment.
What’s Next
Federal agencies are only the beginning of regulatory bodies governing fracking. Chapter 3 will examine specific state regulations enacted in the three largest US shale plays.
