Water Withdrawals for Hydrofracing

Estimates of Amounts of Water Withdrawals for Hydrofracing

It has been difficult to get a precise value for the amount of water that will be used per well in hydrofracing the Marcellus Shale. This may because the amount of water required may differ with site; the amount may differ as hydrofracers gain more experience with the Marcellus shale; and/or government agencies either do not collect or report this information. Water required for hydrofracing shales in other regions of the US appears to be in the range of 3 to 9 M gallons per well, with 3 M gallons probably being closer to the average (Jim Williams, USGS). In a tight shale such as the Marcellus, it appears that hydrofracing is required to initiate an economic flow of gas and so is employed shortly after the well is drilled. In other formations, hydrofracing may be used more than once, as gas flow initially peaks and then gradually declines after hydrofracing. Water withdrawals for hydrofracing need to be understood in the context of other water withdrawals. Estimated water withdrawals for the Great Lake States in the year 2000 for public water supplies was 10.2 billion gallons per day. Many people are unaware that in the United States, more water is withdrawn to cool power plants than for any other use. Year 2000 estimated water withdrawals to cool power plants in the Great Lake States was 53.7 billion gallons per day. (http://pubs.usgs.gov/fs/2008/3032/pdf/fs2008-3032.pdf). Water withdrawals in 2003 by the Bolton Point Southern Cayuga Lake Intermunicipal Water Commission (from Cayuga Lake) were 2.55 million gallons per day, by the City of Ithaca (from Six Mile Creek) 3.75 million gallons per day, and by Cornell University (from Fall Creek) 1.34 million gallons per day. (http://www.boltonpoint.org/PDFs/2005DWQR.pdf). Seen in this context, to hydrofrac a gas well would require the amount of water the City of Ithaca withdraws from Six Mile Creek in one day. A major concern in permitting gas wells is to assure that water for hydrofracing is withdrawn at a rate and location that will not disrupt other users and ecosystem services. The most appropriate locations for water withdrawals from the public’s perspective may incur substantial additional costs in hydrofracing, as there is an economic incentive, due to the cost of shipping water, to obtain water for hydrofracing as close to a drilling site as possible. There is concern about the cumulative impacts of water withdrawals for gas well drilling on a watershed or basin. For the Marcellus shale, the New York State recently enacted a law (http://assembly.state.ny.us/leg/?bn=A10526) establishing a spacing unit for a single well for horizontal drilling as 40 acres plus any acreage necessary to maintain a 330 foot setback (distance from property line to vertical or horizontal well). This implies a maximum number of wells of 16 per square mile. In addition, multiple wells for horizontal drilling can be established on 640 acres (which equals one square mile). The purpose of this larger spacing unit is to allow several vertical gas wells to be drilled from a central pad and expand out horizontally in different directions. It is unlikely that more than 8 wells per square mile would be established under these conditions. Given the potential density of gas wells needed to exploit the Marcellus shale, the likelihood that many of the wells will be located in upper reaches of watersheds, and the need for large quantities of water in a relatively short period of time, there is legitimate concern regarding the over exploitation of water, even if this impact is temporary.

Jurisdiction

Gas wells in the Marcellus shale in New York State will be primarily located in the Susquehanna and Delaware River Basins. Water withdrawals from both surface and groundwater in these basins are under the jurisdiction of interstate commissions. Both commissions have clearly established their authority to permit the use of any water in their basins for developing gas wells. Furthermore, they have identified cumulative impacts and impacts on water quality, in addition to local impacts on water supplies, as key concerns (see below). Marcellus shale extends into the Great Lakes Basin; water withdrawals in this basin are less tightly managed. However, under New York State law any person who withdraws more than 3 million gallons of surface or ground water during a consecutive 30-day period from the Great Lakes Basin is required to obtain a permit (http://www.dec.ny.gov/lands/25581.html). There are on-going disputes regarding water withdrawals from the Great Lakes, but the withdrawal of water for gas well drilling would be insignificant in the context of this debate. The issue of approval and regulation of water withdrawals for tight shale gas well drilling in the Great Lakes Basin should be addressed in the environmental review of gas well drilling that New York State is currently undertaking.

Susquehanna Basin Commission

“The Susquehanna River Basin Commission (SRBC) notified natural gas operators that as of October 15, 2008 any amount of water withdrawn or consumptively used to develop wells in the Marcellus, Utica or other shale formations in the Susquehanna watershed will require prior approval from SRBC. SRBC regulations – 18 CFR, Section 806.5 – allow its executive director to make a determination when water-use activities, regardless of the amount of water, have the potential to affect the water resources of the Susquehanna basin. “While this regulatory provision is certainly not new, it is the first time in the Commission’s 37- year history we are imposing it on a class of projects,” said SRBC Executive Director Paul Swartz. “After careful consultation with the commissioners and my technical and legal staff, I decided it would be prudent to impose the more stringent provision on the natural gas industry to give us the ability to review and regulate the industry’s individual and cumulative impacts on water resources.” In taking this action, Swartz determined the natural gas industry’s water-use activities could have an adverse, cumulative adverse or interstate effect on the water resources of the Susquehanna River Basin. The factors SRBC considered, as required by the regulations, included:

• quantity and rate of water usage
• location of water (ground and surface sources) for withdrawals and consumptive uses
• the potential to alter the physical, biological, chemical or hydrological characteristics of the basin’s water resources
• the potential to affect interstate water quality ( http://www.srbc.net/pubinfo/press/docs/ProjectRevNaturalGasDetermination81508.pdf )

Delaware Basin Commission (DRBC)

“In connection with natural gas drilling, the commission has identified three major areas of concern:

1. Gas drilling projects in the Marcellus Shale or other formations may have a substantial effect on the water resources of the basin by reducing the flow in streams and/or aquifers used to supply the significant amounts of fresh water needed in the natural gas mining process.
2. On-site drilling operations may potentially add, discharge or cause the release of pollutants into the ground water or surface water.
3. The recovered "frac water" must be treated and disposed of properly. In accordance with Section 3.8 of the Compact and Section 2.3.4.E of the DRBC's Rules of Practice and Procedure, a project sponsor may not commence any withdrawal of ground or surface water from the basin, drill any well, construct any impoundment or other associated appurtenances, discharge to the ground waters or surface waters of the basin or otherwise undertake a project until the sponsor has applied for and received approval from the commission.”