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CONCLUSION 391
The study will examine the full cycle of water in hydraulic chemicals used in fracking, which the regulations would
fracturing, from the acquisition of the water, through the not require.
mixing of chemicals and actual fracturing, to the postfractur- In the last draft of the rules, the BLM required companies
ing stage, including its ultimate treatment and disposal. EPA to test the integrity and strength of each well bore to ensure
has selected locations for five retrospective and two prospec- they do not leak fracking chemicals and hydrocarbons—and
tive case studies. Separately, EPA will develop the first submit those results to the agency for review—before the
national standards for wastewater produced along with well could be fracked. Under the new rules, companies can
natural gas. It said any water pretreatment standards would avoid obtaining or submitting this information for wells if
be based on economically achievable technologies. A draft they are similar to one that has been shown to have a strong
report will be released in late 2014. enough cement job. Companies do not have to submit this
On May 13, 2014, EPA posted on its web site a prepub- information until after fracking has occurred. In the last draft
lication version of an Advanced Notice of Proposed of the rules, the BLM required companies to test the integ-
Rulemaking (ANPRM) to regulate chemicals used in rity and strength of each well bore to ensure they do not leak
hydraulic fracturing under Sections 8(a) and 8(d) of the fracking chemicals and hydrocarbons—and submit those
Toxic Substances Control Act. This ANPRM does not pro- results to the agency for review—before the well could be
pose any actual regulation at present but instead seeks fracked. The new rule still requires companies to disclose the
“comment on the information that should be reported or chemical composition of their fracking fluids after the well
disclosed for hydraulic fracturing chemical substances and is fracked. Now, though, it allows them to do it through
mixtures and the mechanism for obtaining this information” FracFocus.org.
from the public and interested parties. EPA also indicates it The American Petroleum Institute (API), oil and gas
is considering whether to require such reporting through trade group, has developed a series of shale development
regulatory action under TSCA authority, to implement a guidance documents that encompass well integrity and
voluntary program, or to have a combination of both. The production operations. Historically, API standards have
ANPRM asks for comments within 90 days of publication been integrated into state regulatory frameworks. Such an
in the Federal Register. This time frame appears somewhat approach benefits all parties in shale gas production: regula-
limited given the broad scope of questions on which EPA tors will have more complete and accurate information;
has requested comments. Operators, well services com- industry will achieve more efficient operations; and the
panies, and chemical manufacturers may all be subject to public will see continuous, measurable improvement in
portions of any new rule that results from this process. shale gas activities. The Interstate Oil and Gas Compact
The U.S. Department of the Interior (DOI, 2013) has Commission, the Marcellus Shale Coalition, the State
been working on fracturing regulations for the 3400 wells Review of Oil and Natural Gas Environmental Regulation
drilled every year on public lands, 90% of which use frack- (STRONGER), the Groundwater Protection Council, and
ing and horizontal drilling. The draft rules focus on the dis- the Intermountain Oil and Gas Project are all working to
closure of chemical identities, well‐bore integrity, and identify best practices.
management of wastewater disposal. On May 4, 2012, the
Bureau of Land management (BLM) issued the proposed
rule for oil and gas on public lands that will for the first time 18.12 CONCLUSION
require disclosure of the chemicals used in the process (DOI/
BLM, 2012). Companies will have to reveal the composition No energy is produced without risk and without some envi-
of fluids only after they have completed drilling—a sharp ronmental cost. The extraction, processing, and transporta-
change from the government’s original proposal, which tion of natural gas all affect the environment. However,
would have required disclosure of the chemicals 30 days expansion of the supply of natural gas permits the displace-
before a well could be started. The draft rule affects drilling ment of more polluting forms of energy. With the shale gas
operations on the 700 million acres of public land adminis- boom continuing to gather steam, hydraulic fracturing will
tered by BLM. likely remain a focus for environmental and citizen groups
On May 25, 2013, the Bureau of Land Management concerned about its potential environmental impacts. Since
(BLM) issued new draft regulations (DOI/BLM, 2013). October 2010, more than 100 bills across 19 states have
Environmental groups say the new draft provides weaker been introduced relating to hydraulic fracturing for natural
water protections than a version DOI proposed a year earlier, gas. The most active states include New York and
while oil industry groups said they wanted regulation left in Pennsylvania. This explosion of recent attention is largely
the hands of states and were opposed to any federal rules. attributed to fracking in regions where it is not as familiar to
Environmentalists expressed disappointment that the regula- the affected communities, such as in the Marcellus Shale
tions do not include a ban on the storage of waste fluids in region. The most prominent recent trend in state legislation
open, lined pits. They also wanted complete disclosure of is an attempt to require chemical disclosure, along with