On July 7, 2021, the Center for Biological Diversity released a study on Gulf of Mexico oil and gas production that is misleading and flat out wrong. The report alleges that "pervasive and damaging offshore fracking and other extreme oil and gas extraction methods" occur in the Gulf of Mexico. The report and its findings, at best, show a complete misunderstanding of offshore production processes.
Offshore, the Bureau of Safety and Environmental Enforcement (BSEE) is responsible for approving well designs, drilling procedures, well completion plans and procedures and most aspects of production operations. Furthermore, the U.S. Environmental Protection Agency (EPA) holds responsibility for managing discharges from offshore facilities. Discharges are managed under the Clean Water Act and its National Pollutant Discharge Elimination System (NPDES) permit program.
The entire lifecycle of offshore oil and gas projects are subject to an interwoven blanket of statutes, permits, regulations and environmental studies and reviews.
The ability to discharge recovered fluids from Frac Pack operations - which is a the combination of hydraulic fracturing and gravel pack completion technologies - is an important logistical consideration. The NPDES permits issued by the EPA for the offshore oil and gas industry have strict discharge limits and monitoring requirements for many categories of discharges, including “well treatment fluids” and “produced water.” Well treatment fluids include fluids recovered from Frac Pack operations and produced water (natural formation water from the producing formation) can include produced water mixed with treatment fluids.
Permit limits applicable to these discharge categories include:
- Prohibition of discharges of listed priority pollutants (other than trace amounts),
- No free oil (no sheen),
- Daily maximum and monthly average limits on the oil content of the discharge,
- Discharge volume reporting, and
- Toxicity limit if the treatment fluid is mixed with produced water.
These performance based limits provide strict controls on the fluids that are discharged and ensure a sound, risk-based approach to protecting the environment.
If the recovered treatment fluid cannot meet the NPDES permit limits, this fluid would be captured, contained and sent to shore for disposal in deep injection wells that are permitted under the Safe Drinking Water Act and managed by the respective states where the injection would occur (authority delegated to the state once the state program is found to satisfy federal requirements). The injection wells are operated as Class II wells under the EPA’s Injection Control Program.
Class II wells are specifically designed to ensure protection of groundwater, isolation of injected fluids, are monitored to ensure the integrity of the well and the geologic formation into which the fluid is injected at all times, and to document the sources and volumes of fluids that are injected.
The claims and findings presented in the report do not reflect the an accurate reality of energy production in the U.S. Gulf of Mexico:
Claim: Gulf of Mexico oil and gas production has become "pervasive and damaging" due to offshore fracking and "other extreme oil and gas extraction methods" since 2010:
For starters, offshore fracking is quite different from onshore fracking from the rock types that are fractured to the objectives, volumes and extent of the fracking process.
Offshore fracking is limited to the near wellbore region typically a few feet up to a maximum of ~300 feet. The objective is to ensure a clean clear flowpath from the relatively soft formation to the wellbore, thus volumes are relatively limited.
Onshore fracking the objective is to increase the exposed surface area of the harder shale “reservoir” and ensure a clean clear flowpath to the well, areas well away from the wellbore up to thousands of feet are fracked and the volumes pumped are significantly greater.
Claim: Since 2010, offshore fracking and acidization of offshore wells have led to at least 66.3 million gallons of "fracking waste" dumped into the Gulf of Mexico.
To imply that waste offshore from completion operations from frac-n-pack operations to well acidizing is simply dumped offshore is wrong and dishonest. All produced fluids must meet rigorous NPDES and EPA standards for offshore disposal.
The entire offshore production process undergoes strict permitting from start to finish to ensure American energy is not produced in a way that harms workers or the environment. All produced fluids from offshore fracking – which is quite different than what occurs onshore – and well acidization must meet rigorous National Pollutant Discharge Elimination System (NPDES), which is managed under the Clean Water Act, and U.S. EPA standards for offshore disposal.
For applications that do not meet NPDES discharge requirements, the flow back fluids are captured and transported onshore for proper disposal. BSEE is also a constant presence throughout the lifecycle of a project, reviewing any well designs, drilling procedures, well completion plans and procedures, and most aspects of production operations.
The U.S. EPA covers the risks of chemicals through the identification of and requirements to monitor and prohibit the discharge of priority pollutants. As evidenced by production platforms that become home to marine ecosystems almost the moment they anchor, adherence to the NPDES works to ensure that chemicals do not pose a significant health risk to humans or marine life.
Claim: Chemicals used in offshore fracking and acidizing pose significant health risks to both humans and wildlife, including cancer, reproductive harm, neurotoxicity and even death.
The U.S. EPA covers the risks of chemicals through the identification of and requirements to monitor and prohibit the discharge of priority pollutants. As evidenced by production platforms that become home to marine ecosystems almost the moment they anchor, adherence to the NPDES works to ensure that chemicals do not pose a significant health risk to humans or marine life.
Louisiana would not be home to large scale commercial and recreational fishing industries if the U.S. offshore oil and gas industry was acting in the manner described by the Center for Biological Diversity.
Ask any Gulf Coast fisherman and they will tell you that oil and gas platforms are home to some of the best fishing you can find. This aspect is so beneficial to sea life that a rigs-to-reefs program has been supported by government and industry. Ecological synergy in the Gulf of Mexico could not happen without constant dedication to safety and environmental performance.
Claim: Offshore fracking has become a near daily occurrence over the past decade. Fracking, or hydraulic fracturing, blasts water and chemicals into the seafloor to fracture rock and release oil and gas. Acidizing injects hydrofluoric or hydrochloric acid to etch pathways in rock walls and release oil and natural gas.
The report gets the very processes it is describing wrong. Offshore well stimulation - loosely described as fracking in the faulty CBD document - is not executed close to the seafloor. During acidization, the last thing an engineer wants to do is “etch” any type of pathway into or along the rock walls. Such a practice actually tends to introduce or loosen other particles that plug the pathway of oil to the wellbore once the well is brought on production. Once acid is used in a wellbore the reaction of the acid with the formation and or sand pack produces spent acid that is neutralized and treated to NPDES standards prior to any potential discharge – industry does not discharge acid or any other materials that do not meet NPDES standards.
The report does not understand the actual science and engineering behind how U.S. offshore oil and gas is actually produced.
