From: Paul Edmiston
Sent: Wednesday, March 06, 2013 10:26:29 AM
To: Matthews, Lisa
Subject: RE: Additional Info for Analytical Chemical Methods Technical Workshop?
Lisa,

Please add the following to the record.  Thank you and good luck with the rest of your study.

-Paul


Above ground management of flow back water and produced water resulting hydraulic fracturing should be of great concern to the EPA.  Contamination of surface or groundwater by fluids mismanagement has been documented in all states where hydraulic fracturing has occurred. The large volume of water that must managed at the surface means there is the possibility that fluids associated with fracturing operations can enter the environment via spills or intentional discharge of fluids. For an example, intentional dumping into surface water has been documented by the EPA in Ohio as recently as February 2013. Therefore, it is encouraged that the EPA monitor surface waters for fracturing chemicals especially near pads and operational centers. Grab sampling and passive sampling would be useful and should include baseline measurements to establish proof of impact. 

Identifying chemicals that are unique to fracturing operations is key to establishing impact by exploration and production activities. Based on my analysis of flow back water organic chemicals such as 2-butoxyethanol and related alcohols in addition to quaternary amines would be useful as these chemicals are used as solvents as additives. BTEX compounds are less abundant and are typical of either produced water unless hydrocarbons (ex. diesel) is added to the fracturing fluid. Polymers are used widely, but it can be harder to develop methods to identify such macromolecules. The best approach, due to changing compositions, is to have a set of indicators such as those mentioned above combine with a broad analysis of organics and salts. I would suggest sampling and detection methods that can capture and identify a range of semi-volatiles and cations. Development of an analysis group with expertise in fracturing fluids and possess flexibility to conduct a suite of analyses would be useful. 

Although operators are doing excellent work recycling both flow back and produced water, care must taken to ensure proper transportation and disposal. Monitoring these activities would be important for environmental protection and should be accomplished with at least equal vigor than exploring whether there is connectivity between formation shale and groundwater aquifers.  [Submitted by Paul L. Edmiston, College of Wootser]




>>> "Matthews, Lisa" <Matthews.Lisa@epa.gov> 03/05/13 8:38 AM >>>
You can send it to me, and we'll add it to the docket for request for information for the study. Thank you.

Lisa Matthews
US EPA Office of Research and Development
202-564-6669 (ph)
202-577-4035 (BBerry)
matthews.lisa@epa.gov



-----Original Message-----
From: Paul L. Edmiston [mailto:pedmiston@wooster.edu] 
Sent: Monday, March 04, 2013 9:14 PM
To: Matthews, Lisa
Subject: Additional Info for Analytical Chemical Methods Technical Workshop?

Lisa,

Thank you for the invitation to attend the workshop. How would it be possible to provide additional comments and information to the workshop record? 

I have been provided flow back water samples by the operators and have received "coke bottle samples" from citizens in the midwest as well as official samples from the DOE. I have a unique perspective into what it is in flow back water. I was reluctant to state what to "look for" due to NDAs with the operators.

After careful consideration, I have determined what I can officially state that will be useful to the EPA.

Thank you for any guidance you can provide.

Best,
Paul Edmiston

