Improving the Regulation of Fracking Wastewater Disposal in BC

Report Recommendations and Response

RECOMMENDATION RESPONSE
B.C. should adopt the Natural Resources Defense Council recommendations for fracking wastewater disposal wells. B.C. disposal wells should be required to meet the U.S. Environmental Protection Agency’s guidelines for Class I hazardous waste wells.
  • The U.S. does not require its own oil and gas industry to meet this standard.
  • B.C. disposal well requirements have become very rigorous.
Summary of Best Practices Rules: B.C. should require operators to reduce, reuse, and recycle wastewater; minimize their use of chemical additives; create “project-specific water-management plans”; and refrain from using water sources that are already experiencing stress.
  • B.C. is already doing this – industry is actively encouraged to reduce its freshwater use and to recycle where possible.
  • B.C. also restricts the use of water for hydraulic fracturing during times of drought.
  • Industry is utilizing integrated water management plans, recognized as a highly important development consideration, examples - water flow lines for both delivery and flowback that reduces trucking, stated goals to re-use 100 per cent of flowback water, use of city of Dawson Creek wastewater.
  • The industry Montney Water Group pro-actively shares flowback water for recycle use by other companies, reducing disposal.
Summary of Best Practices Rules: B.C. should conduct a strategic environmental assessment to assess the cumulative impacts of fracking and disposal well activities in northeastern B.C.
B.C. must consider the cumulative impacts of fracking and injection activity to ensure improperly sited wells do not cause earthquakes, and to reduce the chances of a changing underground environment opening up new pathways for wastewater to make its way to the surface. See the Environmental Law Centre’s report on the need for a Strategic Environmental Assessment of the proposed new Liquefied Natural Gas industry at www.elc.uvic.ca.
  • B.C. has looked at projections for increased industry activity and has determined there are adequate water supplies and disposal capacity being developed.
  • B.C. has done significant research on induced seismicity and has made improvements to increase the number of seismic monitoring stations, and has requirements to shut down operations if such activity reaches a certain threshold.
Summary of Best Practices Rules: B.C. should require operators to carry out a site-specific risk assessment that examines underground and surface in a sufficient radius around the well, taking into account an appropriate timeframe. Operators should be required to submit this information as part of the permitting application. If there is a chance the well will allow fluids to migrate to the surface or induce seismicity, permitting authorities should be required to refuse the permit.
  • B.C. already has such requirements and the Commission does refuse permits that don’t meet our strict regulatory requirements.
  • Wells within a minimum of a 5km radius from a disposal well are examined for adequate integrity as part of the review process.
  • Detailed geologic mapping and analysis of the disposal and overlying formations is part of the application and review process, to ensure competent storage.
  • The risk of induced seismicity is part of the application review process.
Summary of Best Practices Rules: B.C. should require operators to ensure best practice in well design and construction, systematically verify the integrity of the well and quality of the seal, and have this integrity testing evaluated by an independent, qualified third party.
  • B.C. does this and the information is verified by certified professional engineers and geologists, first by the company making the application and operating the well, then independently at the Commission.
Summary of Best Practices Rules: B.C. should require comprehensive baseline testing of surface and
groundwater, soil, and seismic activity near the well prior to operation; this monitoring should continue to take place throughout the life of the well.
  • B.C. does monitor a disposal well throughout its active life.
Summary of Best Practices Rules: B.C. should ensure a robust monitoring and compliance regime exists, along with adequate emergency response plans. An appropriate way for B.C. to ensure robust monitoring and compliance efforts for disposal wells would be to give affected First Nations and other affected communities adequate resources to hire staff to conduct baseline testing; provide monitoring and compliance services throughout the lifetime of the well to ensure wastewater does not adversely impact the environment or public health; and develop, in conjunction with industry, adequate emergency response plans and procedures that give First Nations and other affected communities adequate notice of spills and leaks.
  • B.C. has a robust monitoring and compliance regime. This includes a team of almost 20 inspectors who carry out more than 4,000 inspections annually.
  • Emergency Response Plans are required for all oil and gas operations in the province.
  • The Commission has a program in place with First Nations to work alongside our staff.
  • Communities are contacted anytime there is a spill or leak through the Commission’s 24/7 emergency response system.
  • Disposal well approvals include a requirement for continuous wellbore pressure measurement and recording, the first indicator if there is a potential of loss of injection containment, which requires the well to be immediately shut-in.