Environmentally Conscious Products and Services - Amazon Web ...
Environmentally Conscious Products and Services
In this Presentation, We Will Cover: • Public Perception of Hydraulic Fracturing and Chemicals Used • Product Stewardship/Product Standards
• Tools to Be Proactive in Public Relations • Status of Disclosure
Overview on Misconceptions • Along with having to worry about horsepower, proppants and additives, operators now have to be aware of public perception
• Public Perception is: – Chemicals are the main component being pumped downhole during a frac – The Industry isn’t proactive regarding safety and the environment
The Facts • Chemical only accounts for 0.5% of fluids pumped downhole
• Industry is already working with service companies and regulators to be proactive
What Industry is Doing to be Proactive • Implementing internal processes
• Partnering with service companies to implement processes and programs • Partnering with regulators and agencies • Partnering with communities
Processes to be Proactive • Requires a Partner Approach vs. Supplier – Operator involved in process and product selection
• Implementing Product Stewardship Programs – product selection and product evaluation process
Processes to be Proactive Through the NaturaLine Program, Operators can utilize the following: – Product Stewardship – NaturaLine Standards – Regulatory, Community and Media Relations
Product Stewardship Product Stewardship Offers the following for Operators: – – – –
Product Standards and Evaluations Tangible/Regulatory Based Data Transparent Due Diligence Informed and Calculated Product Selection based upon: • Product technical performance • Environmental aspects • Supplier expertise, safety and service
Frac Product Standards • What is “Environmentally Friendly” or “Green”?:
• U.S. EPA guidance: “The Twelve Principles of Green Chemistry” – Providing safer chemicals and products – Using chemicals that degrade after use – Minimize the potential for accidents
Frac Product Standards • Goals of Product Standards: – Closely meet 12 EPA standards for the definition of “Green” – Utilize universal, well known and measurable criteria – Set ratings based upon regulatory definitions of Excellent, Good, Fair, Poor (i.e. – North Sea CEFAS, USDOT and OSHA) – Provide ability to rank and compare through simple scoring
Environmentally Conscious Products
Definitions: • Toxicity – Human Health-Based – Environmental
• Biodegradability – Capability to be broken down
• Bioaccumulation – Capability to accumulate in living things
Regulatory Relations • • • • •
Partner to provide transparent data to regulators Present Product Evaluations/ Benefits Proactively discuss strategy with regulators The more we provide, the more they trust EPA Best Available Control Technology (BACT) Analogy: – Air Regulatory Required Analysis based upon effectiveness, cost and environmental aspects – Same theory for product selection
Community and Media Relations • Together, we can evaluate media goals, needs and perspective: – Provide technical data – Provide Product Stewardship Program
• Written communications, press releases and community meetings • Verbal communications - training
DISCLOSURE - STATE REQUIREMENTS • Mandatory in four states currently – – – –
Wyoming Arkansas Pennsylvania Montana
• Texas is finalizing disclosure rules and program – Will require operators to submit chemical information to FracFocus – Comment period open until noon on Oct 11 th – Draft final rule to presented to the commissioners which incorporates recent public comment
OPERATOR REQUIREMENTS
• Full compliance with mandatory reporting schemes – Provide appropriate usage reports and data in timely fashion
• Voluntary reporting as requested – Proactive companies reporting in Texas prior to final rule implementation data – Some operators requiring more information than required • Trade secret disclosures without regulatory protections
TRADE SECRET PROTECTIONS •
Wyoming – Can be submitted by chemical companies or operators – Must be approved by Attorney General and only with sufficient justification – Will be released to emergency responders or state officials in case of emergency
•
Arkansas – – – –
•
Must be submitted through Form 37 Approved by Oil and Gas Commissioner with sufficient justification Specific criteria for approval Information must be released to the state in case of emergency
Pennsylvania – Follow OSHA confidential business information rules
•
Montana – Trade secrets allowed without prior approval – Must be disclosed under emergency conditions
•
Texas – – – –
Process currently unclear Trade secret must be submitted to Texas Attorney General and approved before use Allowance for qualified persons to challenge trade secret status Must be sufficiently substantiated with specific criteria
FRACFOCUS REPORTING TOOL • Streamlined method for reporting chemical data to public and state • Requires the following information – – – – – – –
Trade Name of Chemical Supplier Name Purpose of Use Chemical Names of Ingredients Chemical Abstract Number (CAS Number) Maximum Ingredient Concentration in Additive Maximum Ingredient Concentration in Total Fluid
• FracFocus reporting limits operator responsibility to MSDS/OSHA disclosed information only – Trade Secret Allowance – Reporting of “Non-Hazardous” chemicals is not mandatory
FUTURE PATHWAYS • States likely to develop regulations similar to current state regs – New York regulation open-ended and could be modified at any time to require more detailed reporting – Pennsylvania has proposed bill to modify and strengthen current requirements for more public disclosure – Colorado regulators planning draft chemical disclosure regulations sometime this fall – Louisiana has proposed regulation for disclosure (Oct effective date expected) – Michigan requiring MSDS be provided for high volume frac chemicals – California regulations stalled, but likely to be revisited in 2012
• FracFocus to be main information cataloging system • Call for information on poorly understood chemicals • International Implications – Canada regulations – EU Activities to correspond with REACH
Main Points to Remember: • Our industry is being proactive to correct the misconceptions of the public • Partner with service companies to provide necessary tools to work within your communities and with regulators • Ask your partners for metrics and standards to define “environmentally friendly” and “safer” so that you can use them to enhance your operations
THANK YOU FOR JOINING US!
In this Presentation, We Will Cover: • Public Perception of Hydraulic Fracturing and Chemicals Used • Product Stewardship/Product Standards
• Tools to Be Proactive in Public Relations • Status of Disclosure
Overview on Misconceptions • Along with having to worry about horsepower, proppants and additives, operators now have to be aware of public perception
• Public Perception is: – Chemicals are the main component being pumped downhole during a frac – The Industry isn’t proactive regarding safety and the environment
The Facts • Chemical only accounts for 0.5% of fluids pumped downhole
• Industry is already working with service companies and regulators to be proactive
What Industry is Doing to be Proactive • Implementing internal processes
• Partnering with service companies to implement processes and programs • Partnering with regulators and agencies • Partnering with communities
Processes to be Proactive • Requires a Partner Approach vs. Supplier – Operator involved in process and product selection
• Implementing Product Stewardship Programs – product selection and product evaluation process
Processes to be Proactive Through the NaturaLine Program, Operators can utilize the following: – Product Stewardship – NaturaLine Standards – Regulatory, Community and Media Relations
Product Stewardship Product Stewardship Offers the following for Operators: – – – –
Product Standards and Evaluations Tangible/Regulatory Based Data Transparent Due Diligence Informed and Calculated Product Selection based upon: • Product technical performance • Environmental aspects • Supplier expertise, safety and service
Frac Product Standards • What is “Environmentally Friendly” or “Green”?:
• U.S. EPA guidance: “The Twelve Principles of Green Chemistry” – Providing safer chemicals and products – Using chemicals that degrade after use – Minimize the potential for accidents
Frac Product Standards • Goals of Product Standards: – Closely meet 12 EPA standards for the definition of “Green” – Utilize universal, well known and measurable criteria – Set ratings based upon regulatory definitions of Excellent, Good, Fair, Poor (i.e. – North Sea CEFAS, USDOT and OSHA) – Provide ability to rank and compare through simple scoring
Environmentally Conscious Products
Definitions: • Toxicity – Human Health-Based – Environmental
• Biodegradability – Capability to be broken down
• Bioaccumulation – Capability to accumulate in living things
Regulatory Relations • • • • •
Partner to provide transparent data to regulators Present Product Evaluations/ Benefits Proactively discuss strategy with regulators The more we provide, the more they trust EPA Best Available Control Technology (BACT) Analogy: – Air Regulatory Required Analysis based upon effectiveness, cost and environmental aspects – Same theory for product selection
Community and Media Relations • Together, we can evaluate media goals, needs and perspective: – Provide technical data – Provide Product Stewardship Program
• Written communications, press releases and community meetings • Verbal communications - training
DISCLOSURE - STATE REQUIREMENTS • Mandatory in four states currently – – – –
Wyoming Arkansas Pennsylvania Montana
• Texas is finalizing disclosure rules and program – Will require operators to submit chemical information to FracFocus – Comment period open until noon on Oct 11 th – Draft final rule to presented to the commissioners which incorporates recent public comment
OPERATOR REQUIREMENTS
• Full compliance with mandatory reporting schemes – Provide appropriate usage reports and data in timely fashion
• Voluntary reporting as requested – Proactive companies reporting in Texas prior to final rule implementation data – Some operators requiring more information than required • Trade secret disclosures without regulatory protections
TRADE SECRET PROTECTIONS •
Wyoming – Can be submitted by chemical companies or operators – Must be approved by Attorney General and only with sufficient justification – Will be released to emergency responders or state officials in case of emergency
•
Arkansas – – – –
•
Must be submitted through Form 37 Approved by Oil and Gas Commissioner with sufficient justification Specific criteria for approval Information must be released to the state in case of emergency
Pennsylvania – Follow OSHA confidential business information rules
•
Montana – Trade secrets allowed without prior approval – Must be disclosed under emergency conditions
•
Texas – – – –
Process currently unclear Trade secret must be submitted to Texas Attorney General and approved before use Allowance for qualified persons to challenge trade secret status Must be sufficiently substantiated with specific criteria
FRACFOCUS REPORTING TOOL • Streamlined method for reporting chemical data to public and state • Requires the following information – – – – – – –
Trade Name of Chemical Supplier Name Purpose of Use Chemical Names of Ingredients Chemical Abstract Number (CAS Number) Maximum Ingredient Concentration in Additive Maximum Ingredient Concentration in Total Fluid
• FracFocus reporting limits operator responsibility to MSDS/OSHA disclosed information only – Trade Secret Allowance – Reporting of “Non-Hazardous” chemicals is not mandatory
FUTURE PATHWAYS • States likely to develop regulations similar to current state regs – New York regulation open-ended and could be modified at any time to require more detailed reporting – Pennsylvania has proposed bill to modify and strengthen current requirements for more public disclosure – Colorado regulators planning draft chemical disclosure regulations sometime this fall – Louisiana has proposed regulation for disclosure (Oct effective date expected) – Michigan requiring MSDS be provided for high volume frac chemicals – California regulations stalled, but likely to be revisited in 2012
• FracFocus to be main information cataloging system • Call for information on poorly understood chemicals • International Implications – Canada regulations – EU Activities to correspond with REACH
Main Points to Remember: • Our industry is being proactive to correct the misconceptions of the public • Partner with service companies to provide necessary tools to work within your communities and with regulators • Ask your partners for metrics and standards to define “environmentally friendly” and “safer” so that you can use them to enhance your operations
THANK YOU FOR JOINING US!
