Preliminary Proposed Manuscript for Peer-Reviewed Publication
Author: Dr Carl Albrecht, CANSA Acting Head of Research
Abstract
Introduction
Materials and Methods
Results
Discussion
Recommendations
Conclusions
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Abstract
It is the working hypothesis of this research that transparency of chemical quality analysis can lead to a lower incidence of fracking fluid spills because the affected party, i.e. the homeowner would be in a position to institute litigation for compensation. If the data were kept secret as in the US, it can be expected that there may be a lower degree of vigilance leading to more spill incidents.
It is in CANSA’s interest to minimize spills because of the presence of carcinogens in fracking fluid. Whereas CANSA believes that 90% of all cancers are caused by environmental factors and lifestyle choices, carcinogens associated with fracking are considered to be part of the threat.
One of the most important water quality analyses is the first one where data on aquifer drinking water is gathered. This is the baseline upon which all other determinations are stacked. This study concerns the chemical analyses of a water sample taken from a borehole 16km from Cradock in the Eastern Cape. The water was studied for pH, conductivity, a set of elements measured by ICP-MS; a LCMS analysis for organics after 100-fold concentration of the water sample; a search for pesticides and a GCMS analysis of concentrated water. None of these studies showed any unexpected water component with a concentration higher than 10 ppb. In general, the Cradock water contained higher concentrations of especially uranium and thorium when compared to Bellville tap water. During the study it became clear that at least 8 additional analyses can be done for a comprehensive baseline. The study demonstrates that baseline water analysis is a highly feasible exercise of great importance and could be outsourced by a homeowner if the need arose.
This work also catalysed 7 recommendations for improvement of the current Act. Basically these recommendations propose greater transparency concerning the chemicals added to the fracking fluid as well as the findings on aquifer water before, during and after fracking. We believe the homeowner has the right to access of this information in order to protect livelihood.
Introduction
South Africa stands on the brink of shale fracturing (“fracking”) in the Karoo with the hope of releasing vast amounts of gas. It has been discovered that by adding various chemicals to water and pumping this under high pressure to depths of 2-3 km can cause optimal fracturing of shale and release of gas. Without the chemicals, the process is not viable.
Furthermore, certain chemicals such as benzene and formaldehyde are used in the fracking fluid although they are classified carcinogens. Because of the high pressure and depth of operation, it is not surprising that spills of fracking fluid on the way down –or up, have been recorded. CANSA is concerned that these spills could release toxic chemicals including carcinogens into the Karoo environment which could make aquifer drinking water dangerous to consume.
Karoo farmers are not protected by legislation. If the drinking water becomes toxic the farmer needs to personally litigate in court for compensation. Such litigation depends on professional, scientific data of the quality of the aquifer drinking water before fracking started. By comparing before and after chemical analyses of drinking water, a court could decide in favour of the farmer and against the fracking company.
CANSA has embarked on a campaign to promote the professional analyses of drinking water in farms in the Karoo. In order to test the concept, drinking water was professionally obtained from a particular borehole on a farm near Cradock in the Eastern Cape. This water was analysed for conductivity, pH, elemental composition (ICP-MS), organic molecules (LCMS) and pesticides (LCMSMS). In some instances the water data was compared to Bellville tap water. The most marked finding was the high concentrations of uranium and thorium in the Karoo water compared to the Bellville water. Furthermore the water was very clean and did not contain any major organic peaks or pesticides.
This data constitutes the preliminary chemical “fingerprint” of the selected borehole baseline water. Should a fracking spill occur close to this borehole the “before” chemical analysis could be repeated and could reveal fracking fluid chemicals. Without the baseline data this would not be possible and mistakes could be made such as assuming that the high uranium and thorium levels were due to fracking while this was the situation before fracking.
Placing all this data on the CANSA website also acts as a deterrent against fracking or irresponsible fracking. This work is a proof of the concept of using pre-fracking aquifer drinking water sample analyses as a “chemical insurance “against a toxic spill. Future analysis of the same water sample, which are being developed currently, will include VOC’s (volatile organic compounds); PAH’s (Polycyclic aromatic hydrocarbons, methane, BTEX (Benzene, toluene, ethanol and xylene, radioactivity profile, endocrine disrupting chemicals and the recently discovered relationship between boron and lithium isotopes and hydraulic fracturing flow-back fluids
Materials and Methods
Choice of location, farm, farmer, professional company and sampling date
It was decided to choose a location on a farm where fracking was likely to take place within the next few years. Furthermore it was most important that the farmer would co-operate with the whole process and the location would be in reach of a professional company who would interact with the farmer; retrieve the groundwater samples from an existing borehole; conduct preliminary tests on the water and submit a detailed report.
As CANSA had no contacts in this matter, the NGO, Treasure the Karoo Action Group (TKAG) (Jeanie le Roux, Jonathan Deal) as well as the editor of Karoospace.co.za (Julienne du Toit) were approached for advice and assistance. Consultations resulted in the choice of the farm Groot Schuur 131 belonging to Mr Philip Antrobus, which is located 16 km north west of Cradock in the Inxuba Yethemba Local Municipality of the Eastern Cape Province at site co-ordinates of Latitude:-32.0834000 S and Longitude 25.4988300 E.
The quotation of the company AGES EC(Pty) LTD of East London was accepted and it was decided to retrieve the baseline water samples on Tuesday 4th March 2014. The operations were directed by the Managing Director of AGES EC, Mr.A. Myburgh; (Pr Sci., Nat (BSc.Hons Geology) and his colleague, Wilbe.S. Blay, (B.Sc. Hons Geology). Subsequent to the completion of the first phase of the study AGES EC submitted a 17-page Technical Report (Cradock Groundwater Sampling and Analyses, J.A. Myburgh, AGES EC (Pty) Ltd, Technical Report 2014/04/05/GWSE, April 2014.)
Sample analyses
Six 500 ml containers of the borehole water were flown back to Cape Town the same day in a cool bag and then stored at -800C until use. Two containers were sent by AGES to the analysts Talbot & Talbot in Pietermaritzburg in Kwa-Zulu, Natal, where tests were conducted for the following chemicals/characteristics:
Borehole water chemistry analysis-Talbot & Talbot
Ammonia, chloride, colour, conductivity, cyanide, aluminium, antimony, arsenic, cadmium, cobalt, copper, lead, mercury, nickel, selenium, uranium, vanadium, zinc, fluoride, chlorine, nitrate/nitrite, odour, pH, sodium, sulphate, iron, chromium, total dissolved solids, total organic carbon, total phenols, trihalomethanes’ bromoform, chloroform, dibromochloromethane, turbidity.
Borehole and Bellville water chemistry analysis- ICP-MS Unit, Stellenbosch University
A container of borehole water from Cradock as well as Bellville tap water (control) was given to the ICP-MS Unit of the Central Analytical Unit of Stellenbosch University (Ms Riana Rossouw) for analyses. The motivation for these analyses was to double-check the results from Talbot&Talbot as well as compare the borehole water to that of a large city, i.e. Bellville.
Samples were acidified to pH< 2 prior to inductively coupled plasma spectrometry (ICP-MS) analysis, which was performed on an Agilent 7700 system. Samples were filtered prior to ion chromatographic analysis which as performed on a Waters Breeze HPLC system using an IC Pak A column with borate gluconate buffer.
- Results are listed in document CAF Report no CA_CANSA_140506 20140506 for borehole water;
- CAF Control Standard Recovery Values Bellville 20141215; and
- CAF Control Standard Recovery Values Bellville 20141222 for Bellville tap water control samples.
Pesticide analysis of groundwater
A container of groundwater was presented to HORTEC (Pty) Ltd. (Mr Wessel Kriek) for analysis A quantitative analysis was performed on a Waters Acquity UPLC coupled to a Waters Xevo TQ MS mass spectrometer. The sample was tested for 160 different pesticides at lower limits of quantitation (LLOQ) ranging from 10 parts per billion (ppb) to 5 ppb. Qualitative analysis was performed on a Agilent 1290 UHPLC coupled to an AB Sciex 4500 Qtrap mass spectrometer. The sample was screened for 212 pesticides and isomers with a limit of detection (LOD) of 10 ppb for all pesticides.
Borehole water chemistry analysis- LCMS Unit, Central Analytical facility, University of Stellenbosch
A container of borehole water was thawed from -800C to room temperature and subjected to 1000-fold concentration in the LCMS-Unit of Stellenbosch University (Dr Marietjie Stander) using a Waters C18 solid phase extraction cartridge prior to analysis. A non-targeted LC-MS screen was done on the baseline water sample and the same sample was stored for future reference. The equipment for separation was a waters UPLC BEH C18, 2.1 x 100mm column connected to a Synapt G2 quadrupole time-of flight mass spectrometer and the sample was analysed both in the positive and negative mode.
Results
Chemical water quality analyses
Talbot & Talbot data
None of the parameters measured according to SANS 241-1 were above recommended limits.
ICP-MS Borehole & ICP- MS Bellville
Comparison of water samples from Cradock and Bellville showed that the Cradock aquifer water had higher concentrations of certain minerals than the same minerals in Bellville tap water. The minerals were Mn, Fe, Co Sr, U of which Sr and U were the highest.
- Results are listed in document CAF Report no CA_CANSA_140506 20140506 for borehole water;
- CAF Control Standard Recovery Values Bellville 20141215; and
- CAF Control Standard Recovery Values Bellville 20141222 for Bellville tap water control samples.
GCMS of borehole water
The chromatograms obtained showed that the water sample contained very little organic compounds that can be detected with these techniques.
HORTEC Pesticides
Prirmicarb (a selective carbamate insecticide used on aphids on agricultural produce like vegetables) as well as Triazoxide an imidazole fungicide were detected, however the levels were below the limits of detection (LOD) which were 10 ppb and the lower limits of quantitation (LLOQ).
LCMS
The chromatograms obtained showed that the water sample contained very little organic compounds that can be detected with these techniques.
Karoospace Report
The Report-“Ground Zero for Karoo Fracking” by Julienne du Toit and Chris Marais is pictorially and editorially informative of the situation on the 4th April, 2014, when the baseline, borehole, drinking water sample was harvested.
Discussion
Contamination of borehole water
Four different mechanisms have been reported whereby groundwater (borehole water) can become contaminated during fracking (“A critical review of the risks to water resources from unconventional shale gas development and hydraulic fracturing in the United States“, Vengosh A, Jackson R, Warner N, Darrah T and Kondash A, Environ Sci. Technol.,)
The four mechanisms involved in the pollution of aquifers are:
- Stray gas contamination
- Spills, leaks and Inadequate treatment and/or disposal of shale gas wastewater.
- Accumulation of toxic and radioactive elements in soil or stream sediments near disposal or spill sites.
- Direct contamination of shallow ground water from hydraulic fracturing fracturing fluids.
Carcinogens
Carcinogens introduced into the fracturing fluid are obviously not there to cause cancer. The chemicals are all selected through trial and error to facilitate some or other aspect of the fracturing process. Carcinogens and their possible use in fracturing are shown below:
Relationship between some carcinogens and fracturing process
- http://www.earthworksaction.org/issues/detail/hydraulic_fracturing_101#CHEMICALS
- http://en.wikipedia.org/wiki/List_of_additives_for_hydraulic_fracturing
- http://www.kgs.ku.edu/Hydro/Publications/2012/Fracturing/
Outstanding tests
The baseline water analytical tests reported here are not exhaustive. The following list of additional tests need to be applied to the borehole water samples:
- Radioactivity (Radium isotopes and gross alpha and beta particles)
- VOM’s –volatile organic compounds such as BTEX – benzene, toluene, ethyl benzene and xylene (Analysis of BTEX groundwater concentrations from surface spills associated with hydraulic fracturing operations. Gross SA, Avens HJ, Banducci AM, Sahmel J, Panko JM and Tvermoes BE, J Air Waste Manag Assoc, 2013, 63, 424-432.
- Formaldehyde (LCMS?)
- Endocrine Disrupting Compounds (EDC’s) – (Estrogen and androgen chemicals and surface and ground water in a drilling dense region, Kassotis CD, Tillitt, DF, Davis, JW, Hornmann, AM and Nagel SC, Endocrinology, 2014, 155, 897-907. (Development and reproductive effects of chemicals associated with unconventional oil and gas operations, Webb E, Bushkin-Bedient S, Cheng A., Kassotis CD, Balise and Nagel SC, Rev. Environ. Health, 2014, 29, 307 -318.)
- Naphthalene
- PAH’s (Polycyclic aromatic hydrocarbons)
- Cobalt/Lithium isotope ratios (New tracers identify hydraulic fracturing fluids and accidental releases from oil and gas operations, Warner NR, Darrah TH, Jackson RB, Millot R, Kloppmann W, Vengosh, Environ. Sci. Technol. 2014, 48, 12552 -12560.
- Evaluate “in home” testing. Homeowners can test their drinking water once a week with a simple conductivity meter. A reading of about 700 units (microsiemens per centimetre – uS/cm) is acceptable. However if readings go higher the water needs to be tested in an accredited laboratory. Flowback water from fracking in the Marcellusshale in the US gave a reading of 470 000 uS/cm. (http://www.dontfractureillinois.net/baseline%20testing/)
Baseline Legislation –Worldwide
There appears to be a growing worldwide concern for professional, transparent and scientific characterisation of baseline, aquifer, drinking water before fracking is initiated at any particular site.
This concern was to a great extent neutralised by the 2005 Energy Policy Act in the US, which arose out of Vice President Cheney’s Energy Task force , which altered the Safe Drinking Water Act to exclude fracking from all measures mentioned in the Safe Drinking Water Act. This arrangement allowed fracking companies to use chemical “brews” consisting of 700 different chemicals of which a number were proven carcinogens to be injected into the earth to facilitate maximum gas release without needing to divulge the nature of the chemicals used. Furthermore if spills occurred contaminating ground water resources there was no clear mechanism for compensation because the quality of the original groundwater before fracking, was not common knowledge.
- http://en.wikipedia.org/wiki/Exemptions_for_hydraulic_fracturing_under_United_States_federal_law
- http://www.truth-out.org/opinion/item/21828-time-to-end-the-cheney-halliburton-loophole
- http://en.wikipedia.org/wiki/Exemptions_for_hydraulic_fracturing_under_United_States_federal_law
At the state level in the US, initiatives are becoming evident for legislation concerning groundwater quality analyses before fracking starts, so that information could be used in court to receive compensation for contamination. Thus in North Carolina the Mining and Energy Commission have proposed a package of 120+ proposed rules a s a framework.
The rules include;
- That the fracking company is responsible for baseline water testing
- That the company must arrange for extensive sampling data before fracking ensues
- That an analytical laboratory that is a 3rd party and acceptable to the homeowner be hired to do the testing
- That tests be conducted throughout the fracking process and for 2,4 and 6 years after the drilling ceases
- That the fracking company pays for all the tests
- That the distance between the horizontal drill hole and the surface not be less than 1000 ft.
- That the liability distance between the drill hole and the homeowners groundwater source not be less than 5000 ft.
- http://northcarolinaenvironmentalpartnership.org/wp-content/uploads/Fracking-Fact-Sheet-Baseline-Testing_REV.pdf
No regulations or proposed regulations were found in any state that stipulated the need to make pre-drilling groundwater analytical data transparently available to the farmer. The reason for this is not clear. It could be due to clauses in the 2005 Energy Policy Act. Nevertheless in a personal communication from Dr XXX CANSA was informed that South Africa was in the fortunate position to sort out pre-drilling drinking water quality analysis because many litigation cases in the US were aborted due to a lack of baseline data.Personal communication 2010).
In the US there is a call to make fracking liable to the Safe Drinking Water Act. If this happens, transparency of pre-drilling water quality data may become a reality.
Baseline Legislation – South Africa
The only legislation concerned with fracking in South Africa is the Technical Regulations for Petroleum Exploration and Exploitation of Act 28 of 2002.
- http://www.dmr.gov.za/publications/summary/218-hydraulic-fracturing/1025-gazetted-proposed-technical-regulations-for-petroleum-exploration-and-exploitation.html (Regulation document: Gazetted_proposed_technical_regulations_for_petroleum.pdf)
Under Chapter 2; Site assessment, selection and preparation and in particular Section 5, especially Sub-sections 5.(2) and 5.(3) (Page 12) attention is focused on baseline water quality determinations. The key features are the following:
- (5.2) The holder (fracking company) must, prior to conducting hydraulic fracturing operations, appoint an independent specialist approved by the designated agency to conduct baseline water quality assessment of all water resources within 1 kilometre of the vertical projection of the wellbore to surface.
- (5.3) Water samples collected as part of the baseline quality assessment contemplated in sub-regulation (2) must be analysed by an accredited laboratory and the holder must submit the results to the designated agency and the Department of Water Affairs within 7 days after receipt thereof.
No mention is made of which tests are obligatory for water quality control and transparency of this quality data for the homeowner on whose property the fracking is to be done (with no compensation) is not dealt with. Basically the water quality data, according to the act, will be known to the laboratory, the holder, the designated agency and the Department of Water Affairs – but not by the person who has the most to lose, i.e. the homeowner.
Recommendations
That the current ACT 28 of 2002 be amended as follows:
- That the current act become more transparent and even-handed so that the homeowner has enough information on the quality of the groundwater on his/her farm, before fracking; while fracking is taking place as well as up to 6 years after fracking, so that if necessary, this information can be used during litigation.
- That the water quality information should enable an expert to ascertain if the groundwater is polluted with chemicals purposefully used for fracking and/or released from the ground/shale during fracking.
- That a list of essential water quality tests be specified by the Department of Water affairs that will contain internationally accepted markers of fracking such as detected by ICP-MS and LCMS as well as radioactivity monitoring devices and any other applicable technique. Consensus on the contents of this list of essential techniques should be reached by a panel of water quality experts.
- That the holder (fracking company) must pay for all water quality tests that need to be conducted before, during and after fracking as agreed to before fracking starts.
- That the water quality information belongs to the holder but must be made available to designated authorities and the homeowner in good time.
- In the event of the homeowner not receiving the water quality data from the fracking companies, for whatever reason, the homeowner is entitled to have the water tested according to specifications of the Act, at the owners own expense. Such information must be allowed to be used for litigation purposes in court should litigation be sought by the homeowner.
- That Section 29(1) (a) to (g) of the ACT, which sets out the disclosure of each additive (intentionally added) in the fracturing process to the Department of Water Affairs also be transmitted to the homeowner at the same time.
Conclusions
The main aim of this communication is to focus on the importance of assessing the quality of baseline, underground, drinking water before fracking starts. To this end a particular water sample was taken from an underground drinking water source and subjected to a number of tests. The whole exercise shows that this process is feasible and also needs further sophistication. In this sense the current project has demonstrated proof of principle.
South African farmers and homeowners in the Karoo cannot share in any possible profits from fracking because they have no claim to minerals under the ground. Nevertheless, they should at least be able to protect their livelihood by receiving information on the quality of their drinking water from underground aquifers from holders (fracking companies) who according to law are necessitated to gather quality information before, during and after fracking. The main reason why the homeowner should be given all of this information is because if a bad spill of fracking fluid occurs which contaminates the underground drinking water source, this could condemn the farm and surrounding environment causing a loss of many millions of rands. The homeowner should be in a legally sound position to seek redress in court, armed with the “before” and “after” water quality data. Without this data the homeowner could lose everything. Should the holder renege on this agreement, the homeowner should be entitled to seek water quality information, at own expense.
The Department of Water Affairs should also specify the essential water quality tests required so that these tests can be standardised.
It is the working hypothesis of this study that greater transparency and sharing of all relevant information with the homeowner could moderate the entire fracking industry in the Karoo to be more meticulous and responsible and this could result in a very low incidence of spillage into aquifers. On the other hand, by keeping information on water quality a secret, as is the case in the US with the 2005 Energy Policy Act, and denying the homeowner the right to know what is happening on his/her own property, could spell multiple disasters and social unrest.