Chesapeake Energy 2013 Annual Report Download - page 24

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CWA and analogous state laws require individual permits or coverage under general permits for discharges of storm
water runoff from certain types of facilities.
The Oil Pollution Act of 1990 (OPA) establishes strict liability for owners and operators of facilities that are the
site of a release of oil into waters of the U.S. The OPA and its associated regulations impose a variety of requirements
on responsible parties related to the prevention of oil spills and liability for damages resulting from such spills. A
''responsible party'' under the OPA includes owners and operators of certain onshore facilities from which a release
may affect waters of the U.S.
Health and Safety
The Occupational Safety and Health Act (OSHA) and comparable state laws regulate the protection of the health
and safety of our employees. The federal Occupational Safety and Health Administration has established workplace
safety standards that provide guidelines for maintaining a safe workplace in light of potential hazards, such as employee
exposure to hazardous substances. OSHA also requires employee training and maintenance of records, and the OSHA
hazard communication standard and EPA community right-to-know regulations under the Emergency Planning and
Community Right-to-Know Act of 1986 require that we organize and/or disclose information about hazardous materials
used or produced in our operations.
Hydraulic Fracturing
Vast quantities of natural gas, natural gas liquids and oil deposits exist in deep shale and other unconventional
formations. It is customary in our industry to recover these resources through the use of hydraulic fracturing, combined
with horizontal drilling. Hydraulic fracturing is the process of creating or expanding cracks, or fractures, in deep
underground formations using water, sand and other additives pumped under high pressure into the formation. As with
the rest of the industry, we use hydraulic fracturing as a means to increase the productivity of almost every well that
we drill and complete. These formations are generally geologically separated and isolated from fresh ground water
supplies by thousands of feet of impermeable rock layers.
We follow applicable legal requirements for groundwater protection in our operations that are subject to supervision
by state and federal regulators (including the Bureau of Land Management (BLM) on federal acreage). Furthermore,
our well construction practices require the installation of multiple layers of protective steel casing surrounded by cement
that are specifically designed and installed to protect freshwater aquifers by preventing the migration of fracturing fluids
into aquifers.
Injection rates and pressures are required to be monitored in real time at the surface during our hydraulic fracturing
operations. Pressure is required to be monitored on both the injection string and the immediate annulus to the injection
string. Hydraulic fracturing operations are required to be shut down if an abrupt change occurs to the injection pressure
or annular pressure. These aspects of hydraulic fracturing operations are designed to prevent a pathway for the
fracturing fluid to contact any aquifers during the hydraulic fracturing operations.
Hydraulic fracture stimulation requires the use of water. We use fresh water or recycled produced water in our
fracturing treatments in accordance with applicable water management plans and laws. We strive to find alternative
sources of water and reduce our reliance on fresh water resources. We have technical staff dedicated to the development
of water recycling and re-use systems, and our Aqua Renew® program uses state-of-the-art technology in an effort to
recycle produced water in our operations.
Hydraulic fracturing is typically regulated by state oil and gas commissions. Some states have adopted, and other
states are considering adopting, regulations that impose disclosure requirements on hydraulic fracturing operations.
Since early 2011, we have participated in FracFocus, a national publicly accessible web-based registry developed by
the Ground Water Protection Council and the Interstate Oil and Gas Compact Commission, with support of the U.S.
Department of Energy, to report on a well-by-well basis the additives and chemicals and amount of water used in the
hydraulic fracturing process for each of the wells we operate. The website, www.fracfocus.org, also includes information
about how hydraulic fracturing works, the chemicals used in hydraulic fracturing and how fresh water aquifers are
protected. Some states, such as Texas, Colorado, Montana, Louisiana, Pennsylvania and North Dakota, which mandate
disclosure of chemical additives used in hydraulic fracturing require operators to use the FracFocus website for reporting.
The Pennsylvania legislature has passed Act 13, which requires, among other things, additional information in the
stimulation record including water source identification and volume as well as a list of chemicals used to stimulate the
well, including chemicals used in hydraulic fracturing. Certain portions of Act 13 were invalidated by the state’s Supreme
Court in December 2013 and are currently subject to a request for reconsideration by the state.