**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 h ydraulic fracturing should be of great concern to the EPA. Contamination of surface or groundwater b y fluids mismanagement has been documented in all states wher e h ydraulic 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. Gra b sampling and passive sampling would be useful and should include baseline measurements to establish proof of impact. Id entifying chemicals that are unique to fracturing operations is key to establishing impact by exploration and production activities. Based on my anal ys is 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 t ypical o f either produced water unless hy drocarbons (ex. diesel) is added to the fracturing fluid. Polymers are used widel y, 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 anal ys is 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 analy sis group with expertise in fracturing fluids and possess flexibility

to conduct a suite of analy ses 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. Monit oring 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, Coll ege 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 Development202
- 564
- 6669 (ph)

202
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- 4035 (BBerry) matthews.lisa@epa.gov

----- Original Message
----- From: Paul L. Edmiston [ mailto:ped miston@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 addit ional 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 perspectiv e 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 ca n provide. Best, Paul Edmiston