U-M researchers analyze Michigan's policy options for hydraulic fracturing in Utica-Collingwood

April 1, 2015
University of Michigan researchers released a detailed draft analysis of policy options for hydraulic fracturing in Michigan during February.


University of Michigan researchers released a detailed draft analysis of policy options for hydraulic fracturing in Michigan during February. Although industry has done fracturing jobs in Michigan for decades, new technology enables companies to drill wells in Michigan’s Utica-Collingwood shale.

High-volume fracturing in Michigan currently is limited, but researchers suggest the practice could become more widespread. They analyzed options for the state regarding public participation, water resources, and chemical use.

Encana Corp. was among early shale players in Michigan although the company currently plans to concentrate on other shale plays given the 2014-15 slump in oil prices.

Leases for Encana are centered around Cheboygan, Kalkaska, and Missaukee counties in Michigan’s northern Lower Peninsula. In 2012, Encana reported it had 430,000 net acre land position in this play, focusing on the liquids rich window.

In 2010, an Encana well flowed gas-condensate from Middle Ordovician Collingwood shale and underlying Utica shale.

Encana subsidiary Petoskey Exploration LLC, Denver, drilled a 5,000-ft horizontal penetration that targeted the Collingwood shale at 9,500 ft true vertical depth (OGJ Online, Mar. 22, 2010). Petoskey’s Pioneer 1-3 was in 3-24n-7w, Missaukee County, 30 miles southeast of Traverse City.

Collingwood, a shaly limestone about 40 ft thick, lies just above the Ordovician Trenton formation. The Michigan basin extends into Ontario.

The U-M fracturing report does not advocate recommended courses of action, said John Callewaert, integrated assessment director at U-M’s Graham Sustainability Institute, which oversaw the study. "Rather, it presents information about the likely strengths, weaknesses, and outcomes of various courses of action to support informed decision making," Callawaert said.

Options discussed in the report include:

  • More extensive requirements for information about chemical use and water quality, possibly including the full disclosure to state officials of all chemicals used in the hydraulic fracturing process--even substances considered to be trade secrets.
  • New ways to manage the disposal of wastewater from hydraulic fracturing wells in Michigan.
  • Additional options for water-quality monitoring, possibly including long-term monitoring of groundwater and surface water near hydraulic fracturing wells.
  • Requiring hydraulic fracturing well operators to prepare emergency response plans before drilling begins.
  • Increasing public participation in decisions related to hydraulic fracturing.

The draft report, written by U-M faculty researchers with support from students, is the main product of the integrated assessment’s second phase. The first phase of the 2-year project featured seven detailed, peer-reviewed hydraulic fracturing technical reports, released to the public in September 2013.

Updating frac rules

The Michigan Department of Environmental Quality already is considering some rule changes. Those proposed changes--covering water-withdrawal assessment and monitoring, water sampling, additional well monitoring and reporting, and additional chemical additive disclosure procedures--are included in the U-M analysis of policy options.

DEQ last updated fracturing regulations in 2011, the agency’s web site said.

The draft final report will be revised in response to comments from an advisory committee with representatives from corporate, government, and nongovernmental organizations as well as public comments.

A final version is expected to be completed this year that will be shared with government officials, industry experts, other academics, advocacy groups and the general public.

Michigan state officials define high-volume fracturing as a job involving more than 100,000 gal of hydraulic fracturing fluid. As of Dec. 22, 2014, statistics showed 13 producing wells that were completed using high-volume fracturing.

By comparison, more than 12,000 oil and gas wells have been fractured in Michigan since the late 1940s using conventional techniques that typically include relatively shallow vertical wells.

While those earlier wells used 50,000 gal of water each, a modern frac job in the Utica-Collingwood shale formation can use at least 10 million gal, the report said.

"With the intensity of wastewater generation associated with high-volume hydraulic fracturing, it is not clear whether the laws and regulations written at a time of small-scale, shallow hydraulic fracturing options will be adequate," the report said in a chapter on water resources.

Wastewater fluids injected

The current process for managing fracturing wastewater fluids in Michigan involves deep-well injection into Class II wells, which are designed to keep underground drinking water supplies safe from contamination.

This approach, combined with the prohibition against storing those fluids in open surface pits, has prevented surface contamination problems that other states have experienced, according to the report.

Even so, other options for managing and monitoring wastewater disposal could be explored, according to the draft U-M report. One option is wastewater recycling. Instead of being injected into disposal wells, wastewater could be treated and reused for gas development. Treatment of wastewater to be reused for hydraulic fracturing operations should focus on the removal of organic contaminants and inorganic constituents, according to the draft report.

During 2005-11, the US Environmental Protection Agency identified more than 1,000 chemicals either used in fracturing fluids or found in associated wastewaters. But information on human health risks and ecological risks continue to be studied.

Michigan is among 24 states that require well operators to disclose the chemicals used in fracturing fluids. Operators currently have up to 60 days after a well is completed to submit that list, and operators can protect the identity of chemicals deemed to be trade secrets.

"More extensive requirements pertaining to information on chemical use and water quality appear desirable--if they are in plain language--given public concern relating to these aspects and their potential public health implications," the report said.

One option would be to require well operators to provide a list of all chemicals they propose to use before the frac job. That information would be posted on the FracFocus website and a dedicated state government website.

Under that same precautionary approach, information about fracking chemicals considered to be trade secrets would not be posted on the websites. However, well operators would be required to disclose that information to the state.

Michigan currently does not require operators to test groundwater and surface-water quality near wells completed using fracturing. One proposed option would require operators to install test wells and to conduct long-term groundwater and surface water monitoring.

Operators in Michigan also are not required to prepare emergency response plans, the report said, adding that the state of New York had such a requirement before a statewide ban on fracing was imposed there.

Another option would require operators in Michigan to create emergency response plans before operations begin. Immediate notification of spills greater than 1 gal would also be required. Bonding requirements would be tightened, and operators would be required to carry a liability insurance policy of $1 million per well. Currently, Michigan does not require such insurance.

Public participation

Michigan has largely treated high-volume fracturing as an extension of other types of oil and gas activities. As a result, the public has had few opportunities to weigh in on whether and where the process occurs.

The state could consider implementing a number of options to better represent public values in its policies, the report said.

"In the short term, the lack of opportunities for public participation may contribute to feelings that unconventional shale gas is being involuntarily imposed and, thus, lead to greater distrust of state agencies," it said. "In the long term, leaving the public out of … decision-making may result in decisions that inadequately account for location conditions and cultural values."

The option of imposing a moratorium on fracturing in Michigan could give state officials time to conduct studies and to devise regulations for mitigating those impacts, the report said, noting that some communities and nonprofit groups support a statewide ban on high-volume fracturing.

"However, this option comes at the cost of reducing income to the mineral rights owners, industry, and the state by preventing development of the resource," researcher said.

Preparation of the draft final report was overseen by a team from U-M’s Graham Sustainability Institute, the Energy Institute, the Erb Institute for Global Sustainable Enterprise and the Risk Science Center. The hydraulic fracturing project is expected to cost at least $600,000 and is being funded by the Graham Sustainability Institute, the Energy Institute and the Risk Science Center.

More than 200 public comments were submitted in response to the technical reports released in September 2013. Those reports were downloaded more than 1,500 times in the year following their release.