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Reveal all additives

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Modernize fracking rules with tracers

By John Bartlit

Innovation is the pride and lifeblood of our democracy. Innovation in business systems and industries’ products is vital and thriving. Unending resources go into more innovations, think R&D.
Innovation in regulatory tools is as vital, but lags far behind. Why does filling a crucial need attract scant interest and effort? Custom perhaps. Blind spots?
Our interest group took a timely occasion to campaign for regulatory innovation.    
On Nov. 17, the New Mexico Oil Conservation Commission (OCC) held a hearing on a narrow issue related to fracking.
“Fracking” means hydrofracturing of deep rock formations to extract more gas and oil from them. The question of the day’s hearing was to what extent do companies have to reveal all the contents of the fracking fluids they inject into formations.
Companies do not want to list the special additives in their fracking fluids. The very names are eerily chemical, such as ethylene glycol; naphthalene; 1,2,4-trimethylbenzene; formaldehyde and dozens more.
For a mix of reasons, companies use the term “trade secret” to withhold the full list of additives and their proportions. The concealed facts heighten public fears.
We and other groups at the hearing supported full disclosure of fracking fluids.
More to the message of this column, we also proposed an idea for a new regulatory tool. The idea is to add tracers to fracking fluids. A tracer is a tiny amount of a chemical that would clearly identify the origin of contamination from a fracking fluid, should it occur.
Tracers have been used for decades to reveal the pathways of pollutants in air or water, chemistry in the body and food chains in nature.   
Our public comments at the hearing took up four minutes:                                     
“My comments today support the principles of efficiency and transparency in the regulatory process. Transparency of information is a core value of this agency and is the key to credibility. I support the full and public disclosure of all components of fracking fluid, their proportions and amounts used.   
“Improved efficiency of the regulatory process needs to be a high priority of all interests. In my comments, ‘efficiency’ refers to ways of regulating that are more efficient, faster and lower cost in the working.
“Efficiency does not refer to how stringent regulations may or may not be. Competing interests constantly debate the optimum stringency of regulations. Little attention is devoted to constructing regulations whose very nature makes them quicker and cheaper to do in all aspects – in permitting, surveillance and enforcement. ‘Efficient’ means simpler to enforce, simpler to comply.  
“Fracking offers an attractive technical opportunity to improve regulatory efficiency with tracers.  
“Suitable tracers for fracking fluids need three qualities:
•They must be non-reactive with other chemicals in the fracking environment.
•They must be unique to fracking fluids and not otherwise found in the fracking environment. They must mix uniformly in fracking fluids and not be absorbed by soil.
•They must be easily detected and measured in mixtures, whether liquid or gaseous.
“Adding tracers to fracking fluids has great potential to save time and cut costs for all parties in the regulatory process. In particular:
•Tracers have potential to avoid some more complicated requirements that could be used to assure there is adequate knowledge and control of fracking fluids.
•Tracers have potential to save time and everyone’s costs in resolving disputes, even lawsuits, over who or what is responsible if unexplained chemicals reach unexpected places.    
“Work remains to be done. Yet adding tracers to fracking fluids has a large potential to benefit every interest, from industry to regulators, ranchers, towns and taxpayers.
“I urge consideration of this technical opportunity to make regulation more efficient in the working.”
Our remarks said, “Work remains to be done.” What kind of work?
Companies employ tracers in fracking fluid to track progress in cracking rocks.
Normally, industry seeks to expand know-how to meet other needs. Except not to modernize regulation.  
Work needed on tracers includes which tracers to use and distinct tracers for different boreholes.
Tracers require controls to ensure no company avoids adding their tracer.
Control is also needed in case a mischief-maker hopes to add a credible tracer to a water supply.
These are not charges, only real prospects in this flawed world.
Tracers in fracking fluids offer innovation on the way to more efficient regulation.

John Barlit
New Mexico Citizens
for Clean Air & Water