PFAS in Oil and Gas: The Industry’s Fluorochemical Dependency
The petroleum industry’s use of PFAS has received considerably less public attention than AFFF contamination or consumer product PFAS—but it represents a significant and growing source of PFAS in environmental media, particularly in oil-producing regions of the US, Canada, the Middle East, and the North Sea. Fluorosurfactants—including PFAS—are used in drilling and completion fluids, enhanced oil recovery formulations, refinery process aids, pipeline corrosion inhibitors, and AFFF for oil refinery fire suppression. As regulatory attention to PFAS expands across industrial sectors, the petroleum industry faces new disclosure requirements, remediation obligations, and produced water management challenges related to PFAS content.
PFAS in Drilling and Completion Fluids
Drilling fluids (muds) and hydraulic fracturing completion fluids use PFAS-based surfactants as wetting agents, friction reducers, and emulsion stabilizers. A 2021 Physicians for Social Responsibility study identified at least 20 PFAS compounds in hydraulic fracturing fluid formulations disclosed in FracFocus, the voluntary industry disclosure database. PFAS from drilling operations can reach surface water and groundwater through: spills and releases at well pads; inadequate produced water containment; and long-distance transport with injection fluids. Wyoming’s and Pennsylvania’s regulatory agencies have identified PFAS in groundwater adjacent to active oil and gas operations—though establishing direct causation versus background contamination is methodologically challenging.
Produced Water PFAS: A Growing Management Challenge
Produced water—the water that flows back from oil and gas wells during production—contains PFAS from drilling additives, naturally occurring fluorine, and PFAS deposited in the formation from historical operations. US onshore wells produce approximately 21 billion barrels of produced water annually—eight times the volume of oil produced. Produced water management options (underground injection, evaporation ponds, treatment and surface discharge, beneficial reuse for irrigation or dust control) each carry PFAS risks. The EPA’s 2016 Effluent Limitation Guidelines for oil and gas extraction prohibited surface discharge of produced water from most onshore operations—but underground injection (Class II UIC wells) disposes of produced water without PFAS treatment, and beneficial reuse applications (increasingly permitted in water-stressed western states) apply PFAS-containing produced water directly to land.
Refinery AFFF and Fire Suppression Systems
Oil refineries—among the highest-hazard industrial facilities for fuel fire risk—have historically relied on AFFF for fire suppression in tank farms, loading docks, and process units. API RP 2021 guidance on tank fire protection cited AFFF as the standard for large hydrocarbon storage fire suppression. The transition from AFFF to fluorine-free foam (F3) is progressing in refinery applications: Shell, BP, ExxonMobil, and Chevron have committed to AFFF phase-out programs, primarily replacing AFFF in training and incidental use first while maintaining AFFF in emergency response systems pending F3 qualification under API performance standards. Refinery sites with AFFF contamination of on-site groundwater and stormwater systems face significant PFAS remediation obligations under state environmental programs.
The petroleum industry’s PFAS footprint—from wellhead to refinery—is substantial and largely outside current regulatory disclosure frameworks, making it an emerging frontier for both PFAS regulation and industry voluntary action programs.