I started reading the recently issued (December 13, 2016) final report from the U.S. Environmental Protection Agency (EPA) – “Hydraulic Fracturing for Oil and Gas: Impacts from the Hydraulic Fracturing Water Cycle on Drinking Water Resources in the United States” (EPA-600-R-16-236Fa). I found the report to be significantly changed from the draft report issued way back in June of 2015. It is less a scientific report now and more of what the document was intended to be – a report to Congress on the impacts of hydraulic fracturing, if any, on drinking water resources. It hasn’t been “dumbed down” for that purpose, as I suppose a member of Congress will never actually read through the report, but it has been made much easier to read with far less science “jargon”. There is also not as much data and discussion on how EPA reached the conclusions in the report. But there is sufficient within the report, which covers a wide range of impacts from water acquisition to chemical toxicity, to dwell on it for some time in a series of posts. Otherwise, today’s post would be about twenty-five pages – a little long for anyone these days to sit down and read.

 

I will however write you a little summary of the report and you can follow-up in the next few months with my more detailed reviews of individual chapters within the report – the first of which I will post next week. Another reason I want to spread the wealth on the information in this report is because frankly, I have a lot of questions about the data and analysis in the report. I’m going back to many of EPA’s sources cited in the report in order to check the content of those sources so I can better understand the analysis. I was able to attend EPA’s webinar on the report held December 14, 2016. During the webinar EPA explained a few of the discrepancies between the original draft and the final. For example, the report no longer contains the phrase “studies found no widespread contamination of drinking water resources by hydraulic fracturing.” The reason EPA gave for the deletion of this phrase was due to comments from the Science Advisory Board, which reviewed the report, asking EPA to “quantify” this statement. Quantify in this case, apparently means provide exact numbers nationwide on where surface and groundwater have been contaminated during hydraulic fracturing. Since there are no databases containing this type of information, EPA could not reasonably provide such quantification and therefore decided to leave the phrase out of the current report.

 

Basically EPA said: hey, nobody is out characterizing the drinking water sources in an area before and after hydraulic fracturing occurs, so we can’t really say much about whether hydraulic fracturing is causing widespread drinking water contamination or not. Lack of this type of information is one of the many “data gaps” EPA identified in the report. Since the purpose of the report was to determine if hydraulic fracturing is impacting drinking water sources, I really kind of have to say: huh, are you kidding me, you’ve been conducting this study for six years and all you can say is (I quote here from the final report): “significant data gaps and uncertainties in the available data prevented us from calculating or estimating the national frequency of impacts on drinking water resources from activities in the hydraulic fracturing water cycle. The data gaps and uncertainties described in this report also precluded a full characterization of the severity of impacts.”

 

I would say there was something seriously wrong with the design of the work plan for the report, if it wasn’t for the fact, EPA didn’t follow the work plan in its entirety. For example, EPA was supposed to conduct pre- and post-hydraulic fracturing characterization of drinking water resources. These studies did not occur, which resulted in the major data gap mentioned above. Other data gaps resulted in part from the databases EPA used. They provided such significant inability for EPA to make conclusions on the nature and extent of any possible contamination; it is now worth while asking: why were they used in the first place.

 

Well, I better provide a summary now, or this post is going to turn out to be twenty-five pages just by itself. I guess I’ll start where I ended in my last post, when I wrote: “the major findings made by EPA were rather self-evident and didn’t need a six year study.”  Let’s take the first category: water acquisition. Water is a major component of hydraulic fracturing fluid (90 – 97% by volume) so the water used for making up the fluid has to come from somewhere. It can be a lot of water and a major question by water managers in the west has been: how is the increased use of water in hydraulic fracturing activities impacting water supplies. EPA says the median volume of water used per well fractured between 2011 and 2013 (the period of the study) is 1.5 million gallons. Of course you know “median” means half of the wells used more than 1.5 million gallons and the other half used less. It depends on the type of rock being fractured and whether the well is vertical or horizontal as to how much water is needed for hydraulic fracturing. EPA looked at water use by county and was able to determine that in most counties the amount of water used in the hydraulic fracturing of wells was less than 1 % of water use in the county; except in counties where it wasn’t. In fact, in 39 out of 401 counties with data, ten percent or more of water use in the county was for hydraulic fracturing and these were pretty much in the driest states, like Texas and North Dakota, and in counties where there’s not a whole lot of population. States like Pennsylvania in the east, where populations are greater and there is plenty of surface water (of course) showed less water is used by hydraulic fracturing compared to total water uses.

 

EPA’s study of contamination to drinking water sources from chemical mixing areas (where chemicals are stored on site and transported through pipes and hoses to equipment at the well where fracturing occurs) showed spills to be caused by equipment failure or human error. EPA studied 151 spills at the surface from chemical storage, mixing, and transport. Thirty percent were from the areas where fluid was stored. The median spill was 420 gallons, but the spill ranged from5 galloons to 19,320 gallons and included acids, biocides, friction reducers, cross linkers, gels, and blended fluid. Thirteen of the 151 spills reached a surface water body.

 

For contamination caused by the actual injection of hydraulic fracturing fluid into a well, EPA looked at a couple of different pathways: those pathways caused by newly created fractures from the process of hydraulic fracturing and pathways caused by mechanical failure or poor construction of the well being hydraulically fractured. These are two underground pathways where the hydraulic fracturing fluid could potentially flow into ground water. EPA pretty much took the information from already published studies; no new findings here.

 

The concern EPA has with fractures in the subsurface is that they might extend upward from the rock formation being fractured into shallower potable drinking water aquifers and create a route for hydraulic fracturing fluids to move into an aquifer. The EPA cites several studies which show fractures vary significantly in length depending on the rock formation being fractured. For example, hydraulic fracturing creates fractures with a greater median length in the Marcellus Shale of Pennsylvania than it causes in the Barnett Shale of Texas. The orientation of the fractures varies with the rock formation’s depth; fracturing at depths less than 2000 feet yields mostly horizontal fractures which don’t extend upward towards shallower groundwater zones, whereas fracturing at depths greater than 2000 feet yields mostly vertical fractures. EPA cites another study indicating there is a greater likelihood for upward migration of hydraulic fracturing fluid into groundwater resources when there is less vertical separation between the rock being fractured and the rock containing the groundwater.

 

In the report, EPA has some actual cases they have cited where well construction and mechanical failure causing contamination, but again the number of hydraulically fractured wells where this type of contamination pathway has occurred cannot be quantified

 

Another pathway EPA looked at to determine its potential for contamination of drinking water sources was the spillage of water containing hydraulic fracture fluid at the surface. When wells are injected with fluid to fracture the rock, high pressures are applied to the well at the surface. After the fractures are formed, the pressure on the well is released and a lot of the fluid put down the hole comes back up to the surface. Normally the water is collected and contained at the surface in tanks. But EPA was able to discern a number of cases (225) from 2011 to 2012 where there were spills of this fluid. Usually spill volumes were small – 340 to 1000 gallons – but there were at least 12 spills greater than 21,000 gallons, one of which was 2.9 million gallons. Thirteen percent of the spills reached surface water.

 

The collected hydraulic fracture fluid has to be disposed of eventually or reused. Where disposal options are limited, EPA shows more of the fluid is treated and reused. For example, in the past in Pennsylvania the collected fluid was often sent to local Publically Owned Treatment Works (POTWs) for treatment and disposal into local waterways. That all ended of course during the course of EPA’s study. The POTWs couldn’t really treat the fluid sufficiently and water with elevated level of bromide, strontium, barium and radium were being discharged into local rivers. The state environmental regulators pretty much shut all of that down, and now 90 % of the fluid is treated and reused in hydraulic fracturing. Most other states are disposing of the fluid into Class II injection wells. These are permitted wells used for waste disposal. Of course we’ve all seen some of the problems this has caused, not from contamination, but from earthquakes produced by the injection of fluid from thousands of wells into rocks with faults that are activated by all of the excess water. Use of unlined pits for collecting the fluid, instead of containing it in tanks, has also caused contamination as the fluid percolates into shallow groundwater beneath the pits. Many states have outlawed this practice now.

 

Basically, there’s a lot of information in the EPA report. But other than specific known cases of contamination, EPA is not able to make any sort of conclusion on how widespread contamination is (or isn’t) from the various pathways identified in the report. EPA says in the report, the data gaps are too great to make solid conclusions on the frequency of impacts to drinking water resources from hydraulic fracturing. What they mean by data gap, is simply the information is not readily available; either it is not collected (such as pre- and post fracking water quality), it’s not publically available (the toxicity data on many of the chemicals used in hydraulic fracturing fluid), or the information is just way too difficult to put together (for example, the surface locations of all wells being hydraulically fractured and the locations of the associated wastewater management).

 

EPA can only make some very obvious conclusions on what can cause impacts to drinking water sources; for example, using a lot of water for hydraulic fracturing in an area with few surface or groundwater sources can impact the availability of water for other uses, or inadequately treated wastewater can impact surface water to which it is being discharged, or disposing of hydraulic fracturing fluid in unlined pits can result in shallow groundwater beneath those pits being contaminated. All of these conclusions are already widely known and only take a modest amount of common sense to figure out. Unfortunately, common sense is not very common and all of these activities have occurred. Will state regulators address these problems with laws and regulations? Many of them already have. But the question remains unanswered of whether or not you need to shiver in your boots, if a company wants to hydraulically fracture an oil or gas well in your neighborhood.