I was elated when I got the notice that the Environmental Protection Agency’s (EPA) Science Advisory Board had finished the peer review of the agency’s draft report: “Assessment of the Potential Impacts of Hydraulic Fracturing for Oil and Gas on Drinking Water Resources.” I thought at long last there will be a final report issued. My elation turned to dismay after reading the 133 page peer review. Of course EPA asked for it. EPA asked the Science Advisory Board to look at how complete and accurate each chapter in their report was, to determine if information in each chapter supported the conclusions, to evaluate what other conclusions might be drawn from the material presented in a chapter, and to provide additional background, information, and research gaps.

 

The Science Advisory Board’s comments were comprehensive. So much so that I now think it unlikely we will get a completed report from EPA in a reasonable timeframe. For those of you who are unfamiliar with what a Science Advisory Board is, let me make a short explanation. EPA’s Science Advisory Boards are external review teams made up of senior scientists from universities, corporations, trade groups, state agencies, and consultants. The members of the team are usually some of the foremost experts in their fields. In this case most of the board members are academics. Their comments are very detailed and charge EPA with producing a lot of additional analysis and examination of different data sources. Many of the comments will require EPA to undertake significant new work. It’s difficult to say how long such additional new work might take.

 

I was so alarmed by the prospect of waiting another five years; I sent comments to be part of the docket. After all, this report was begun sometime in 2010. It is now 2016. Companies are continuing to use hydraulic fracturing techniques but there is still no comprehensive report on what impacts, if any, there might be to drinking water in areas where hydraulic fracturing is taking place. If you have been reading this blog’s posts on EPA’s “retrospective” studies of areas where there have been concerns about groundwater contamination, you know there are substantial indications in a few cases that there has been contamination of groundwater resources from stray gas and hydrofracture chemicals after hydraulic fracturing has taken place. These cases have generally been related to blowouts accompanied by releases of fracturing fluid to the surface, poor cement bonding that allowed natural gas to travel up the gas well, or poor disposal locations and practices for waste. Certainly there should be at least some sort of interim report on status to date if the peer review comments are completely accepted as is.

 

Read my comments to the Science Advisory Board below.

Comments in Response to Request of EPA’s Science Advisory Board on the Peer Review of EPA’s Draft “Assessment of the Potential Impacts of Hydraulic Fracturing for Oil and Gas on Drinking Water Resources” (May 2015, External Review Draft, EPA/600/R-15/047

 

Thank you for your service on the Science Advisory Board (SAB) Hydraulic Fracturing Research Advisory Panel. I have three comments I would like to share with the Science Advisory Board in regard to comments made by the SAB on the EPA’s Draft “Assessment of the Potential Impacts of Hydraulic Fracturing for Oil and Gas on Drinking Water Resources.” The first two are of a technical nature and the second is in regard to the overall extent of comments and length of time which may be needed for EPA to address all SAB comments.

 

(1) My first comment is in regard to the SAB’s review of Chapter 4 of the EPA report covering “Water Acquisition.” I will paraphrase the SAB comment: water acquisition is a localized issue as to its impacts on groundwater and surface water resources. The SAB comments also state there are important gaps and uncertainties in publicly available information on sources and quantities of water used in hydraulic fracturing. The SAB goes on to recommend that EPA examine well completion reports, permit applications and water management plans to assess water usage for hydraulic fracturing. I have followed the water acquisition issue for many years and it seems to be of greatest concern to western state water managers. Most of these water managers are responsible for allocation of water resources within their states. Many may have a compilation of water usage data within the state engineer’s office and because of past expressed concerns may have collected data on water usage for hydraulic fracturing. An assessment of well completion reports and permit applications sounds like an extensive effort and since indeed water acquisition impacts are localized a reconnaissance for state data sources would be more expedient.

 

(2) My second comment is in regard to the SAB’s review of Chapter 6 of the draft EPA report. Page 54 states: “Modeling results do not represent actual sites or all combinations of stresses, gradients, rock properties, typical geology and heterogeneity. Include a discussion on the importance of understanding regional geology of an area prior to embarking on installing a hydraulic fracturing well.” I was disappointed, after reading the EPA’s draft report, in the lack of incorporation of information from the retrospective case studies. One of the main points I took away from the retrospective studies was the lack of characterization of the local geology, hydrogeology and water quality prior to hydraulic fracturing. In their retrospective studies, EPA was in some cases relying on water quality data from the 1970s. It seemed obvious from the retrospective case studies that any contamination of drinking water resources, whether from degraded hydraulic fracturing chemicals or stray natural gas and whether from a blow-out or from poorly constructed wells (or even from natural conditions), is dependent on local geology and hydrologic conditions such as hydraulic gradient, fracture flow, etc. An assessment of these local characteristics could inform what protective construction needs are in advance of drilling a well or disposing of waste. It would also inform response to large spills by defining depth to groundwater, hydraulic gradients, and migration pathways for contaminated groundwater.  The SAB should make this a stronger recommendation to EPA. I recall one of the goals, EPA set out in producing their report, was to provide information to help regulators. Site and local characterization of the geology and hydrogeology before hydraulic fracturing could be incorporated into the regulatory permit process in areas where it is not now required.

 

(3) My final comment is in regard to the scope of the SAB comments. The SAB has produced a very comprehensive and well informed set of comments. However I would urge you to look at the necessity of some of the data needs you are recommending to EPA for inclusion in the current report. Some of the recommendations could take extensive extra effort. We are already five years from the inception of EPA’s report. In fact, many of your recommendations are to update information in the report. Just updating information to 2016 could take significant efforts. I am worried about the extended time period for EPA to produce a report. Could the efforts take so long that once again in two years we are asking EPA to update the report with new information. I’m afraid it could be a never ending cycle. I think the SAB and the EPA need to assess the time needs for each one of the comments to be incorporated into the report and determine if the information need is vital to the current report or could be included in a follow-on report.         

 

Thank you for the opportunity to comment.