Well stimulation activities and oil and gas development in general can result in a range of impacts to the environment and human health, but much more data is needed to completely analyze the risks, according to two new reports from the California Council on Science and Technology.
The reports are lengthy and will take time to read and fully digest, but a number of findings and recommendations immediately stand out, including:
"Operators currently dispose of wastewater from hydraulically fractured wells in percolation pits and also likely have occasionally injected wastewater contaminated with stimulation chemicals into protected groundwater. These practices should stop."
No minced words there.
Unlike many other states, California still permits the mind-boggling practice of allowing oil and gas operators to dispose of their potentially toxic wastewater by putting it in massive pits and letting it soak into the ground. The scientists found that nearly 60% of hydraulic fracturing wastewater may be managed using this method in the month after wells are stimulated, and that these pits could provide a direct pathway for contaminants to reach groundwater. This contaminated groundwater could end up in streams or rivers or even possibly introduce contaminants into our food.
As I've blogged about previously, California has improperly permitted thousands of injection wells to pump wastewater and other fluids into federally protected drinking water aquifers. The scientists found that some of that wastewater could contain hydraulic fracturing chemicals.
It's not at all clear whether the brand new well stimulation regulations, which went into effect just over a week before the study was released, will indeed require these practices to stop. Those rules say that wastewater from fractured wells can't be "stored" in pits, but are silent about disposal. And far from stopping wastewater with fracking chemicals from being injected into protected groundwater, the State's current plan is instead to potentially exempt that groundwater from the very legal protections that would prevent this activity.
"Operators have unrestricted use of many hazardous and uncharacterized chemicals in hydraulic fracturing. [T]he use of chemicals with unknown environmental profiles should be disallowed. The overall number of different chemicals should be reduced, and the use of more hazardous chemicals and chemicals with poor environmental profiles should be reduced, avoided, or disallowed."
Oil and gas operators in California reported using more than 300 different chemical additives in well stimulation, yet the scientists found that complete information about the hazards and risks is only available for about one third of those chemicals. They go on to state that, "The toxicity and biodegradability of more than half the chemicals used in hydraulic fracturing remains uninvestigated, unmeasured, and unknown. Basic information about how these chemicals would move through the environment does not exist."
This is an enormous data gap, and seriously impedes our ability to understand the full environmental and human health risks associated with stimulation practices. What's more, the new well stimulation regulations don't address this issue at all.
"Shallow hydraulic fracturing presents a higher risk of groundwater contamination, which groundwater monitoring may not detect. This situation warrants additional scrutiny. Operations with shallow fracturing near protected groundwater could be disallowed or be subject to additional requirements regarding design, control, monitoring, reporting, and corrective action..."
Given that the scientists found that about 75% of fracturing in California takes place in shallow wells less than 2,000 feet deep, this is a bombshell finding. Protected groundwater isn't present everywhere these wells are located, but where it is that water could be at serious risk of contamination. The report details an extensive list of actions operators should take in such cases to reduce this threat, including better modeling of where fractures will go to ensure they won't intersect protected water, and enhanced monitoring. While the new rules do include some of these actions, as the scientists point out, many questions remain about how they will be implemented in practice and whether they will be effective.
"The majority of impacts associated with hydraulic fracturing are caused by the indirect impacts of oil and gas production enabled by the hydraulic fracturing."
This is significant, and something NRDC has long advocated. Hydraulic fracturing and other well stimulation techniques are just one step in a long, complex chain of activities used to produce oil and gas. Each one of those activities has the potential to threaten our air, water, land, wildlife, and health. The protection afforded to our communities and environment from those threats is only as good as the weakest link in the chain.
California has taken some important steps forward to put those protections in place, but as this study shows, we still have a long way to go. Making sure those protections are adequate is seriously complicated by something this and previous studies from New York State, the EPA, and others have found: there's a lot we don't know. Major chunks of this study and those that came before it are devoted to the gaping holes in available data and the uncertainties in the data we do have.
Science doesn't tell us what to do in the face of this uncertainty. That's a decision that we as a society have to make based on our values. From NRDC's perspective, this study and our values tell us that California should pause and take the time to get this right, to put in place the long list of recommended actions the study calls for, and to ensure our communities and environment are protected from the threats of well stimulation and oil and gas production.
See more on the study from my colleague, Miriam, here.