A few years ago, the Environmental Protection Agency announced it would conduct the first ever comprehensive study of the risks to drinking water from hydraulic fracturing. As part of the study, EPA has been holding a series of stakeholder workshops to provide updates and get feedback on its progress. NRDC representatives have participated in several of these workshops over the past year or so, and after doing so we have serious concerns about several fundamental aspects of the current approach the agency is taking.
We sent a letter to the EPA today, outlining those concerns. In short, we believe that the current scope of the study is too narrow to address the full range of risks that fracturing poses to drinking water. This means that the study as currently planned may fail to fully answer the question of whether or not hydraulic fracturing poses risks to Americans’ drinking water supplies and, if so, what those risks may be.
This is the latest in a troubling pattern we’ve seen in EPA’s scientific work on hydraulic fracturing and water contamination. In the past two years the agency dropped three high-profile water contamination investigations– in Dimock, PA, Pavillion, WY, and Parker County, TX . The American people must have confidence that the EPA can fulfill its mission, which includes ensuring that “all Americans are protected from significant risks to human health and the environment where they live, learn and work.” This includes addressing these serious shortcomings in the scope of their study.
Specifically, a key piece of the study is the construction of a computer model to simulate various ways that fracturing can possibly impact drinking water. We have several concerns about the current plans for this modeling:
- Industry is withholding critical data: The scientists creating the model haven’t been able to get access to actual field data to calibrate the model. This is because the oil and gas industry has so far refused to provide such data. Comparing the model inputs and results to actual measured data is a key step in the model building process that can’t be skipped. NRDC recommends that EPA ask industry to provide this data.
- The Marcellus Shale is the only geological formation being modeled: The model will only look at hydraulic fracturing in the East Coast’s Marcellus Shale. However, fracturing is also used in tight sandstones, coalbed methane, and other shale formations all across the country – from Texas to North Dakota and California. The risks in these other types of formations may be different. In order to assess the full range of risks to drinking water, EPA should model fracturing in other shale types as wells as in tight gas and coalbed methane formations.
- Important risk pathways are left out: EPA is modeling five different scenarios for how fracturing could impact drinking water. While we support these scenarios, there are also others that EPA has left out that are important to fully understanding the risks. These include modeling scenarios where the wells have been improperly constructed, where fracturing fluids are injected directly into drinking water (as is the case for coalbed methane wells), fracturing in older wells that may be corroded, and others. It is crucial to understand the risks not only under the best conditions, but also when things go wrong.
- Access for independent reviewers may be limited: The model will be constructed using proprietary software. This may limit the ability of others – such as academics or even EPA itself – to use and independently verify the model. NRDC believes that it is very important for EPA to develop a modeling tool using computer codes and systems that are available to a broad range of scientists and engineers.
We’re also very concerned that EPA is only looking at wells and sites that use best practices, rather than examining the whole range of practices that different operators use, and that may pose different levels of risk to drinking water.
To date, a comprehensive and independent study of the potential risks of hydraulic fracturing to drinking water supplies does not exist. This EPA study has the potential to be just that, and help fill this critical knowledge gap. In order for that to happen, though, this must be conducted using the highest scientific standards. It is essential that EPA fulfill its own stated intent “to better understand any potential impacts of hydraulic fracturing on drinking water and ground water.” Fulfilling this goal of creating a comprehensive study is crucial to ensuring the public that all risks have been examined.