Ten Important Things to Know from EPA’s 1,000-page Groundwater Study

Last week, the Environmental Protection Agency (EPA) released its long-awaited study on the relationship between groundwater and hydraulic fracturing, finding that fracturing technology has “not led to widespread, systemic impacts to drinking water resources,” as routinely claimed by oil and gas critics.

The assessment, originally requested in the form of an Appropriations subcommittee rider introduced by then-Rep. Maurice Hinchey (D-N.Y.), took five years, tens of millions of dollars, and hundreds of thousands of man-hours to complete. And coming in at nearly 1,000 pages in length, a lot of folks are still trying to figure out what the document actually says. Below, we identify just a few of the highlights that jumped off the page to us:

Fact #1: EPA greatly expands the definition of what “hydraulic fracturing” is for the purposes of its study, but still finds “no widespread, systemic impacts” to groundwater.

As an academic matter, EPA actually defines hydraulic fracturing correctly in the executive summary of the paper:

“Hydraulic fracturing involves the injection of fluids under pressures great enough to fracturing the oil- and gas-producing formations.” (ES-1)

That’s pretty much in line with the official definition you’ll find in Webster’s dictionary:

“[T]he injection of fluid into shale beds at high pressure in order to free up petroleum resources (such as oil or natural gas)”

But even after taking the time to properly cite and define the technology being studied, the agency goes on to explain that the scope of its examination includes processes and procedures used in oil and gas development that have nothing to do with fracturing technology at all.  As EPA explains in the report:

We defined the scope of this assessment by the following activities involving water that support hydraulic fracturing (i.e., the hydraulic fracturing water cycle; see Figure ES-2):

  • Water acquisition: the withdrawal of ground or surface water needed for hydraulic fracturing fluids;
  • Chemical mixing: the mixing of water, chemicals, and proppant on the well pad to create the hydraulic fracturing fluid;
  • Well injection: the injection of hydraulic fracturing fluids into the well to fracture the geologic formation;
  • Flowback and produced water: the return of injected fluid and water produced from the formation (collectively referred to as produced water in this report) to the surface, and subsequent transport for reuse, treatment, or disposal; and
  • Wastewater treatment and waste disposal: the reuse, treatment and release, or disposal of wastewater generated at the well pad, including produced water. (ES-3)

EPA picture

As this picture clearly shows, the only section of the report that deals with the actual process of fracturing a well is the injection section. But even that section encompasses (and, indeed focuses on) well-casing issues, which you’ll find in all sorts of different wells – whether they’re shale-related or not, or whether they’ve been fractured or not.

EPA also uses a significantly expanded definition for what constitutes “drinking water” – but at least it actually concedes that this definition is basically something it just made up. From the report:

“Drinking water resources are defined within this report as any body of ground water or surface water that now serves, or in the future could serve, as a source of drinking water for public or private use. This is broader than most federal and state regulatory definitions of drinking water and encompasses both fresh and non-fresh bodies of water.” (ES-3; emphasis added)

Of course, it was precisely this expanded scope that anti-fracturing activists have been pushing for from the very beginning. As a recent Senate Environment and Public Works Committee (EPW) report explains, despite a clear indication from Congress that the report be focused on the fracturing process itself, EPA forged ahead with a plan to widen the scope to include all parts of the oil and gas development process – hence the report coming in years behind schedule and millions of dollars over the original budget. The Senate EPW Committee report points to an email from an EPA official and member of the hydraulic fracturing study steering committee, which reveals that as of March 11, 2010:

“[The official] was successful (at least for now) in getting the most expansive scope definition. Still limited to drinking water, but would include the drawdowns of fresh water (surface, ground or utility supplied) used to make-up the frac fluids (2 to 7 million gallons a frac event), the fracturing process itself, and waste management issues like produced water handling, spills, waste pits that might impact surface or ground water sources.”

Why did EPA unilaterally decide to broaden the scope of the study, even given the clear orders delivered by Congress?  As a meeting summary from 2010 between EPA and environmental groups explains, anti-fracking groups:

“expressed concern that the study will not include all aspects of the HF and natural gas extraction process. EPA will use a lifecycle framework to organize the study. While a complete mass balance will most likely be beyond the scope of the study, EPA is currently planning to consider all stages of HF activities, including initial water withdrawals and waste storage and disposal.”

In other words, EPA bowed to the wishes of activists and significantly expanded the scope of the study, likely with an eye on increasing the odds of finding something negative to hang its hat on. Instead?  EPA spent five years and millions of dollars to study each and every aspect of the oil and gas development process, and still were not able to find anything resembling“widespread, systematic impacts” to groundwater.

Fact #2: Rare instances of groundwater impacts not even linked to the fracking process

While EPA found some isolated instances of subsurface water impacts, these events were not caused by the fracturing process itself.  Specific to the fracturing process, here’s what EPA actually has to say:

“[V]ertical separation between the production zone and drinking water resources protect drinking water.” (6-54)

It continues,

“When faults are present, relatively larger microseismic responses are seen during hydraulic fracturing, and larger fracture growth can occur than in the absence of natural faults for fractures. However, modeling studies indicate that fluid migration from deep production zones to shallow drinking water resources along natural faults and fractures or offset wells is unlikely.” (6-55)

There was initially some confusion in the press when Thomas Burke of the EPA’s Office of Research and Development described the study this way:

“‘The focus of our study was on wells that were fracked, but there is a narrow window in time where that fracking takes place. We looked far beyond that to look at the entire water cycle,’ Burke said, noting that there are instances where the process of fracking itself compromised well construction, which in turn led to surface water contamination.”

Burke was also quoted by the Washington Examiner as having told reporters “there are instances where the fracking activity itself have led to well construction problems that have led to water impact.” But when pressed on the issue, an EPA spokesperson pointed to an event in Killdeer N.D. “in which she said a pressure spike during injection at a well in Killdeer, N.D., ruptured casings that allowed fluids to escape to the surface.” But that event was widely documented to be related to a standard well-casing failure; it had nothing to do with hydraulic fracturing.

Another example cited in the report occurred in the Mamm Creek field in Colorado, where “inadequate cement placement in a production well allowed methane and benzene to migrate along the production well and through natural faults and fractures to drinking water.” As an independent review of that incident found, the event was caused by a casing issue and was “unrelated to [the] hydraulic fracturing process.” EPA also points to an incident in Bainbridge, Ohio, but EPA states in the report that it was “the result of inadequate cement” (6-20) and not due to the fracturing process – thus contradicting itself.

The official conclusion of the well injection section of the EPA report is also telling, as it focuses entirely on well-casing issues, not hydraulic fracturing:

“Fluids can migrate from the wellbore and surrounding subsurface formations due to inadequate casing or cement, and via natural and man-made faults, fractures, and offset wells or mines (see Text Box 6-5). To prevent fluid migration through the wellbore or through subsurface pathways, wells must have adequate casing and cement, and induced fractures must not intersect existing fractures or permeable zones that lead to drinking water resources. Evidence shows that the quality of drinking water resources may have been affected by hydraulic fracturing fluids escaping the wellbore and surrounding formation in certain areas, although conclusive evidence is currently limited.” (6-57)

Fact #3: Incidents of groundwater being impacted by development activities were “small”

EPA found the number of cases of groundwater being impacted by development activities to be “small.” To wit:

“Of the potential mechanisms identified in this report, we found specific instances where one or more mechanisms led to impacts on drinking water resources, including contamination of drinking water wells. The number of identified cases, however, was small compared to the number of hydraulically fractured wells.”(ES-6)

Of course, even if a well does experience elevated pressure, EPA concedes in the study that this doesn’t necessarily lead to water contamination.  From the report:

It is important to note that the development of one pathway within this system does not necessarily result in an impact to a drinking water resource. For example, if cracks were to form in the cement of a well, the vertical distance between the production zone and a drinking water resource (and the multiple layers of rock in between) could isolate and protect the drinking water aquifer if pressures were insufficient to allow fluid movement to the level of the drinking water resource. Conversely, if an undetected fault were present in a rock formation, intact cement within the production well could keep fluids from migrating up along the well to the fault and protect drinking water resources.” (6-51; emphasis added)

Fact #4: Directly contradicts oft-cited Ingraffea, Dusseault and Muehlenbachs well casing studies

Reports issued by well-known oil and gas critics Anthony Ingraffea, Maurice Dusseault, and Karlis Muehlenbachs on the prevalence of casing failures in oil and gas wells were evaluated by EPA, and even cited in the final report as studies the agency considered in arriving at its own conclusions with respect to well integrity. Despite giving those studies a thorough look, though, EPA still came out in the end with a determination that well-casing failures were exceedingly “rare” – a direct retort to activists who have made “well integrity” their top talking point.

Just as a refresher, Ingraffea is known for claiming that half of all shale wells “fail,” a conclusion to which he arrived by using data from what he called “industry documents” contained in another report that EPA also cites as “a study of wells in the Gulf of Mexico (Brufatto et al., 2003).” (6-14) This claim of high failure rates for well-casings was also made Muehlenbachs, who said, “The biggest problem is that half or more the [shale] wells drilled leak due to improper cement jobs or industry is not following best practices” based on that same Brufatto et al study.  Both Ingraffea and Muehlenbachs used Dusseault’s 2000 paper to back up their claims.

The Brufatto study contained a decade old chart produced by the U.S. Minerals Management Service (MMS) – a government agency which no longer even exists — that evaluated deep water oil and gas wells in the Gulf of Mexico, not onshore wells. Also, the data in that chart didn’t even have anything to do with “well failures” – rather, it plotted out events in which sustained casing pressure (SCP) was detected in a wellbore offshore.

The distinction is an important one: a well contains several redundant barriers that are designed to protect groundwater, while the inner casings are designed to protect against any potential issues inside the wellbore.  If an accumulation of pressure in a well is detected, such as SCP, it can affect one of the barriers – but even if one of these barriers fails, it doesn’t mean that the well’s integrity has been compromised, and it certainly doesn’t mean the well will leak. In fact, the “industry document” in the Brufatto study was a guide to the processes and technologies available to address and fix SCP if it were to occur in a well.

The 2014 Ingraffea paper that EPA cites uses the same faulty methodology of inflating well leakage by conflating it with SCP, when in reality, rates of wells actually leaking into the outside environment are a mere fraction of one percent of all wells drilled across the United States.

The bottom line is that if wells were failing at the astronomical rates Ingraffea, Dusseault and Muehlenbachs were claiming, EPA would have found that.  Instead, EPA concluded exactly the opposite – that the number of contamination cases is “small” compared to the tens of thousands of wells drilled every year in the United States.

Fact #5: Contradicts Duke water contamination studies

EPA also consults a number of studies produced by researchers who were at one time (or still are) affiliated with Duke University, such as Robert Jackson, Anver Vengosh, and Stephen Osborn.  These were studies that found thermogenic methane in drinking water resources, which the researchers blamed (sort of) on hydraulic fracturing. EPA references their research in this way:

“Multiple researchers (e.g., Jackson et al., 2013b; Molofsky et al., 2013; Révész et al., 2012; Osborn et al., 2011) have described biogenic and/or thermogenic methane in ground water supplies in Marcellus gas production areas, although the pathways of migration are generally not apparent.” (6-17) […] Flewelling and Sharma (2014) note that for migration to occur, an upward hydraulic gradient would be necessary, particularly for brine that is denser than the ground water in the overlying formations; in the case of natural gas, though, buoyancy would provide an upward flux (Vengosh et al., 2014).” (6-36)

Not only did EPA find no instances of the fracturing process contaminating water, it also made clear that the mere presence of thermogenic methane in water wells does not necessarily mean it came from shale formations – or otherwise had anything at all to do with development activities.  As EPA states, “pathways of migration are generally not apparent.”

Fact #6: EPA debunks activists’ water usage claims

In contrast to the frequently invoked claims of anti-fracking groups that shale development is rapidly depleting water resources, EPA finds that fracturing technology only accounts for a small percentage of overall water use.  From the report:

“Cumulatively, hydraulic fracturing uses and consumes billions of gallons of water each year in the United States, but at the national or state scale, it is a relatively small user (and consumer) of water compared to total water use and consumption.” (4-8; emphasis added)

EPA also finds that, in the vast majority of counties it studied, the amount of water required to support local oil and gas activity is less than one percent of the total amount of freshwater available for all uses. From the report:

“Overall, hydraulic fracturing water use represented less than 1% of fresh water availability in over 300 of the 395 counties analyzed (see Figure 4-5a). This result suggests that there is ample water available at the county scale to accommodate hydraulic fracturing in most locations.” (4-30; emphasis added)

Even the driest counties, where water usage for oil and gas development exceeds the amounts EPA considers “available,” can still obtain water from other sources to be used for hydraulic fracturing. The report goes on:

“In Texas counties with relatively high brackish water availability, hydraulic fracturing water use represented a much smaller percentage of total water availability (fresh + brackish +29 wastewater) (see Figure 4-5b). This finding illustrates that potential impacts can be avoided or reduced in these counties through the use of brackish water or wastewater for hydraulic fracturing; a case study in the Eagle Ford play in southwestern Texas confirms this.” (4-22)

Fact #7: No documented impacts to groundwater from spillage of fracturing fluids

EPA also looked at the chemical mixing process, which occurs when the fracturing crew prepares the water-based solution for delivery to the formation. Specifically, the report looked at 497 spill reports that were generated as a result of this process and found:

“No documented impacts to ground water from those particular chemical spills, though there was little information on post-spill testing and sampling” (5-71)

Fact #8: EPA says that literally tens of millions of Americans reside in proximity to hydraulically fractured wells – and concludes that they are safe

If hydraulic fracturing activities were only taking place in a few counties in Wyoming, the bar for determining whether the practice causes “widespread, systemic impacts” to the public’s drinking water would be set pretty low – mostly because, irrespective of how safe the technology actually is, not many people would be exposed to it.

But obviously, that’s not the case when it comes to modern shale development, which currently is being pursued in no fewer than 25 U.S. states. EPA acknowledges this fact, and goes to great lengths in its report to map-out all the places across the country where fracturing activities are taking place, as well as the many millions of Americans who reside relatively close by.   From the report:

“Millions of people live in areas where their drinking water resources are located near hydraulically fractured wells. While most hydraulic fracturing activity from 2000 to 2013 did not occur in close proximity to public water supplies, a sizeable number of hydraulically fractured wells (21,900) were located within 1 mile of at least one PWS source (e.g., infiltration galleries, intakes, reservoirs, springs and ground water wells). Approximately 6,800 sources of drinking water for public water systems, serving more than 8.6 million people year-round, were located within 1 mile of at least one hydraulically fractured well. An additional 3.6 million people obtain drinking water from private systems in counties with at least one hydraulically fractured well and in which at least 30% of the population is reliant on private water systems.” (3-11)

By finding “no widespread, systemic impacts” to groundwater, EPA’s report shows that there’s no credible threat to the drinking water of the “millions of people” who live near shale wells.

Fact #9: Anti-fracking activists claim of “industry influence” debunked

Back in March, anti-oil and gas groups like the NRDC and InsideClimate News (ICN) began a preemptive campaign aimed at downplaying the forthcoming EPA report, mostly because they were afraid of what it would actually say. Playing a classic game of lowering-expectations ahead of the study’s release, they attempted to push the narrative that “industry influence” was responsible for watering-down a report that they hadn’t even read yet.  As Wenonah Hauter of Food & Water Watch claimed at the time,

“Sadly, the EPA study released today falls far short of the level of scrutiny and government oversight needed …’ This reveals the undue influence the industry has over the government and shows that the industry is afraid to allow careful monitoring of their operations.”

But, as Politico reported,

Thomas Burke, EPA’s deputy assistant administrator for research and development, denied charges by multiple green groups that drillers had deliberately stymied the study by withholding key data. The agency had “a generally very cooperative relationship with industry” over the course of its research,” Burke told reporters.” (emphasis added)

National Journal also reported,

“Burke added that the EPA had a ‘generally very cooperative relationship’ with the industry, which he said was a ‘major source of information.’”

So much for that.

Fact #10: This is easily the most comprehensive study on hydraulic fracturing to date

As EPA’s Thomas Burke said in a press release,

“It is the most complete compilation of scientific data to date, including over 950 sources of information, published papers, numerous technical reports, information from stakeholders and peer-reviewed EPA scientific reports.”

The study text itself explains the sheer breadth of the research that was conducted here:

“The EPA used a broad search strategy to identify approximately 3,700 sources of scientific information that could be applicable to this assessment. This search strategy included both requesting input from scientists, stakeholders, and the public about 1 relevant data and information, and thorough searching of published information and applicable data.” (1-6 to 7)





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