*UPDATED* EPA Progress Report on Hydraulic Fracturing Reveals Obvious, Little Else
The EPA has issued a 278-page progress report on its gigantic hydraulic fracturing study due for completion in 2014 or thereabouts. The interim report offered a multitude of words one assumes are intended to obscure the ultimate direction of the report. Nonetheless, there are some interesting aspects to the report and, to be fair, the agency seems to be trying to ensure the appearance of objectivity.
UPDATE: Some of our readers have suggested additional concerns with the EPA study. They note there were EPA roundtable discussions in November preceding the release of the progress report at which special invitees included several known natural gas opponents such as Dr. Tom Myers, Dr. Glenn Miller, Brianna Mordic (NRDC), Hugh MacMillan (Food and Water Watch), Wilma Subra and many others such Amy Mall of NRDC, who has published some of the most egregious material on shale gas exploration. If this is any indication of how EPA plans to populate the ad hoc scientific advisory panel, then there is a chance junk science will rule the day, unless true industry experts are also represented in sufficient numbers. Unfortunately, the current candidate list is also deep in individuals with narrow experience, many of whom have previously made grave conclusion errors and some who are even categorically opposed to hydraulic fracturing and natural gas development in general under any regulatory scheme. These include Avner Vengosh, Anthony Ingraffea, Robert Howarth and Tracy Bank to name just a few. Their biases are both extreme and well-known, Ingraffea, for example, has said “The economics of shale gas are known to be boom and then bust. It will be a few months of prosperity for some and then generations of health and environmental impacts for everybody else. Natural gas is simply not worth it.”
Also, it appears from the PowerPoint presentation given at the roundtable, that EPA is going to rely on a yet-to-be perfected simulator designed by Lawrence Berkeley National Lab. Readers tell us this lab clearly lacks industry expertise or experience and unless it plans to engage industry experts that are already well versed in and have already developed such modeling software, the results are likely to be more junk science. Industry involvement is needed to build realistic models, interpret results properly and test the “new” simulator against existing simulators that are in common use in industry today. This is a very ambitious task for the EPA time line, especially considering the make-up of the current hydraulic fracturing SAB board that doesn’t have a single person with experience in this area. Worse, some the potential pathways identified in the progress report as examples to be tested border on the absurd as we have noted below.
The EPA’s Study of the Potential Impacts of Hydraulic Fracturing on Drinking Water Resources – Progress Report was released this past week to much anticipation in some quarters. The EPA has a very mixed track record that wildly swings from the sublime to the ridiculous and back again. The embarrassing actions of the agency in Pavillion and Parker County and its political collaboration with EarthJustice and the like in regard to the Marc-1 Pipeline, all suggest an out-of-control bureaucracy, at least at the regional level. Lisa Jackson, its Administrator, on the other hand has been a model of reasonableness and propriety when it comes to hydraulic fracturing, careful to note there is no definitive determination the process has ever polluted a water supply and offering her views the states should do most of the regulating and are doing a good job already.
Perhaps no case demonstrates the EPA split personality better than Dimock, where the Philadelphia Regional Office abused the Superfund process to conduct redundant testing and even trucked in water while it did its tests, all on the apparent word of a handful of litigants who manipulated events. The Regional EPA, in taking these actions, also rejected the word of Pennsylvania’s DEP and independent testing laboratories as it pursued what everyone with any real knowledge of the case knew was a fool’s errand. Rushing in where angels feared to tread, it conducted an extensive investigation that, in the end found Pennsylvania DEP had it right all along.
This dualism is reflective of political reality. EPA has some great staff and, it appears, an honorable Administrator committed to science. Its regional directors? Well, not so much. They are political appointees with political agendas, as Al Armendariz demonstrated so effectively. Fortunately, the EPA hydraulic fracturing study is being run from Washington, D.C. and not the regional offices. The progress report reflects this. It doesn’t offer anything much new, but a review indicates the agency is, for now, approaching the task more scientifically than politically. As reassuring as this is, though, there are still some issue that suggest continued concern is warranted.
Let’s take a look at some of what may be found amidst those 278 pages.
The paragraph making the greatest impression on me was described the agency’s study approach to the Bradford County area (which includes western Susquehanna County and Dimock, one of five case studies being pursued). It reads:
Naturally high levels of TDS, barium, and chloride found in ground water make it difficult to assess the potential impacts of hydraulic fracturing activities in this part of the country since these analytes would normally serve as indicators of potential impacts. In addition, methane occurs naturally in ground water in the study area, making an assessment of potential impacts of methane due to hydraulic fracturing on drinking water resources more challenging than at other study locations. (Page 145)
This is an encouraging sign EPA learned from Dimock. The little community with the name known throughout the world is, in fact, only mentioned once in the entire report – in a footnote indicating the following:
Soon after, EPA Region 3 began an investigation of potential drinking water contamination in Dimock, located in Susquehanna County. In order to avoid duplication of effort, this case study focuses on reported changes in drinking water quality in Bradford County. Subsequent sampling for this case study has been, and will continue to be, done in Bradford County. (Page 143)
Exactly what this means is unclear, but it appears EPA intends to work its Dimock results into the overall analysis in some fashion. It also indicates EPA’s experience in Dimock has led it to realize nothing can be determined with any certainty absent baseline testing, which is, exactly what was so lacking in that instance and led to the controversy there. Trying to assess the impacts of hydraulic fracturing or other aspects of natural gas development without a baseline to compare post-development results is like trying to evaluate your golf game with no par.
This is, no doubt, why EPA is stressing Bradford County where there is some significant baseline testing that occurred prior to development. The following table, for example, is included in the progress report and summarizes some findings from a 1998 study entitled Hydrogeology and Groundwater Quality of the Glaciated Valleys of Bradford, Tioga, and Potter Counties, Pennsylvania by the U.S. and Pennsylvania Geological Surveys.
It is encouraging to see this data being examined by EPA. It is a strong indication objective science is being taken into account and a hopeful sign the hysteria that has pervaded hydraulic fracturing discussion in so many quarters will not rule the day with this study.
There are other encouraging signs as well. The progress report notes the study will not only include case studies of existing areas with natural gas development, but also prospective case case studies that follow development from beginning to end, described as follows (emphasis added):
The EPA continues to work with industry partners to begin research activities at potential prospective case study locations, which involve sites where the research will begin before well construction. This will allow the EPA to collect baseline water quality data in the area. Water quality will be monitored for any changes throughout drilling, injection of fracturing fluids, flowback, and production. Samples of flowback and produced water will be used for other parts of the study, such as assessing the efficacy of wastewater treatment processes at removing contaminants in hydraulic fracturing wastewater. (Page 3)
This collaborative approach extends to working with state agencies such Pennsylvania DEP and several individual companies. EPA is also including the FracFocus database in the analysis. Once again, this common sense consultation with the industry as a source of data and expertise, suggests the study is, in fact, a search for the facts. The term “industry partners,” combined with the serious data gathering taking place indicates the study is an attempt to learn as much as possible with no obvious bias. This is reinforced by statements such as this one that go a long way toward dispelling the wild accusations coming from natural gas opponents:
Chemical entries in FracFocus that contained “CBI,” “proprietary,” or “trade secret” as an ingredient were only 1.3% (3,534 of 277,029) of all chemical ingredients reported in FracFocus. (Page 61)
Notwithstanding all this, there are also causes for concern in the progress report.
While the progress report acknowledges recycling of flowback and produced water is taking place (on page 104), for example, there are also troubling figures and statements such as the following:
As depicted in Figure 8, the wastewater is typically stored onsite in impoundment pits or tanks.
This figure and accompanying statement suggest wastewater impoundment pits are still standard best management practice for the industry when they are not – recycling is. We have noted here the fact several companies now recycle up to 100% of their flowback and produced water. The EPA is clearly behind the curve on this one and the fact it is could indicate a desire to simply encourage a “faster please” approach that will be part of its final recommendations, having already been addressed by the industry. One hopes so.
There is also a disconcerting emphasis on computer models and scenarios suggesting things that have never happened and which are only figments of imagination in the minds of natural gas opponents. These are spelled out in Chapter 4, complete with illustrations that are likely to become fodder for anti-gas articles where they are presented as fact and not speculation. Here is one of the scenarios, for instance:
Fracturing of the overburden because inadequate design of the hydraulic fracturing operation results in fractures allowing fluid communication, either directly or indirectly, between shale gas reservoirs and aquifers above them. Indirect communication would occur if fractures intercept a permeable formation between the shale gas formation and the aquifer. Generally, the aquifer would be located at a more shallow depth than the permeable formation.
There is, as the EPA and several states have already stated, no evidence this has ever occurred and much evidence, even in the progress report itself (see page 253), that it could not. So, why is it being studied? It will only give credence to the impossible or extremely unlikely and, even if the study ends up saying this, it will still be met with “what if” questions by those determined not to accept facts.
More to the point, how does the EPA expect to develop a computer model for this, if there is no evidence to work with that would ensure the model is capable of predicting backward as forward? History is now full of examples of computer models that failed to predict forward because they were never tested backward to evaluate whether the model would have predicted what we know occurred. Paul Erlich, who has made a career with one failed Malthusian prediction after another comes to mind, even losing real money betting on them.
The EPA penchant for computer models is no substitute for the actual record (which is better than good with hydraulic fracturing) and that is a real problem with the approach being taken. Nevertheless, the agency is apparently looking at the real data as well and that helps.
Where does this leave us? Well, it is genuinely difficult to know. There is, on the whole, more that is good about this study than bad, but it will impact an entire industry, the economy and our energy future for the sake of a problem no one has been able to document. We are, nevertheless, beyond the point of arguing whether the study is necessary or not. It’s happening. Will it turn out based on science? I’m betting it will, but I’m also of the “trust, but verify” persuasion. So, the answer is simply this; we’ll see.