Energy in Depth Responds to Stanford Study on Fracking
Energy in Depth, an industry-backed site, has posted an article about this study. Below you can read it in its entirety.
New Stanford Study Confirms No Contamination from Fracking, “Shallow” or Not
by Dave Quast, Energy in Depth
Researchers led by Rob Jackson of Stanford University recently released a study in the journalEnvironmental Science and Technology that suggests that shallower wells could pose more risk to groundwater than deeper ones. (You may recall Dr. Jackson from previous fracking-related work he did while at Duke University.)
In the Stanford study, Dr. Jackson and his coauthors found no evidence of the fracking process contaminating groundwater, which is consistent with studies released in the past several weeks by the Environmental Protection Agency (EPA) and the California Council on Science and Technology (CCST).
According the report’s press release:
“Using innovative techniques such as isotopic “tracer” compounds that distinguish the source of chemicals in well water, Jackson has not found evidence that frack water contaminants seep upward to drinking-water aquifers from deep underground.”
The researchers simply claim there are potential risks from shallower wells, but they do not provide convincing evidence that these risks are plausible. Further, existing evidence from other studies, and from 65 years of practical experience, do not support such a conclusion.
Fact #1: Landmark studies find no contamination from shallower wells
The researchers claim,
“Using 44000 observations of hydraulic fracturing depths reported to FracFocus between 2008 and 2013, we address three questions: (1) What are the range of depths and water use for hydraulic fracturing across the United States?; (2) In which states and at what locations has the shallowest high-volume hydraulic fracturing occurred?; (3) What policy protections are or might be put in place to minimize the risk of direct contamination of drinking water from hydraulic fracturing?” (Stanford Study, Page B)
The study, then, assumed a greater risk of water contamination based on well depth. However, the most recent existing peer-reviewed study involving fracking and water quality is one the Stanford authors cite – a peer-reviewed report by the independent California Council on Science and Technology (CCST), which was released in the last few weeks. The study notes among other things that approximately half of the hydraulically fractured wells in California were found at depths less than 2,000 feet from the surface.
The CCST study then clearly states that even shallow wells have not been contaminated:
“We found no documented instances of hydraulic fracturing or acid stimulations directly causing groundwater contamination in California.” Page 52 [Emphasis added]
Another landmark national study drew the same conclusion earlier this month. The U.S.Environmental Protection Agency (EPA) conducted its own comprehensive, five year study on wells around the country, including the shallowest hydraulic fractured wells: those involving coal-bed methane (CBM).
The EPA concluded:
“From our assessment, we conclude there are above and below ground mechanisms by which hydraulic fracturing activities have the potential to impact drinking water resources…We did not find evidence that these mechanisms have led to widespread, systemic impacts on drinking water resources in the United States.” (ES-6) [Emphasis added]
Well depths of the investigated areas were as shallow as 350 feet, and seven of the major coal basins had depths lower than 1,000 feet.
This confirms a 2004 EPA study specifically related to shallow CBM wells that concluded:
“Based on the information collected and reviewed, EPA has concluded that the injection of hydraulic fracturing fluids into [CBM] wells poses little or no threat to USDWs [underground sources of drinking water] and does not justify additional study at this time.” (Section 7.4)
Whether in extra-shallow CBM wells or much-deeper shale wells, we would know about anyproven links between fracking and water contamination if they existed, not least because anti-industry activists would trumpet them from the proverbial (or perhaps literal) rooftops. As it happens, when asked at a U.S. Senate hearing by Sen. Mary Landrieu (D-LA) to name a specific instance of fracking contaminating groundwater, representatives of the Sierra Club and the Natural Resources Defense Council were unable to do so.
Fact #2: Hydraulic fracturing accounts for a fraction of one percent of total water use
The researchers claim,
“Water use for hydraulic fracturing varied widely among states. The average water volume used to hydraulically fracture a well in the United States was 2,400,000 gallons (9,200,000 L). Five states with the highest reported water use per well between 2010 and 2013 were Arkansas (5,200,000 gallons), Louisiana (5,100,000 gallons), West Virginia (5,000,000 gallons), Pennsylvania (4,500,000 gallons), and Ohio (4,300,000 gallons). States with the lowest average 243 water use for hydraulic fracturing included Alabama (38,000 gallons per well), Virginia (42,000 gallons), California (158,000 gallons), and Utah (382,000 gallons)…Surprisingly, the volumes of water and chemicals used for shallower hydraulic fracturing 263 were indistinguishable from those used for deeper wells.” (Stanford Study, Page D) [Emphasis added]
Importantly, the study notes that:
“Several recent reports examining hydraulic fracturing have concluded that surface activities, particularly spills, and near-surface activities via well integrity provide the greatest potential risks for groundwater, but their risks could be managed with proper safeguards.” (Stanford Study, Page B)
The most plausible causes of sporadic contamination, then, are already heavily regulated, easily mitigated and not related to well depth.
The authors of the Stanford study examined water used for fracking across the country, and it is a useful summary. However, the implication is one that is made frequently by activists: that fracking uses a “large” amount of water. Hydraulic fracturing does not, in fact, use much water compared to most other commercial water uses. As EPA notes:
“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)
Also:
“Overall, hydraulic fracturing water use represented less than 1% of fresh water availability in over 300 of the 395 counties analyzed. This result suggests that there is ample water available at the county scale to accommodate hydraulic fracturing in most locations.” (4-30) [Emphasis added]
It would be natural to assume that California, with its major drought, might be an exception to this, but with exceedingly low water use for fracking (0.00062 percent of the state’s freshwater withdrawals – equivalent to about 500 households) the impact is negligible, especially given that the industry produces 31,000 acre-feet of water that is put to productive use by the agriculture industry to mitigate the impact of the drought.
Fact #3: Oil and gas producers are not “exempt” from federal laws
The authors make the mistake of repeating the falsehood that fracking was “exempted” from the Safe Drinking Water Act (SDWA) in 2005, when in fact it was never previously covered. The SDWA became law in 1974, many decades after the regular use of fracking, and the Act has been silent on the subject.
This is because the EPA has always ceded regulatory responsibility for the practice on the individual states given their disparate geologies, which is pretty smart, as far as we are concerned. The reason fracking became an issue in 2005 was because activists were trying to change this regulatory framework and get EPA to regulate fracking at the federal level so lawmakers sought to make the status quo clear: fracking has been effectively regulated by the states and this should continue.
Of course, the notion that an industry as complex and important as the energy industry would be “exempt” from federal regulation is absurd on its face.
In 2012, the independent Government Accountability Office (GAO) report made crystal clear that oil and gas development – including “unconventional” development – falls under the authority of (at least) eight major federal regulations. From that report:
“As with conventional oil and gas development, requirements from eight federal environmental and public health laws apply to unconventional oil and gas development. For example, the Clean Water Act (CWA) regulates discharges of pollutants into surface waters. Among other things, CWA requires oil and gas well site operators to obtain permits for discharges of produced water – which includes fluids used for hydraulic fracturing, as well as water the occurs naturally in oil- or gas-bearing formations – to surface waters. In addition, the Resource Conservation and Recovery Act (RCRA) governs the management and disposal of hazardous wastes, among other things.”
The report then cites specific federal environmental and public health laws that govern the development of oil and gas, including:
- Safe Drinking Water Act (SDWA) (for disposal wells)
- Clean Water Act (CWA)
- Clean Air Act (CAA)
- Resources Conservation and Recovery Act (RCRA)
- Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA)
- Emergency Planning and Community Right-to-Know Act (EPCRA)
- Toxic Substances Control Act (TSCA)
- Federal Insecticide, Fungicide and Rodenticide Act (FIFRA)
In addition to these federal regulations, of course, operators also have to comply with a tapestry of state and local laws. For example, in the City of Los Angeles, operators are under the jurisdiction of 18 regulatory entities.
Doesn’t look too “exempt” to us.
Much ado
The Stanford study makes policy recommendations based on its data analysis and concern about shallow wells:
“In summary, our analysis suggests that additional safeguards would be beneficial if shallow hydraulic fracturing continues in the future. Few states provide additional oversight or data transparency regardless of how shallow the fracturing occurs, even for high volume hydraulic fracturing. To protect people, the social license to operate for companies, and current and future sources of drinking water, the possibility of contamination from shallow hydraulic fracturing should be acknowledged in the best practices and rules governing it.” (Page G)
But if the potential impacts the authors identify were valid, wouldn’t they have materialized in the 65-year history of routine hydraulic fracturing in the United States?
The bottom line is that scientists and regulators continue to confirm that hydraulic fracturing has not led to significant concerns about groundwater contamination, and this is irrespective of well depth.
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