An Investigation to Determine the Risks to Underground Sources of Drinking
Water Associated with the Hydraulic Fracturing of Coalbeds for Methane Gas

                      Document No. EPA816-K-00-007

                           Prepared by the

             United States Environmental Protection Agency
                    Office of Ground Water and Drinking Water
                         Washington, D.C. 20460
                            July 24, 2000


Study Design
(1) Incidents
(2) Potential Risks
(3) Regulations and Legislation

Study Design for Evaluation of Risk to Ground Water
from Hydraulic Fracturing of Coalbeds for Methane
The Environmental Protection Agency (EPA) will conduct a study of the environmental risks
associated with hydraulic fracturing. The study will focus first on hydraulic fracturing of
coalbeds for enhancing methane production. EPA may later study a wider universe of hydraulic
fracturing if information collected during this study indicates further investigation is warranted.
EPA is initiating this study because we have received reports from citizens of contamination of
their ground water-supplied drinking water wells, and ground water loss which they believe to be
the result of nearby hydraulic fracturing of coalbed methane(CBM) gas production wells.
EPA intends to evaluate the potential and actual (as defined by incident rates) risks associated
with this type of hydraulic fracturing. EPA will also survey existing State regulations and
investigate industry practices to determine if the current regulatory structure (if present) is
sufficient to protect against environmental damage that could result from hydraulic fracturing of
Prior to 1997, EPA’s understanding of its authority under the SDWA concerning the regulation
of hydraulic fracturing was that the Agency believed that such a production well stimulation
process did not fall under the UIC program’s purview. This understanding was held by EPA
during the promulgation of UIC regulations in the early 1 980s. But in 1994, the Legal
Environmental Assistance Foundation (LEAF) - a Florida based environmental interest
organization - challenged that interpretation by petitioning EPA to withdraw Alabama’s EPA-
approved Section 1425 (SDWA) UIC program. LEAF, prompted by its membership, believed
the State should regulate hydraulic fracturing for coalbed methane development as underground
injection because they alleged a case of drinking water well contamination in Alabama. This
case was investigated and findings from State and Federal agencies determined that nearby CBM
production was not at issue. Therefore, EPA denied LEAF’s petition a few years later.
However, LEAF litigated and in August 1997, the 11 th Circuit Court of Appeals ruled that
hydraulic fracturing of coalbeds for methane gas recovery in Alabama should be regulated under
the SDWA as an underground injection ( LEAF v. EPA , 11 8F. 3d 1467). After appeals by EPA
were denied by the Court, the LEAF petition was remanded to EPA and a schedule was
established for the Agency to either withdraw the program or require the State to regulate CBM
hydraulic fracturing accordingly. The State chose to modify its UIC program, and in December
1999, EPA approved this revision and published a final rule doing so in the Federal Register
(January 2000).
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But, during the 1 1 th Circuit Court’s deliberations, EPA received several verbal phone calls and
written correspondence from other environmental interest groups, who also alleged that practices
associated with methane gas production from coalbeds had resulted in contamination and/or loss
of water from underground drinking water well sources. Because of these communications, and
because the frequency of coalbed methane development is rapidly escalating, EPA determined it
would be in the public interest to evaluate the risks to underground sources of drinking water
associated with hydraulic fracturing. Congressional, State, and industry interest in this issue has
grown significantly, and public opinion on the practice of coalbed methane gas production has
polarized various interest groups. EPA believes that the proper action it must take would first
involve an appropriate level of data and information collection regardng this is sue, in order to
make further decisions concerning the potential regulation of hydraulic fracturing.
Study Design
EPA will conduct the study in three parts: (1) investigation of incidents; (2) evaluation of
potential risk based on the geology of the areas likely to be developed for coalbed methane, best
available technology for planning and conducting fracturing jobs, and common industry
practices; and (3) survey of existing regulations and legislation. A more detailed discussion of
these parts of the study follows.
(1) Incidents:
The current study will estimate contamination and water loss incidents associated with hydraulic
fracturing through interviews with State and local agencies responsible for drinking water
protection, citizens, and industries performing hydraulic fracturing.
• Survey public health agencies in charge of drinking water quality in States where
hydraulic fracturing is practiced frequently. This survey will serve as a follow-up to the
Ground Water Protection Council’s 1998 survey of State Oil and Gas Boards to
determine if public health agencies are aware of incidents of water contamination or loss.
• Conduct interviews with citizens and/or public health officials. During these interviews,
EPA will attempt to collect information which may help link a physical mechanism to an
alleged incident.
• Request list and descriptions of incidents from industry. EPA believes individuals
- working in the industry are likely to have information on water contamination and/or loss
incidents that may have occurred due to hydraulic fracturing, since one line of recourse
for resolving problems is to contact the producing company.
• Secure and review O&G records of reported incidents. EPA will request that State Oil
and Gas Boards allow us to review records on any incidents we believe have not been
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EPA intends to rely on field tests performed as part of other studies such as those performed in
the San Juan Basin and the Alabama Black Warrior Basin. Depending on the findings from our
investigation, EPA may perform field tests to research the association between fracturing and
incidents of water contamination and/or loss.
(2) Potential Risks:
EPA will perform a literature review of fracturing technology and geology in areas developed for
methane production and conduct site visits to gather information on hydraulic fracturing
practices. We will assimilate information to evaluate the potential risks posed by hydraulic
fracturing of coalbeds in areas likely to be developed for methane gas production.
• Literature review of fracturing technology. The literature review will include technical
aspects of fracturing theory, modeling, mechanics, fluid composition, and chemical
interactions likely to result after fluid leakoff.
• Literature review of instrumentation technology. The current available technologies for
measuring fracture areas and the strengths and limitations of the technologies will be
characterized. EPA will review any fracturing records that are offered by industry.
• Literature review of geology and hydrogeology. The literature review will include the
geology and hydrogeology for each region of the country with methane reserves.
Specifically, we will identify:
-the locations within the U.S.
-underlying geology and hydrogeology
-current and future water usage
-underground sources of drinking water (USDW)
-water quality data
-coalbed methane well location strategies
-water well locations
N Site visits. EPA will attempt to visit sites during hydraulic fracturing events and
interview individuals who are or have been involved in hydraulic fracturing work. These
site visits and interviews are intended to characterize field practices for implementing
hydraulic fracturing.
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(3) Regulations and Legislation:
State and local regulations. EPA will survey States to collect what regulations pertaining to
coalbed methane development are in place. EPA will review and summarize the regulations.
This current study will identif r and characterize the risks underground sources of drinking water
associated with hydraulic fracturing of coalbeds for methane production.
R p tt
EPA will produce a report presenting all the data collected during the study, methods of data
analysis, methods of risk characterization and our conclusions regarding the risks associated with
hydraulic fracturing of coalbeds for methane production.
This study will evaluate hydraulic fracturing of coalbeds, however, EPA will also consider
experiences with hydraulic fracturing associated with other types of production. EPA may later
study a wider universe of hydraulic fracturing if information collected during this study indicates
further investigation is warranted.
EPA’s timeline for completing the study is shown below.
Timeframe Event
August 2000 Stakeholder comments on EPA’s study
Fall 2000 Site visits
Fall 2000 Survey to public health agencies responsible for
groundwater protection
Fall 2000 Review SDWA documents
Fall 2000 to Winter 2001 Collect and analyze information offered by industry
Winter 2001 Survey State agencies for State and local regulations
Fall 2000 to Spring 2001 Literature reviews
Spring 2001 Review existing studies, characterize risks
Summer 2001 Prepare Report
Fall 2001 Draft report available for comment
Win ter 2002 Final report
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