PROPOSED COALBED METHANE STUDY DESIGN

An Investigation to Determine the Risks to Underground Sources of Drinking

Water Associated with the Hydraulic Fracturing of Coalbeds for Methane Gas

Recovery

Document No. EPA 816-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
TABLE OF CONTENTS

Background

................................................................ 1

Study Design

................................................................ 2

(1) Incidents

................................................................ 2

(2) Potential Risks

................................................................ 3

(3) Regulations and Legislation

................................................................ 4

Report

................................................................ 4

Schedule

................................................................ 4
Page 1 of 4

Study Design for Evaluation of Risk to Ground Water 

from Hydraulic Fracturing of Coalbeds for Methane

Production

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 coalbeds. 

Background

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 1980s. 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 11th 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, 118F. 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).
Page 2 of 4

But, during the 11th 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 issue, 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 resolved.
Page 3 of 4

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

-population

# 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.
Page 4 of 4

(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 identify and characterize the risks underground sources of drinking water associated with hydraulic

fracturing of coalbeds for methane production. 

Report

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. 

Schedule

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

Winter 2002 Final report