EPA’s Hydraulic Fracturing Research Related to Drinking Water Resources

The Natural Resources Defense Council (NRDC) appreciates the Environmental Protection Agency’s (EPA’s) scientific research work to examine the relationship between hydraulic fracturing and the risks and impacts to drinking water resources. NRDC also appreciated the opportunity to send representatives to the April and June 2013 Workshops on this topic. This letter responds to EPA’s request for additional information to be considered in the research efforts. Below we have provided a specific list of recommendations based on the scientific research work presented by EPA and its contractors at the April and June 2013 Workshops. 1. Hydraulic Fracture Model Type, Calibration, and Access. NRDC supports EPA’s efforts to independently model hydraulic fracturing (HF) scenarios and examine the risks and impacts to drinking water resources. EPA hired Lawrence Berkley National Laboratory (LBNL) to develop a three dimensional numerical, deterministic, multi-phase computer simulation model, based on first principles, using open source data. LBNL’s model uses the TOUGH model code. The LBNL model will not be a usable long-term product for industry, EPA, or the public because it requires access to proprietary software, must be run on a super computer, and will not have a user-friendly front-end built