The State Water Resources Control Board (“Water Board”) has recently released recommendations from the Lawrence Livermore National Laboratory (“LLNL”) on Model Criteria for Groundwater Monitoring. Pursuant to Senate Bill 4 (“SB 4”), the Water Board is required to develop regulations for sampling, testing, and monitoring groundwater during hydraulic fracturing operations. The bill requires groundwater monitoring at scales from single well monitoring to regional monitoring.
The recommendations are designed to assist the Water Board in taking a scientifically credible approach in developing groundwater monitoring regulations. The authors acknowledge the immense challenge of developing a set of regulations to govern well stimulation in California due to the unique and dynamic nature of each oil field.
The report recommends a tiered approach to groundwater monitoring where higher quality water is monitored more intensively than lower quality water. The monitoring would be conducted through one upgradient and two downgradient wells within a one-half to one-mile radius of the stimulated oil well.
Under the framework proposed by the LLNL, groundwater would be analyzed on a tiered basis, with additional testing required only when potential impacts to water quality are observed. Sampling would occur before hydraulic fracturing and then semi‐annually for at least three years after the well stimulation.
The report cites multiple studies across several states analyzing the impacts of hydraulic fracturing on groundwater contamination. The report found that “none of the studies could directly link the elevated levels of measured contaminants to the use of well stimulation technologies.”
The LLNL report comes on the heels of a recently released EPA study, which found no signs of “widespread, systemic” drinking water pollution from hydraulic fracturing.