Mike Middlebrook, petroleum engineer and Range’s Vice President of Operations

Question: “Throughout the process of drilling those wells and completing them and producing them in the summer of 2009, were there any problems or issues that developed in real-time as those wells were being drilled and completed and developed?” Answer. “Not at all. We had zero issues while drilling the wells. The completions went flawless. No problems whatsoever.” (pg. 20)

Q: “Prior to the issuance of the EPA order … did the EPA provide Range any data on which it based the December 7th order?” A. “No, they did not.” Q. “Prior to issuance of the December 7th order by the EPA, had Range been continuing to work with the Texas Railroad Commission on the investigation related to the Lipsky water well issue?” A. “Yes, we had.” (pg. 36)

Q: “Was there discussion about hydraulic fracturing in the meeting with the EPA?” A. “Yes.” Q. “What was the EPA’s response to that?” A. “Mr. [Chris] Lister [of EPA] acknowledged that hydraulic fracturing likely had nothing to do with it based on the distance of the Barnett Shale from the water aquifer, in this case over a mile.” (pg. 43)

Q: “Between December 16, 2010 and today, has Range been able to actually accomplish all of this testing, sample all those water wells and do all the gas testing and get the results back to be able to present here today?” A: “Yes, we have.” Q. “Has this protocol — or what does it cost to do all this?” A: “Extremely expensive … Almost unprecedented with the time frame and the dollars that we spent to do this work. In my 19 years I have never witnessed the kind of work that has gone on in the last 30 days.” (pg. 47)

Mark McCaffrey, Ph.D., geochemical gas fingerprinting expert

“We found that nitrogen … can be used to distinguish Barnett formation reservoir gas from Pennsylvanian Strawn reservoir gas. Specifically high nitrogen, low CO2 samples are characteristic of gasses produced from the shallower Pennsylvanian reservoirs. The natural gas component of the most recently collected Lipsky well headspace gas samples, which is the two that were shown in the previous table on the previous slide, contain higher nitrogen than is in Barnett gas.” (pg. 12)

“[The EPA order] does indicate that there is thermogenic [natural gas], but it doesn’t indicate that they are likely to be from the same source anymore than the presence of wings can tell you whether it’s a bat or a bird because the other sources also have the same carbon isotopic composition. It is not distinctive between the different sources. So it is not a basis for linking the Lipsky gas to the Range gas at all.” (pg. 39)

“[I]t’s hard to imagine a scenario by which the Barnett gas is migrating to the shallow aquifer and yet the bradenhead gas that is open to the whole — this thousands of feet of Pennsylvanian section, that bradenhead gas sample doesn’t contain Barnett gas. It clearly contains Pennsylvanian reservoir gas. It also … contains some bacterial gas as well, which is also not in the Barnett.” (pg. 27)

“[I]t calls into question any scenario whereby gas would be migrating from the Barnett up to a shallower aquifer. … The approach used by the EPA to correlate the Lipsky gas sample to Range Resources production was fundamentally flawed.” (pg. 31-33)

“[T]he two most recently collected Lipsky samples lay in the zone of higher nitrogen, indicating a Pennsylvanian [Strawn] origin. The sample that the EPA collected has lower nitrogen … Lipsky, two most recent samples, Pennsylvanian gas. Purdue well, the well closest to the Range wells, Pennsylvanian gas. The bradenhead of the Butler well, Pennsylvanian gas. How can it be that gas is migrating from the Barnett to this much shallower aquifer and yet all of these samples are showing up Pennsylvanian gas?” (pg. 28-29)

“[T]hey … indicate that both gasses are thermogenic in origin. If you were to stop there it is absolutely true. But then whoever wrote it says, ‘and likely to be from the same source.’ They can’t know that from the data they have. They can’t know that because they do not know if these parameters that they measured here would distinguish Barnett gas from shallower reservoirs. Therefore they have no foundation to say that — there is no support for saying that they are likely to be from the same source.” (pg. 37)Q. “Based on your study, based on the study undertaken by you and Dr. Kornacki, based on your over 20 years of experience in geochemical gas fingerprinting, did the EPA use a scientifically correct method to attempt to fingerprint the Lipsky gas as being sourced from either the Barnett Shale or from Range’s wells?” A. “No.” (pg. 40)

John McBeath, P.E., expert petroleum engineer

“Basically from the information we have in these wellbores, there is no evidence of faulting that could be — that could join up with a potential hydraulic fracture even if you could get past the physics of not having enough volume or enough pressure to reach all the way from the Barnett through a mile of rock up to the surface.” (pg. 5)

Q. “Do you have an opinion whether there is any scenario in which hydraulic fracturing could be a source for contamination in the freshwater wells in this area?” A. “With the facts that I have looked at, I have been able to rule that out also.” (pg. 6)

“I don’t see how [EPA]s order] can be justified … based on the actions that have gone on through the fall of 2010, and the ongoing investigation. So I am somewhat confused by that finding. I certainly don’t agree with it.” (pg. 16)

“I have concluded that the presence of gas in the Lipsky well and the other wells in the area is due to a natural connection between the Cretaceous and the Strawn that is probably exacerbated with the water wells being drilled either too deep.” (pg. 18)

READ MORE:

• Hearing Documents: Actual facts associated with Parker Co. wells
• Issue Alert: EPA MIA In Austin
• ICYMI: EPA Staff Acknowledge HF, Range Not to Blame for Parker Co. Wells