Researchers from GSI Environmental recently published a comment in Environmental Science and Technology, explaining that a 2016 report suggesting that oil and natural gas production contaminated water wells in Pavillion, Wyoming, is based on faulty data.

That 2016 study was actually conducted by Dominic DiGiulio and Robert Jackson of Stanford University – and importantly DiGiulio was also an author of the Environmental Protection Agency’s (EPA) Pavillion study, which has been thoroughly discredited by state and federal regulators (more on that in a bit), but was used as a rallying cry for activists determined to ban fracking across the nation.

DiGiulio and Jackson claim in their study to “have, for the first time, demonstrated impact to USDWs as a result of hydraulic fracturing” based on data from EPA’s now infamous pair of monitoring wells in Pavillion.  But GSI Environmental finds that the available chemical data in these two wells do not indicate such impacts.  Here’s how they explain it:

“The data show that water wells in this area do not exhibit impacts from hydraulic fracturing activities, as there is no significant difference in the water quality of water wells located near to and far from the gas production wells. Furthermore, comparison of the two monitoring wells shows that they exhibit very different ionic signatures but an identical organic signature – an organic signature that is distinct from that of all other wells, whether water or gas, in this field. This chemistry suggests an irregularity in the two monitoring wells rather than an impact by hydraulic fracturing, which could not reasonably have caused the two monitoring wells to have different ionic signatures but the same organic signature.” (emphasis added)

In other words, the chemical data do not show impacts from fracking because water wells both close to and far from gas wells have the same inorganic chemistry; EPA’s two monitoring wells have different inorganic chemistry from the wells in the area, yet they share an identical organic chemistry. So the data confirm that improper monitoring well construction by EPA, rather than oil and gas development is the cause of the chemistry in these monitoring wells.

The GSI researchers conclude:

“[I]t is not reasonable to suggest that hydraulic fracturing operations could cause these two wells to have a different ionic content but the same organic content. The simpler explanation is that there are no ionic impacts on these wells by hydraulic fracturing and that the organic chemicals are sourced by something other than oilfield operations.

In sum, we find no evidence of impacts by hydraulic fracturing to the groundwater resources actually being utilized by the local community. The water quality of the two monitoring wells most likely reflects natural salinity conditions combined with organic contaminants that may have been introduced during installation of the monitoring wells.” (emphasis added)

Background on Pavillion, Wyoming

As Energy In Depth has noted on many occasions, activists spent years pushing fracking contamination claims in Pavillion based on a single draft EPA report from December 2011, which theorized a link. But EPA’s theory came under fire almost immediately, as state, federal and industry officials found serious flaws in the data EPA used to support it.

Due to concerns over EPA’s methods, the agency agreed to retest the wells, and the U.S. Geological Survey was brought in to do its own sampling.  Upon release of USGS’s results, EPA prematurely declared that the findings were “generally consistent” with its own.  But in reality, more than 50 separate measurements from the USGS differed from EPA’s results. The USGS also effectively disqualified one of only two monitoring wells used by EPA, due to low flow rates and poor construction.

But USGS was not the only federal agency to find problems with EPA’s data. Don Simpson, then-state director for the U.S. Bureau of Land Management (BLM), criticized EPA’s testing procedures in Pavillion and suggested EPA could have introduced “bias in the samples” due to faulty construction of its monitoring wells. As he said EPA’s results:

“[S]hould not be prematurely used as a line of evidence that supports EPA’s suggestion that gas has migrated into the shallow subsurface due to hydraulic fracturing or improper well completion until more data is collected and analyzed.”

In an October 2012 meeting of the Pavillion Working Group in Riverton, Wyo., the Wyoming Department of Environmental Quality (DEQ) presented its “down-hole camera” investigation of EPA’s monitoring wells, showing the presence of drilling mud and cuttings at the bottom of the well, which can lead to blockages in a screened section of the well, reducing the flow of water.

DEQ geologist Nicole Twing, who presented the findings of the down-hole camera investigation, explained the importance of the flow rate in an interview with EID:

“You have low flow rates that increase the time water is in contact with those drilling materials, and materials used in drilling mud can affect groundwater quality. You don’t know if it’s biasing the results up or down.” (emphasis added)

In other words, DEQ found that the water at the bottom of that well was both stagnant and apparently contaminated by the very materials that EPA used to build the monitoring well. That means any water samples taken from the well would not be representative of the water outside the well, which presumably had not been contaminated by EPA’s drilling materials.

After the Pavillion data had been collected and analyzed — but not yet made public — then-EPA Administrator Lisa Jackson said: “We have absolutely no indication right now that drinking water is at risk.” After the report was released, Jackson told reporters, “In no case have we made a definitive determination that the fracking process has caused chemicals to enter groundwater.”

In fact, from the very beginning, EPA officials privately admitted their findings were being misunderstood at best and misrepresented at worst. Internal e-mails released under the Freedom of Information Act show EPA officials fuming over the “inflammatory and irresponsible” coverage of the draft Pavillion report, which failed to note “these limited findings are not final [and] will go through peer review.” The same coverage included this claim from the anti-fracking Natural Resources Defense Council: “Fracking poses serious threats to safe drinking water.”

Due to all the problems with its data, EPA refused to submit its draft report for peer-review, and instead turned the investigation over to state regulators to complete the investigation. In December 2015, the Wyoming Department of Environmental Quality (DEQ) released the draft results of its 30-month investigation into water contamination in Pavillion, Wyoming. As that report explains,

“Evidence suggests that upward gas seepage (or gas charging of shallow sands) was happening naturally before gas well development.

“It is unlikely that hydraulic fracturing fluids have risen to shallower depths intercepted by water- supply wells. Evidence does not indicate that hydraulic fracturing fluids have risen to shallow depths intersected by water-supply wells. The likelihood that the hydraulic fracture well stimulation treatments (i.e. often less than 200 barrels) employed in the Pavillion Gas Field have led to fluids interacting with shallow groundwater (i.e. water-supply well depths) is negligible.”  (emphasis added)

As the Casper Star-Tribune put it,

“Samples taken from 13 water wells in 2014 detected high levels of naturally occurring pollution. Test results showed little evidence of contaminants associated with oil and gas production.”

Now, this data from GSI Environmental is just the latest to conclude that EPA’s data is based on faulty construction of its monitoring wells and that fracking did not contaminate water in Pavillion, Wyoming – yet another blow to activists who have tried to use this story as a linchpin for their anti-fracking agenda.