* Update* ODNR Geologist Says Draft EPA Pavillion study “Truly Flawed Science”
It’s probably a pretty safe bet that no one in Ohio has actually ever been to Pavillion – a town of less than 170 residents in the middle of the Wind River Indian Reservation in Fremont Co., Wyoming. But after the release last week of a draft EPA study suggesting that the fracturing of shallow natural gas wells in the area could have impacted groundwater, it’s probably safe now to assume that hundreds of thousands of Ohio residents have heard of it.
So important was the news that the Columbus Dispatch ran the Pavillion story on its front page. Ditto in Dayton. But now, as the dust starts to settle out a bit, we’re starting to get a much better and clearer sense of exactly what went wrong out in Pavillion. And every shred of data and information coming in right now indicates that most of “what went wrong” resides directly with EPA itself.
From drilling their monitoring wells squarely into a natural gas-producing zone (700 feet below where anyone could expect to find potable groundwater), to reporting that petroleum compounds were found even in the “blank” water samples that were tested (control samples, not even from Pavillion) – the methodological errors that EPA appears to have committed in Pavillion are legion. At least that’s the conclusion to which several prominent news outlets came over the weekend, with one editorial suggesting that EPA’s findings are based on “shoddy scientific analysis.”
Well, add one more important voice to that choir: ODNR geologist Tom Tomastik. In a position paper released publicly earlier today, Mr. Tomastik lays out what he considers to be myriad errors of both omission and commission with respect to the work product issued by EPA’s Denver office late last week. The full, four-page ODNR analysis is available here – but below, we excerpt out a few of the highlights:
- “As a professional geologist at the Division for 23 years with experience and expertise in conducting several hundred alleged groundwater contamination cases in Ohio, I see many deficiencies and concerns with this draft U.S. EPA report.”
- There is huge lack of geological and hydrogeological information within this report. When conducting a groundwater investigation of this magnitude, local geology and hydrogeology must be presented and evaluated to accurately determine the impacts geology and hydrogeology play in the role of identifying pathways for migration of contamination.
- “Total lack of evaluation or determination of naturally-occurring hydrocarbons in shallow geologic reservoirs. If they exist, they need be evaluated.”
- “In my evaluation of the cement bond logs examples that are presented in this report, U.S. EPA did not consider the normal issues (microannulus, poor cement bonding, gas-cut cement, or free pipe) inherent to first generation cement bond logging evaluation. These issues need to be address prior to obtaining accurate determinations.”
- I see no geochemical analyses by U.S. EPA of oil and gas production brines or other hydrocarbon fluid production to evaluate natural BTEX compounds already present in the reservoirs. To assume these compounds came from additives inherent to hydraulic fracturing is truly flawed science.”
- “The U.S. EPA Investigation of Ground Water Contamination near Pavillion, Wyoming is clearly lacking in the demonstration of the scientific method. A more through geologic and hydrogeologic investigation is warranted.”
Update 1 – December 22, 2011
One key point made in the story was that
The production in Pavillion hasn’t been identical to production elsewhere in the U.S. or even Wyoming. In Pavillion, the gas is relatively close to the surface — just a couple thousand feet down, much shallower than other gas fields where the gas is as much as two miles deep.
Encana’s four key points are:
- The EPA found no evidence of oil and gas impacts and no connection to hydraulic fracturing in Pavillion residents’ drinking water
- The EPA drilled two deep monitoring wells into a known natural gas reservoir and to no one’s surprise found components of natural gas
- The EPA released its preliminary findings without a truly independent, qualified third-party review
- That’s why, for everyone from the Pavillion residents to those who make their living in the natural gas industry, we all need a truly independent panel of experts with widely recognized scientific knowledge to tell us what’s going on with Pavillion groundwater