Mountain States

Wyoming Regulators Ask EPA to Plug Flawed Pavillion Monitoring Wells

Last week, the Wyoming Department of Environmental Quality (WYDEQ) released its final groundwater report, which found no evidence of contamination from fracking in Pavillion. That finding rightly generated a lot of headlines, but what received less attention, is the fact that the DEQ also asked the Environmental Protection Agency (EPA) to plug and abandon its now infamous monitoring wells drilled in 2011 as part of its investigation into water contamination claims.

In a fact sheet released with their report the DEQ requested that EPA do this due to the “potential hazard they pose in relation to groundwater supplies and physical safety.” In a conference call to discuss their report, Kevin Frederick, water quality administrator for WYDEQ official highlighted the fundamental flaws in EPA’s monitoring wells that, as EID has previously reported, have plagued the credibility of the EPA’s Pavillion investigation for years. From the WYDEQ:

“Of particular concern to us was that the monitoring wells were constructed using what’s known in the industry as black pipe. It is our understanding initially that the wells were to be constructed using casing that had no coating. Unfortunately that didn’t happen. These monitoring wells were constructed with black coating. Our analysis indicates that the coating is essentially used to help discourage rust from developing on the outside of the casing and so forth. Unfortunately the coating in many cases contains petroleum hydrocarbons, and it’s a concern to us that during the installation that some of that material may have actually become dislodged while the casing was being installed and ended up in the water samples that were being taken.” (23:30-24:42)

In other words, WYDEQ believes that EPA may have contaminated its own monitoring wells with hydrocarbons. Of course, EID has pointed out on many occasions that despite originally reporting that they had used stainless steel, EPA had actually used pipe that was completely inappropriate for a groundwater monitoring well. But as WYDEQ points out, the problems were only beginning. Also from the call:

“The installation of the wells did not include a sand pack above the perforated interval of the well as required by our regulations. And the purpose of that sand pack is to essentially provide a cushion or a barrier between the perforated interval and the bentonite grout that’s placed above the sand to seal off the annular space in between the casing and the well bore. And in the absence of that sand pack, the bentonite or grout material is not restricted from essentially coming into contact with the screen interval where you are essentially monitoring contents of the bentonite grout as part of your water supply analysis. The intention is to make sure that those materials are clearly separated, the grout from the screened interval. So there are concerns along those lines. And I think if you go back and take a look at the USGS reports with respect to sampling those two wells, after the EPA draft report came out, they clearly identify issues with not being able to collect representative samples from monitor well one, or excuse me monitor well two, and clearly it throws into question the efficacy of collecting reliable representative water quality results from those two wells.” (24:45-26:37)

So not only did EPA use improper pipe, the agency also made a series of additional mistakes that all undermine the credibility of any water quality data culled from the wells. And when asked to follow up on whether the WYDEQ felt that asking for those wells to be plugged and abandoned was essentially putting an “exclamation point” on the reliability of the data from the wells, WYDEQ responded:

“That’s absolutely right.” (26:54-27:01)


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 the concerns raised over EPA’s methods, the agency agreed to retest the wells, and the U.S. Geological Survey (USGS) 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.

Later, even more issues with EPA’s methods came to light during an October 2012 meeting of the Pavillion Working Group in Riverton, Wyo., the WYDEQ 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. WYDEQ 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, WYDEQ 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.


Not only did WYDEQ’s investigation close the book on activist claims that fracking led to groundwater contamination in Pavillion, it should also be noted for closing the book on the credibility of EPA’s monitoring wells.


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