The EPA issued yesterday its draft findings of its Pavilion, Wyoming Ground Water Investigation for Public Comment and Independent Scientific Review. Its contents are disturbing and demand attention from all regulators and all those charged with managing drilling companies. The mess in Pavillion, Wyoming is a screeching, disturbing event for regulators and the gas industry.
My preliminary review of the 121 pages of draft findings is that EPA has done a careful, methodical investigation that has produced strong, probably compelling evidence that leaks from surface pits, gas well design and operation failures, and hydraulic fracturing at what appear to be depths less than 1,300 feet below the surface have caused chemical and methane pollution of groundwater in Pavillion, Wyoming. For the EPA draft findings and accompanying press release, go to http: www.epa.gov/region8/superfund/wy/pavillion/index.html.
The press release states: "The draft report indicates that ground water in the aquifer contains compounds likely associated with gas production practices, including hydraulic fracturing." For example chloride levels 18 times the expected levels have been found in ground water and other measurements in the draft findings strongly support the preceding sentence. Encana, a large Canadian headquartered gas business, is the only company identified as being engaged in "gas production practices" in the document.
The report itself says there are 169 production wells which extract gas in the area and that "at least 33 surface pits previously used for the storage/disposal of drilling wastes and produced flowback waters are present in the area" (page xi). Pages 17 to 27 of the findings provide strong evidence that failures in the pits have caused ground water contamination
The report goes on to say that water wells are as deep as 732 feet but: "With the exception of two production wells, surface casings of gas production wells do not extend below the maximum depth of domestic wells in the area of investigation" (page xi).
The EPA's description of the surface casing, cementing, and fracking at depths of less than 1300 feet add up to a set of outrageous practices, if the descriptions are correct, and they appear to be. They would violate the Pennsylvania drilling rules or just about any set of rules. Rules must be enforced and followed to do any good. This mess is a strong reminder of that cardinal rule of regulation and good management.
The EPA states that the circumstances in Pavillion appear unique to the area. I would certainly hope so.
Pages 27 to 29 of the draft findings provide strong evidence of gas drilling causing gas migration and pollution of ground water.
Pages 29 to 32 have strong evidence that poor casing and cementing as well as hydraulic fracturing frequently at depths of less than 2,000 feet and at least once at 1222 feet caused ground water pollution. Leaving aside the issues of casing and cementing for a moment, Marcellus Shale fracking in Pennsylvania occurs at depths between 5,000 to 8,000 feet below the surface.
Here are the key conclusions at page 33:
1. "Detection of high concentrations of benzene, xylenes, gasoline range organics, diesel range organics, and total purgeable hydrocarbons in ground water samples from shallow monitoring wells near pits indicates that pits are a source of shallow ground water contamination in the area of investigation." This finding again highlights the risks associated with pits that store frackwater and the operational challenges of pits, a practice that is declining in Pennsylvania but not yet totally eliminated.
2. "Detection of contaminants in ground water from deep sources of contamination (production wells, hydraulic fracturing) was considerably more complex than detection of contaminants from pits necessitating a multiple lines of reasoning approach common to complex scientific investigations...While each individual data set or observation represents an important line of reasoning, taken as a whole, consistent data sets and observations provide compelling evidence to support an explanation of data. Using this approach, the explanation best fitting the data for the deep monitoring wells is that constituents associated with hydraulic fracturing have been released into the Wind River drinking water aquifer at depths above the current production zone."
EPA has issued its draft findings for a 45 day public comment period. The draft findings are not the final word. Yet, this document should be read by every board member of every gas drilling company operating anywhere in the world, by all the top managers of those companies, and by every regulator charged with environmental protection.
The EPA has provided reasons for humility, a real commitment to strong rules and strong enforcement, and a genuine dedication to excellence in operations and a culture of safety by both companies and regulators. The opposite may well have happened in Pavillion, Wyoming.