UPDATE (3/29/2016; 2:30 pm ET): The Casper Star-Tribune and Greenwire have both reported that the lead researcher of the Stanford Pavillion study, Dominic DiGiulio, was also the author of EPA’s Pavillion study, which has been thoroughly discredited.

As the Casper Star-Tribune put it,

“More than four years after he penned the explosive report linking fracking to contaminated drinking water outside of Pavillion, Domenic DiGiulio is releasing the study he always hoped the U.S. Environmental Protection Agency would.”

Greenwire reported,

“A team of Stanford University scientists led by a former U.S. EPA investigator has linked hydraulic fracturing in Pavillion, Wyo., to underground drinking water contamination.

Lead author Dominic DiGiulio, who wrote the 2011 EPA draft report on Pavillion’s water, is now a visiting scholar at the Stanford School of Earth, Energy & Environmental Sciences.”

In other words, not only does this new study rehash the same debunked data from EPA’s two monitoring wells, which were widely criticized by federal and state officials, it also has the same author.

This information was not included in the original embargoed materials, although it was apparently conveyed to the press.

— Original Post March 29, 2016 —

In a new study examining water quality in Pavillion, Wyo., Stanford researchers claim to have “for the first time, demonstrated impact to Underground Sources of Drinking Water (USDWs) as a result of hydraulic fracturing,” a theory that many critics of drilling have promoted for the same region. But the research team did not take any new samples, choosing instead to reinterpret the same data that state officials used to exonerate drilling.

The research team was led in part by Dr. Rob Jackson. If Jackson’s name sounds familiar, it’s because he was one of the Duke University researchers who published studies in 2010 and 2013, which also claimed fracking could have contaminated groundwater. Those reports suffered from a number of major flaws, several of which were conceded by the authors, including a lack of baseline data, the decision not to randomly sample wells, and the presence of high levels of methane in water wells that were nowhere near natural gas drilling. Numerous studies by USGS, Syracuse University and other reputable research organizations, have thoroughly debunked those claims.

So it’s not surprising that Dr. Jackson has published yet another paper alleging a link between drilling and water contamination. But let’s take a deeper look at his latest project.

Fact #1: Researchers didn’t take any new samples just reinterpreted EPA’s old discredited data

The researchers state,

“We conducted a comprehensive analysis of all publicly available online data and reports, to evaluate impact to USDWs and usable water as a result of acid stimulation and hydraulic fracturing.  Although injection of stimulation fluids into USDWs in the Pavillion Field was previously documented by EPA, the potential impact to USDWs at depths of stimulation was not assessed. We evaluate potential upward migration of contaminants to depths of current groundwater use using data from MW01 and MW02.” (emphasis added, p. B)

Again, Jackson’s team didn’t take any samples. Instead, they simply reinterpreted data from the Environmental Protection Agency’s (EPA) study involving two monitoring wells, MW01 and MW02.  The researchers state,

“We evaluate potential upward migration of contaminants to depths of current groundwater use using data from MW01 and MW02.” (p. B)

The researchers fail to mention, however, that these monitoring wells were rife with problems.

In December 2011, EPA issued a preliminary report, which “theorized a link between a petroleum industry practice called hydraulic fracturing and groundwater pollution in a Wyoming gas field.” But EPA’s conclusion was so weak that, before long, more state and federal agencies were disputing its theory than agreeing with it.

When the U.S Geological Survey (USGS) conducted its own subsequent testing, they had more than 50 separate measurements that differed from EPA’s results. USGS also effectively disqualified MW02, due to low flow rates and poor construction. The drilling of the well has also been criticized by another federal agency. Don Simpson, then- state director for the U.S. Bureau of Land Management (BLM), suggested EPA’s testing could have introduced “bias in the samples”:

“Bias in the samples obtained from these wells may exist. Possible causes include transfer of shallow contamination into deeper zones through the drilling process, or contamination of samples through the introduction of contamination during the drilling and well installation process…”

“In addition, the development of these monitor wells appears to be deficient for sampling purposes and groundwater samples from the wells should not be fully trusted until development activities indicate that the wells are yielding formation water untainted by any effects introduced by the drilling, well completion, and sampling process.”

“These observations are anticipated and should 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, which showed that EPA was not using stainless steel casing as it had claimed, but had actually used carbon steel, which likely introduced contaminants into the wells.  They also found drilling mud and cuttings at the bottom of the well, which can lead to blockages in the 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 MW02’s 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)

So, the water at the bottom of MW02 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.

The Stanford researchers also state in their report,

“2-Butoxyethanol, a glycol ether used extensively for well stimulation in the Pavillion Field (Table SI C3), was detected in both monitoring wells at a maximum concentration of 12.7 μg/L.”

The Stanford researchers are attempting to link trace concentrations of 2-Butoxyethanol (2-BE) in the monitoring wells to drilling.  That’s exactly what EPA did in 2011 when it seized on a “hit” of 2-BE as potential evidence that hydraulic fracturing had impacted water quality in Wyoming.  But the contamination found by EPA in Pavillion was likely a false-positive detection of 2-BE and glycols, due to the cement and steel casing EPA used to construct its monitoring wells. As one peer reviewed study put it,

“[T]o establish a link to hydraulic fracturing in the deep monitor wells, the EPA draft report relied heavily on the detection of exotic organics chemicals such as glycols and 2-butoxyethanol in the deep groundwater monitor wells, some of which were present at very low or trace concentrations, at least initially. If the detection of such low chemical concentrations is to be used as a criterion to show impacts from hydraulic fracturing, it is important to exercise extreme care in decontaminating drilling tools, well casings, and screens placed in the well, in the use during drilling of hydrocarbon-based fluids and lubricants, in eliminating the potential for well construction materials to leach chemicals into the water, in conducting thorough well development, in confirmation sampling, and in robust laboratory QA/QC protocols.” (emphasis added)

As a report by the American Petroleum Institute (API) explained,

“A review of the USGS data presented in their report shows pH stabilization did not occur during sampling, and graphs in that USGS report suggest that well MW-01 is still being impacted by high pH cement (known to contain glycols and phenols) and/or drilling fluids used by EPA. Review of all analytical and development data suggests that both monitoring wells MW-01 and MW-02 have yet to be properly developed and are both being affected by cement. USGS was unable to use standard USGS and best practice sampling/purging methods for monitoring well MW-02 due to completion and development problems encountered during the April-May, 2012 USGS investigation. […] It is likely that this steel casing may have introduced to the groundwater organic and inorganic compounds, including hydrocarbons and 2-butoxyethanol (2-BE) allegedly reported sporadically in EPA’s samples.” (emphasis added)

In late 2011, 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 2013, EPA essentially admitted that the conclusions they derived from the data were wrong.  As an EPA spokesperson said,

“We stand by what our data said but I do think there is a difference between data and conclusions.” (emphasis added)

In response to significant criticism from federal and state regulatory officials, EPA withdrew its draft report from the peer-review process, and turned the investigation over to state regulators.

Meanwhile, state regulators, who have been on the ground evaluating this area for years, recently determined there was little to no evidence to suggest any impact from hydraulic fracturing, which brings us to our next point.

Fact #2: State regulators found fracking was “unlikely” to have been the cause of contamination

The Wyoming Department of Environmental Quality (DEQ) released the results of its 30-month investigation into water contamination in Pavillion, Wyoming, in December 2015. 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.”

Fact #3: Researchers use overly broad definition of “Underground Source of Drinking Water”

The press release for the study states,

“Only one industry is allowed to inject toxic chemicals into underground sources of drinking water – hydraulic fracturing, or ‘fracking.’”

But the actual study states,

“The Fort Union Formation is not used for water supply in the Pavillion area.” (emphasis added)

So how can the researchers claim in their press release that companies are injecting “toxic chemicals” into drinking water sources, while also acknowledging that the formation is not being used for drinking water?

The answer has to do with the U.S. EPA’s definition of an Underground Source of Drinking Water (USDW). To be classified as a USDW, an underground reservoir merely has to exhibit certain characteristics that could make it a usable aquifer sometime in the future. The authors know that (since they define what a USDW actually is in the study), but what sort of media attention would you get by saying the companies aren’t injecting into the community’s drinking water supply? That’s not scary at all!

So instead, the authors – recognizing that many reporters will only read their press release – suggest companies are deliberately injecting fluids into drinking water sources, a characterization that is misleading at best. The fact that the authors know this, and still chose to conflate generic USDWs with actual reservoirs from which actual drinking water is taken for public use, makes it even worse.

Importantly, rock layers that contain oil or natural gas also typically contain water. That’s why, when companies produce oil and natural gas, they often also produce water, and sometimes in large quantities.  These zones aren’t ubiquitous. In some areas, the oil or natural gas concentrations are higher. In others, the water content is really high. But there is nothing controversial about producing oil and natural gas from areas where oil and natural gas are located.

Fact #4: Report relies heavily on flawed research of Anthony Ingraffea

The very fact that the researchers thank Dr. Anthony Ingraffea in their acknowledgements, presumably as a reviewer of the study, is enough to give anyone pause about its reliability.

Ingraffea’s work, from methane emissions to well integrity issues, has been repeatedly discredited by peers and colleagues alike.  At a presentation in Denver, Ingraffea openly admitted that the research in which he participates is geared for “advocacy”:

“You can read any of the papers I participated in writing and you can easily detect the words we use, the phraseology…predilection. I wouldn’t say bias…it’s too strong a word. But, in the conclusions and in the summaries and the abstract, it’s clear what we owe people to provide by reading this paper. And that’s a form of advocacy. And we have advocacy-laced…advocacy-laced words and phrases in our papers.”

The only evidence of well casing failure the researchers cite is a report by Dr. Ingraffea, when making this claim,

“Casing failure occurred at five production wells following well stimulation.”

Meanwhile Wyoming regulators determined in August 2014 that the wells in Pavillion “were properly permitted, drilled, completed, and operated in compliance with applicable state and/or federal rules and regulations.”

Ingraffea’s bias isn’t the only reason he might not be the best source of information on well integrity issues.  At the recent trial in Dimock, he openly admitted that he’s never actually been on a well pad and has no hands-on experience with the process at all.  When asked “what personal experience do you have with plugging or cementing an oil or gas well?” He answered, “Absolutely none.”

Conclusion

State and federal officials have been studying the Pavillion case for many years. Multiple investigations – including those that actually gathered their own samples and new data – have revealed that water quality issues in the region are most likely the result of natural causes. As we know, EPA attempted to link those issues to hydraulic fracturing, but faced with mounting criticism, the agency essentially withdrew its report and abandoned the peer-review process altogether.

If the EPA believed its own data were not sufficient to make it through peer-review, then why should we trust the conclusions of another research team that simply repackaged the same flawed results?