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 API REVIEW
 API’s Review o Recent USGS Pavillion, WyomingReports Show USGS Groundwater Sampling ResultsDier From EPA’s Results in 2011 Drat Report
Two new technical reports
1,2
were released by the United StatesGeological Survey (USGS) on September 26, 2012 regarding EPA’sPavillion, WY groundwater study and associated December, 2011report
3
. The USGS reports describe the results o their April-May,2012 testing o one o the monitoring wells (MW-01) previouslysampled by the EPA, and their attempts at sampling monitoringwell MW-02. In summary, the USGS did not nd the presence oseveral key chemical compounds o interest, most notably glycolsand 2-butoxyethanol, previously reported to be ound in deepmonitoring wells MW-01 and/or MW-02 by EPA. Other materialspreviously ound by the EPA were ound at signicantly lowerconcentrations by the USGS.The 2011 EPA Pavillion Drat report
3
, which claimed groundwaterimpact linked to hydraulic racturing near Pavillion, has comeunder intense scrutiny by the scientic community
4
. The USGSdata does not support any such link. Some o the faws that havebeen identied include improper monitoring well constructionand development; possible cross-contamination o groundwaterduring EPA monitoring well drilling, development, and sampling;and misrepresentation o monitoring well depths in relation todrinking water well depths in the area
4
. Many o these concernswere validated by the USGS. For example, the USGS was unableto sample one o EPA’s deep monitor wells (MW-02) because thewell could not yield enough water to produce a representativegroundwater sample which is due to improper well construction/ development.The two new USGS’ reports
1,2
underscore the need or transparentpeer-reviewed research and the use o proven and testedscientic practices.USGS recognized the importance o several actors overlooked bythe EPA during the development and implementation o the studydescribed in EPA’s 2011 report
3
: 1) proper testing and QualityControl/Quality Assurance (QA/QC) procedures; 2) representativesamples (to date a representative sample o groundwater romMW-02 has not be obtained); and 3) use o standard analyticaltesting methods.USGS’ work has raised the bar or sound science in the EPA’sPavillion research, however, some key technical issues still remainrequiring review and consideration by the USGS, EPA, and thescientic community. These issues include:
Page 1
•
USGS was to “
…provide an independent perspective o the quality o groundwater pumped rom two USEPA monitoring wells located near Pavillion, Wyoming” 
2
. However, based uponthe USGS report
1
and backup USGS sampling documents
2
,EPA was onsite and may have infuenced the USGS’ samplingeort. For example, USGS’ eld notes
1
collected during thesampling o MW-01 indicate not all samples were collectedas planned by the USGS due to the EPA limiting access andtime or ull USGS sample collection.
•
USGS did not provide technical interpretation o the data,but rather was requested by a cooperative agreement withWyoming
5
to provide those results to the panel tasked withlooking at the broader EPA study. USGS did provide one keynding in its Data Series Report
1
:
“One compound o interest in the Pavillion area, 2-butoxyethanol, was not identifed in the TIC analyses or any o the environmental samples.” 
Inaddition, USGS reported that toluene, xylene, isopropanol,diethylene glycol, triethylene glycol, and acetone were notound in groundwater rom well MW-01. These compoundswere reported in this well during the previous EPA samplingactivity
3
.
•
USGS sampled or a large variety o parameters (e.g.,organics, metals, radionuclides), none o these parameterswere detected at levels that exceeded EPA primary health-based drinking-water Maximum Contaminant Levels (MCLs).The chloride level in groundwater rom MW-01 was 27 partper million (ppm), well below the EPA secondary MCL o 250ppm. The methane, ethane, propane, and similar compoundsare likely naturally occurring, and many o these have beendetected historically
4
in groundwater in the Pavillion area, aact that has not been acknowledged by USGS or EPA. MW-01 is located in a very shallow natural gas production areaand the presence o methane and other hydrocarbons is notunexpected.
•
USGS issued (September 26, 2012) a Sampling and AnalysisPlan
2
(SAP) to support its sampling eorts at Pavillion, whichis normally prepared in advance and outlines sampling,testing, and QA/QC procedures. USGS appears to haverevised this SAP ollowing completion o their April-May,2012 sampling activities, which is highly unusual. It isrecommended that all revisions o the USGS SAP be providedto the public. Field notes and observations should be part othe data report and not in the SAP.
•
USGS was unable to meet standard USGS and best practicesampling/purging methods or monitoring well MW-02 dueto completion/development problems encountered during the April-May, 2012 USGS investigation. EPA, in spite o USGS’svalid reasons or not sampling well MW-02, collected asample o groundwater rom MW-02 on April 22, 2012 andsent those samples or analyses. This act was not discussed
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