API’s Review o Recent USGS Pavillion, WyomingReports Show USGS Groundwater Sampling ResultsDier From EPA’s Results in 2011 Drat Report
Two new technical reports
were released by the United StatesGeological Survey (USGS) on September 26, 2012 regarding EPA’sPavillion, WY groundwater study and associated December, 2011report
. 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 oseveral 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 signicantly lowerconcentrations by the USGS.The 2011 EPA Pavillion Drat report
, which claimed groundwaterimpact linked to hydraulic racturing near Pavillion, has comeunder intense scrutiny by the scientic community
. The USGSdata does not support any such link. Some o the faws that havebeen identied 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
. 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
underscore the need or transparentpeer-reviewed research and the use o proven and testedscientic practices.USGS recognized the importance o several actors overlooked bythe EPA during the development and implementation o the studydescribed in EPA’s 2011 report
: 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 thescientic community. These issues include:
USGS was to “
…provide an independent perspective o the quality o groundwater pumped rom two USEPA monitoring wells located near Pavillion, Wyoming”
. However, based uponthe USGS report
and backup USGS sampling documents
,EPA was onsite and may have infuenced the USGS’ samplingeort. For example, USGS’ eld notes
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
to provide those results to the panel tasked withlooking at the broader EPA study. USGS did provide one keynding in its Data Series Report
“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 notound in groundwater rom well MW-01. These compoundswere reported in this well during the previous EPA samplingactivity
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
in groundwater in the Pavillion area, aact 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
(SAP) to support its sampling eorts 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 othe 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