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API's Review Shows Flaws in EPA Pavillion Groundwater and Monitoring Report

API Releases Its Formal Review of EPA’s Pavillion December 8, 2011 Draft Report with a Focus on Monitoring Well Drilling, Completion, and Sampling Activities

On June 20, 2013, EPA took a significant step in announcing that it will be supporting the State of Wyoming in its further investigation of drinking water quality in Pavillion, Wyoming and stepping back from further direct involvement. Since 2010, API expressed serious concerns with the groundwater assessment in Pavillion, through the Agency’s sampling of domestic wells, pit remediation sites, and produced water and condensate from the five primary production wells operated in the area. Not only did we question the scientific rigor of the sampling program, but recognized the potential negative impact the Agency’s substandard work and analysis might have on the validity, findings and conclusions of the larger EPA study on hydraulic fracturing (the National HF Study). The potential for this became particularly clear when EPA released its data from both the domestic well samples and its own poorly installed monitoring wells in a December 8, 2011 Draft Report; including unsubstantiated conclusions.

In response, API met with representatives of EPA and the US Geological Survey (the USGS was asked to work with EPA in the spring of 2012 to clarify questions about the EPA’s initial monitoring well results) in late 2012 sharing concerns regarding EPA’s monitoring well drilling, construction, development, and sampling issues. In addition, the omission of a number of critical details and facts in the Draft Report, including the failure of EPA to disclose antifreeze, cement, and diesel fuel releases from their operations at the deep monitoring well drilling sites, was discussed; facts important to any potential peer reviewer or investigator. Two Fact Sheets were submitted to both agencies in late 2012 and early 2013 detailing API’s concerns.

As a direct result of what we uncovered and our continued pressure to ensure sound science, in its June 20th announcement, EPA emphasized that it did not plan to finalize or seek peer review of its December 2011 Draft Report and no information from Pavillion would be included as part of the National HF Study.

On July 1, 2013, API submitted its Final Report (see PDF file below) to the formal docket on the EPA’s Draft Report. In our Final Report API identified many fatal flaws in the Pavillion study and has called upon EPA to formally retract both the Draft Report and all of the associated data. We view EPA’s work at Pavillion equal to that of Parker County, Texas and Dimock, Pennsylvania – one more example of questionable science and flawed data leading to unsupported conclusions.

See related documents below:


API's Review of EPA's Pavillion December 8, 2011 Draft Report with Focus on Activities Related to Deep Monitoring Wells MW-01 and MW-02

File Size: 4.2 MB

API Review: Recent USGS Pavillion, WY Reports Show USGS Groundwater Sampling Results Differ from EPA's Results in 2011 Draft Report

File Size: .2 MB

API Review: EPA's Monitoring Wells at Pavillion, WY are Improperly Constructed and Unsuitable for Groundwater Quality Assessment

File Size: .1 MB

API Letter to EPA regarding Docket ID No. EPA-HQ-ORD-2011-0895

File Size: .3 MB