The EPA and Good Science?

A little more than a week ago, the EPA released its report, Investigation of Ground Water Contamination near Pavillion, Wyoming.  This draft research report offers an initial investigation into suggestions that local groundwater in Pavillion could have been impacted by migration of hydraulic fracturing (fracking) fluids.  This report and other related investigations of fracking by the EPA depend upon good science for their contribution to policy, and the report, as it stands right now, fails to pass the test of good science.

It has been my view that we should support sound science as a fundamental solution to our energy security and energy independence, and that is why I have endorsed a carefully defined role for the Federal Government in R&D and why I have documented significant advances in energy research in areas such as energy storage.  Good science matters for our energy future and our economic prosperity.  That is why it is so essential that the EPA’s reports represent good science.  The alternative is to foster bad policy with poorly done research that represents bad science.

Media coverage of this draft report erroneously assumed the EPA had confirmed evidence that, for the first time, fracking fluid was proven to have migrated out of a well because of the hydraulic fracturing process. It is important to understand that the findings only now are currently undergoing peer review; in its current state, the report offers only suspicions, not causes, of the groundwater issues at hand in Pavillion.

Like many in the media who got the story wrong, upon reading the EPA’s most recently released draft report, I found myself with more questions than answers.  Those questions about a research report are normally issues addressed with either substantial revisions to the report or the rejection and disposition of a research report prior to its publication. The peer review process results in a procedure whereby experts in the field carefully read and evaluate a draft research report, providing the authors with challenges, questions and areas for clarification.  The dialogue and background involved in initial peer review is essential to improving the quality of any research report that is finally accepted for publication, thereby increasing the potential for understanding an issue by other researchers, media, and the public. The process is an important one for science. It is the foundation of respected scientific journals.  Where it fails, good science fails.

The questions that I asked myself upon reading the report were ones that could have been addressed in an appropriate peer-review process.  For example, the draft report observes that some surface casings were “as shallow as 110 meters below ground surface.”  The report goes on to state, “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 areas of investigation.”  Petroleum engineers in their review of the report could have addressed the extent to which any ground water contamination resulted from improper design and construction associated with the well bore or cement bond, thereby leading to the migration of fracking fluids into the ground water supply.  If the design and construction were a probable cause, then the conclusions and the implications of the report could have been altered to provide better context for that possibility rather than leaving an apparent implication about the general role of the hydraulic fracturing process.

The report also raised questions that could have been addressed by peer review from geologists, for example, questions about the appropriateness of the Pavillion substrata for the sort of technology employed there.  The EPA report notes that, “There is little lateral and vertical continuity to hydraulically fractured tight sandstones and no lithologic barrier to stop upward vertical migration of aqueous constituents of hydraulic fracturing in the event of excursion from fractures.”  This area is known as the Wind River Formation, and it has been subject to previous research, e.g., a 1984 article by Osiensky et al., Monitoring and Mathematical Modeling of Contaminated Ground-Water Plumes in Fluvial Environments.  Their work addressed contamination from uranium mill waste, and it made the following observation about the Wind River Formation, “The pattern of seepage migration suggests that zones of high hydraulic conductivity (i.e., buried stream channels) . . . are controlling the movement of contaminants.”  It is possible, then, that the particular characteristics of the Wind River Formation may have led to natural seepage that could have contaminated ground water.  It is also possible that the Wind River Formation is significantly disparate from areas such as Utica and Marcellus where hydraulic fracturing technology is also employed.

Questions arise as well about other areas of the draft report, including the chemistry used.  For example, are the detected variances in the presence of certain chemicals reasonably linked to fracking, and is the failure to find similar results in different test wells realistic, given the methodology?  In light of the questions raised already in just the first few days since release of the report, chemists or chemical engineers weighing in during the peer review process may well find other significant areas for further study, thereby limiting  or circumscribing conclusions of this report.

To make the claim that contamination is “likely” prior to the scrutiny associated with a peer review process undermines the research, leaving its methodology and initial results open to questions about the extent to which this research represents good science.  In the end, the draft report offers us little that is useful in addressing the questions that have been raised about fracking.  Instead, the report implies unsubstantiated policy implications that risk our energy future and our economic recovery.  We should expect more from any federal agency.

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One thought on “The EPA and Good Science?

  1. US Energy Independence « Penley on Education and Energy

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