Cracks in the Facade

7/31/2019 Cracks in the Facade

1/36w w w. e w g . o rg / g a s - d r i l l i n g - a n d - f r a c k i n g

Cracks in the Faade25 Years Ago, EPA Linked Fracking to Water ContaminationDusty Horwitt, Senior Counsel, Environmental Working Gr

August 3, 2011


2/36Environmental Working GroupCracks in the Fa ade 20112

w w w. e w g . o rg / g a s - d r i l l i n g - a n d - f r a c k i n g

Background

Illustrations

Acknowledgments

i. Executive Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .3

ii. EPA Report Contradicts Industry Claims . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .9

iii. Parsons Well Was Drilled and Fractured . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .1

iv. Gas, Gel in Parsons Water Well . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .1

v. Gel in Water Consistent with Fracturing . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .1

vi. Aquagel: An Alternative Explanation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

vii. Were Older Wells the Source of Contamination? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

viii. Four Old Wells Within 1,700 Feet of Parsons Gas Well . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

ix. Fractures Can Extend up to 2,500 Feet . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .20

x. West Virginians Say Problems Persist . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .2

xi. Couple Says Home Became Unlivable . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .2

xii. Summary and Recommendations: . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .28

xiii. References . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .31

i. EPA Traced Pollution of Underground Water Supply to Hydraulic Fracturing . . . . . . . . . . . . . . . . . . . . .

ii. Families Say Drilling, Fracturing Polluted Water. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

Contents

EWGs Cracks in the Faade was made possible thanks to the generosity of the Park Foundation, Civil SocietyInstitute and EWGs community of online supporters.

Our thanks to EWGs staff designer Aman Anderson for his work in layout and illustration, Tylan Yalniz for in designing the reports website and interns James Meinert and Justine Chow for their research.

The opinions expressed in this report are those of the authors and editors and do not necessarily reflect the viour supporters. EWG is responsible for any errors of fact or interpretation contained in this report.

2011. Environmental Working Group.


3/36Environmental Working GroupCracks in the Fa ade 2011 3

EXECUTIVE SUMMARY25 Years Ago, EPA Linked Fracking toWater Contamination

In 2006, a Dallas-based company riding a na-tionwide natural gas boom drilled and hydrauli-cally ractured a gas well in a sandstone and shale

ormation in Jackson County, W. Va. Just a terEXCO Resources ractured the well, area resi-dents said that two nearby water wells becamepolluted.1

When the water actually went bad was a terthey ractured, says Paul Strohl, 69, a retired re-

ghter who lives in Jackson County.Even the consistency changed, said his wi e

Janet, 67. It was slimy.A ter the problems sur aced, Paul Strohl says,

yler Mountain Water, a company based in Poca, W. Va., began delivering water to the a ected resi-dents. A ter they racked, this water truck startedshowing up delivering water. I dont think it takesmore than a third-grade education to gure out

what that means.2

Te landowners whose water wells were involvedin the incident have declined to comment, saying they signed con dentiality agreements with

EXCO. Te Strohls account bears striking simi-larities to a report issued almost 25 years ago by the Environmental Protection Agency, whichconcluded that hydraulic racturing (colloqui-

ally known as racking) could and did ctaminate underground drinking water sourceTat all-but- orgotten report rom Decemb1987, uncovered by Environmental WorkinGroup and Earthjustice, contradicts the drilliindustrys insistence that there has never beedocumented case o groundwater contaminatcaused by hydraulic racturing.

Used in more than 90 percent o natural gand oil wells, racking involves injecting a m

water, sand and chemicals into a well under hi

pressure in order to racture underground roormations and unlock trapped gas and oil.EPAs long-ignored 1987 report ound th

racturing uid rom a shale gas well more 4,000 eet deep had contaminated well wa

just across the road rom the Strohls home, tthe contamination was illustrative o the ty

o pollution associated with natural gas anddrilling, and that EPAs investigation had behampered by con dentiality agreements betweindustry and a ected landowners.

Since then, the industry has hydraulically tured hundreds o thousands o wells and is ctinuing a historic push into natural gas-bearishale ormations, once considered inaccessthat lie beneath populated areas in a numbo states, including West Virginia, New YoPennsylvania, Ohio, Michigan, Louisiana a

Arkansas. o access these ormations, drillers o
http://www.epa.gov/osw/nonhaz/industrial/special/oil/rtc1987.pdfhttp://www.ewg.org/http://www.ewg.org/http://www.ewg.org/http://www.ewg.org/http://www.epa.gov/osw/nonhaz/industrial/special/oil/rtc1987.pdf




use a relatively new combination o horizontaldrilling and higher-volume racturing. As drilling activity has intensi ed, reports o pollutionhave sparked a growing national debate over theactual or potential environmental risks, includ-ing contamination o groundwater, the source o drinking water or more than 100 million Ameri-cans, according to the U.S. Geological Survey.3 Asthe West Virginia case and others like it indicate,the risk o groundwater contamination is greatly increased because decades o oil and gas explora-

tion have le t many regions o the country riddled with thousands o abandoned and o ten poorly sealed wells. Government and industry studiesshow that racking uids rom new wells can po-tentially in ltrate these older bores and rise back up to the level o drinking water aqui ers closer tothe sur ace.

In the debate over these risks, EPA andCongress have never cited the agencys own 1987report and have largely exempted racturing romregulation.

During the racturing process, EPA investi-gators wrote in the 1987 report, which ocusedon the handling o natural gas, oil and geother-mal wastes generally, ractures can be produced,allowing migration o native brine, racturing

uid and hydrocarbons rom the oil or gas wellto a nearby water well. When this happens, the

water well can be permanently damaged and a

new well must be drilled or an alternative souro drinking water ound.4

In an introduction to the chapter on con-tamination cases, including the case in JacksoCounty, the EPA noted that within each [geographic] zone, the report presents one or morcategories o damages that EPA has selected

airly illustrative o practices and conditi within that zone.5

Industry representatives reviewed EPAs repoand appeared to reach di erent conclusions abou

the case.In the EPA docket center in Washington

EWG discovered comments submitted by th American Petroleum Institute (API), the naturagas and oil industrys major trade associatio

Although API was generally critical o EPAsvestigation, calling it inaccurate and careless1

API did not speci cally dispute EPAs conclusioabout the West Virginia case in several writtecomments. Indeed, the industrys commentindicate that the association agreed with EPA ththe case involved contamination o groundwaas a result o racturing.

One case, the API wrote, re erring to t West Virginia contamination case, resulted in workover operation racturing into groundwatas a result o equipment ailure or accident. Asscribed in the detail write-up this is not a normaresult o racturing as it ruins the productive



pability o the wells. Another document attachedto APIs comment noted that in the West Virginia case the damage here results rom an accidentor mal unction o the racturing process.Teprocess requires the ractures to be created to belimited to the producing ormation. I they arenot as is the apparent case here oil and gas are lost

rom the reservoir and are unrecoverable.6

A group o state oil and natural gas associationstook a di erent approach in comments submit-ted to EPA in 1988. EPA is incorrect in its state-

ment that the racturing o a well can result incontamination o nearby water wells. the as-sociations wrote. Such a statement is completely

without support in the study. In act, we know o no case where this has occurred given propercasing. Te zones which are ractured are severalthousand eet below the deepest resh water zones

making contamination o the resh water zonesextremely unlikely.7

Environmental Working Group recently con-ducted its own year-long investigation and con-cluded that a variety o evidence indicates thatthe West Virginia case was indeed an example o hydraulic racturing pollution o groundwater,though it could not rule out that another stage o the drilling process could have caused the problem.

A ormer EPA ofcial who worked on the1987 report and asked not to be named said thatthe agency was aware o other cases o groundwa-

ter pollution involving hydraulic racturing bdid not include them in the report because thdetails were sealed under con dential legal settments reached between a ected property owneand energy companies. Te 1987 document notedthat such settlements o ten presented hurdles the EPAs investigation.

Private citizens rarely bring cases to coubecause court cases are expensive to conducthe EPA reported, and most o these cases asettled out o court. In addition to concealin

the nature and size o any settlement entered inbetween the parties, impoundment curtails acceto scienti c and administrative documentation othe incident.8

Te ormer ofcial said the EPA identi edother cases o groundwater contamination causby racturing but excluded them rom the rep

because they involved pollution by migratinnatural gas or oil, not by the chemical-laced uiinjected in the racking process itsel . Contamition by leaking natural gas and oil was consideroutside the scope o the report, which ocused oon the management o wastes rom the natugas, oil and geothermal industries. Te report alsonoted that because EPA had only three monthto collect cases rom across the nation, there wlimited time available or damage case reviewTe ormer EPA ofcial explained that EPA hadto complete the study quickly because the agen




had missed a Congressionally mandated deadlineand was working under a court-ordered timeta-ble.

Both the 2006 incidents in West Virginia andthe 1987 EPA study, which involved dozens o documented incidents o apparent contamina-tion by racking, drilling wastewater stored in pitsand other drilling techniques, raise new questionsabout the agencys commitment to protecting thepublic as it pursues its current two-year study o hydraulic racturings risks.

Inexplicably, the EPA ailed to mention itsown nding when it produced a second report in2004, a document that an internal whistleblowersharply criticized or its lack o scienti c rigor and

or relying on a review panel stacked with currentor ormer industry employees.10 Te 2004 analysisconcluded that hydraulic racturing in coal bed

methane natural gas wells, a relatively small subseto natural gas and oil wells, posed no risks to under-ground water supplies. Te study set the stage or a Congressional vote in 2005 that legally exempted

racking or all types o natural gas and oil wellsrom regulation under the ederal Sa e Drinking

Water Act, a law speci cally designed to preventcontaminants injected underground rom migrat-ing through abandoned natural gas and oil wells.11

In its 2004 report, the EPA announced thatit was limiting its review to coal bed methane

wells in large part because such wells tend to

be shallower and closer to [underground sourco drinking water] than conventional oil angas production wells and EPA has not hearconcerns rom citizens regarding any other tyo hydraulic racturing.12

It made that decision despite the ndings oits own 1987 report on the West Virginia case

which ound that hydraulic racturing or natugas in a shale deposit more than 4,000 eet dehad polluted a water well only 400 eet rom sur ace.

EWGs investigation also turned up recenindustry and government reports that sharpeconcerns about racturing and may help explathe West Virginia case eatured in the EPAreport. Tese documents show that racture

rom one well can spread unpredictably and aknown to have caused racturing uid to migra

into other nearby natural gas and oil wells, somtimes known as o set wells.Fractures are usually enormous eature

wrote engineer and drilling industry consutant M.C. Vincent in a paper that he presentedat a hydraulic racturing con erence held nHouston in January 2009. In many reservoir

ractures are mapped to extend beyond 1,000 (hal -length) rom the wellbore. In some revoirs, hal -lengths exceeding 2,200 eet have bcon rmed as treatments have broken into o s

wellbores13



State regulators in Illinois and exas, as wellas Congress investigative arm, the Government

Accountability Ofce, have also documentedcontamination problems caused when oil and gas

waste uids injected underground or disposalmigrated up nearby older wells and broke outnear the sur ace, where groundwater is ound,a phenomenon sometimes called saltwaterbreakout.14 One case in exas involved uid thattraveled hal a mile underground rom an injec-tion well and then migrated up through an old,

improperly plugged well.15 Tere were our aban-doned natural gas wells within about 1,700 eeto the gas well and water well involved in the WestVirginia case documented by the EPA in 1987.

Currently, both EPA and the Department o Energy are reviewing the environmental risks o hydraulic racturing. Tese multiple pieces o in-

dependent evidence underscore how essential itis that both agencies tackle these issues in a armore thorough way than EPA did in its cursory and deeply awed 2004 review.




In 1982, Kaiser Gas Co. drilled and hydraulically fractured a natural gas well on the property ofJames Parsons in Jackson County, W. Va. The EPA concluded in a 1987 report to Congressthat the process contaminated Parsons water well with fracturing fluid. It is unclear how thefracking fluids may have entered the water well, but four old natural gas wells nearby couldhave been the conduits for contamination.

EPA Traced Pollution of UndergroundWater Supply to Hydraulic Fracturing

Fluid MigrationGovernment studies have found thatoil and natural gas waste fluids injectedunderground can migrate up old oil andnatural gas wells.

Breakout into AquiferThese fluids can break into aquifers nearthe surface if the old wells have deterioratecasings, lack cement plugs or contain craccement. This phenomenon is known as sawater breakout. It is possible that hydraulfracturing fluids migrated in a similar wayParsons water well.

1940s Wells NearbyFour old natural gas wells werelocated within 1,700 feet of thegas well drilled on James Parsonsproperty. Each of the wells wasshot, an early fracturing processin which companies detonated

explosives inside a well to helpaccess gas or oil deposits.

Hydraulic FracturesAccording to industry studies,hydraulic fractures can extend up to2,500 feet horizontally, well withinrange of old natural gas wells nearParsons property. Studies foundthat fractures have broken intonearby oil and gas wells and thatfracking fluid has migrated up oldwells to the surface.

1

Hydraulic Fracture

Shale

Not to scale

ParsonsHome

Cracked or absent cement/casings

2

1

2

2

2

2

3

4

1,000 ft.

3,000 ft.

4,000 ft.

7,000 ft.

Aquifer

Water Well

500 ft.

1941

1941

1941

1941-42

1982

Hydraulicfracturingfluid injected

Contaminantsenter water well

Old Well

Drilled 1941-42

New Well

Drilled 1982

2

3 4

Jackson County, WV



EPA Report ContradictsIndustry Claims

Fracturing in the drilling industry dates tothe 1800s, when companies began exploding glycerin or dynamitedeep inside their wells toopen passages through which natural gas or oilcould ow more rapidly into drilling pipes orcollection. In 1947, drillers or the rst time usedhydraulic racturing on a gas well operated by thePan American Petroleum Corp. in Kansas, and

the process is now used in more than 90 percento natural gas and oil wells.16

In hydraulically racturing a well today, alsoknown as stimulating it, drillers inject a mix o

water, sand and chemicals (some o them toxic)under extremely high pressure. Te process,

which uses anywhere rom tens o thousands to

millions o gallons o uid, creates new racturesin the rock or re-opens pre-existing natural rac-tures. Te sand props the ractures open, dra-matically increasing production. Te chemicals

acilitate various aspects o the process, including helping to thicken the uid so that sand can becarried arther into the ractures.17

Te industry maintains that hydraulic ractur-ing has never contaminated groundwater. oour knowledge, there have been a million wells

racked, and no documented cases o contamina-tion o groundwater rom hydraulic racturing,

Exxon CEO Rex illerson told the House Energand Commerce Committee in January 2010echoing other industry representatives.18

In its 60-year history, hydraulic racturing hnot resulted in a single case o water contamintion a act rein orced by the EnvironmenProtection Agency, wrote Lee Fuller, executidirector o Energy In Depth, an industry-backe

website, and vice president o government retions or the Independent Petroleum Associatio America, in a 2010 letter to the Ithaca (N.Y

Journal.19 A 1987 Environmental Protection Agenc

report tells a di erent story.In concluding that hydraulic racturing ca

and did contaminate groundwater, the EPAdetailed its investigation o a contaminated wa

well on land owned by James Parsons o Rip

W. Va., a town o 3,300 in Jackson Counthal way between Charleston and ParkersbuTe case summary reads:

In 1982, Kaiser Gas Co. drilled a

gas well on the property of Mr. James

Parsons. The well was fractured using a

typical fracturing uid or gel. The residual

fracturing uid migrated into Mr. Parsons

water well (which was drilled to a depthof 416 feet), according to an analysis by

the West Virginia Environmental Health

Services Lab of well water samples taken

from the property. Dark and light gelati-
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nous material (fracturing uid) was found,

along with white bers. (The gas well is

located less than 1,000 feet from the water

well). The chief of the laboratory advised

that the water well was contaminated and un t for domestic use, and that an alter -

native source of domestic water had to

be found. Analysis showed the water to

contain high levels of uoride, sodium,

iron and manganese. The water, accord-

ing to DNR of cials, had a hydrocarbon

odor, indicating the presence of gas. To

date Mr. Parsons has not resumed use of the well as a domestic water source. (API

states that this damage resulted from a

malfunction of the fracturing process. If

the fractures are not limited to the pro-

ducing formation, the oil and gas are lost

from the reservoir and are unrecoverable.)

Parsons Well Was Drilled and FracturedOn Aug. 8, 1982, according to records on le

with the West Virginia Ofce o Oil and Gas,the state issued a permit to Ravenswood, W. Va.-based Kaiser Exploration and Mining Co. to drilla natural gas well on the Parsons property. By

Aug. 25, Kaiser had bored through ten layers o shale, limestone and sandstone to complete the4,572- oot-deep well, which reached a DevonianBrown Shale ormation that is similar to theshale ormations where companies are drilling

or natural gas today. Te company was seeking

to extract gas rom a pay zone between 4,2and 4,364 eet underground, nearly 4,000 ebeneath Parsons water well but less than tw

ootball elds away horizontally.20

On Aug. 31, Kaiser ractured the well in tpay zone with more than 13,000 gallons o wat60,000 pounds o sand and 760,000 standarcubic eet o nitrogen injected at a pressure oto 3,100 pounds per square inch.21 [By comparison, water generally ows through a re hosebetween 100 and 150 pounds per square inch.22]

West Virginia state records show that Kaisused three layers o casing and cement to seal new gas well rom adjacent rock ormations that Jerry ephabock, a state inspector,checkedthe well three years laterand ound the casing ancement to be in compliance with state standard(State records do not re ect any earlier inspecti

o the casing and cement).23

Prior to reviewindocuments associated with the case, EWG spokbrie y with ephabock by telephone, but he dinot comment substantively. ephabock did norespond to two later calls seeking comment.

Parsons water well was lined with a steel casiaccording to a state well inspection orm andlawsuit Parsons later led.24

Gas, Gel in Parsons Water Well A year and a hal a ter Kaiser ractured

gas well, Parsons well water became pollut
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Parsons declined to speak to EWG about theincident, citing privacy concerns, but a well in-spection ormcompleted in June 1984 by the

West Virginia Department o Mines Ofce o Oil and Gas reported that a problem rst devel-oped in March-April 1984 when someone (the

orm does not say who) smelled a rotten egg odorcoming rom the water well. In June, there were

white bers and natural gas in the water. Gasin water wellwill burn at vent tube, the statereport said.25

On Oct. 2, 1984, Michael Lewis, an engineer with the West Virginia Ofce o Oil and Gas, wrote in a letter to Parsons that the well drilledon your property by Kaiser could have been a possible source o contamination as you havesuggested. Te Ofce o Oil and Gas, however,can not determine ault or liabilities in such a

matter. State law does address this matter inCode 22-4-19, which says there shall be a re-buttable presumption that any oil or gas welldrilled within 1000 eet o a water supply isthe proximate cause o contamination or de-privation o such water supply I know youare concerned about compensation or yourtrouble and expenses incurred with the waterproblems. Te Ofce o Oil and Gas has nomeans o awarding you compensation. Shouldyou eel that Kaisers well was indeed the sourceo contamination to your water and that they,

there ore, owe you compensation and will npay, your only recourse is to le a civil suit damages. In such an action, Code 22-4-19 is applicable and or your protection.26

Te West Virginia Department o PublicHealths Environmental Health Services Lab colected and tested vesamples o Parsons w

water between June and November 1984.27 OnNov. 8, James E. Rosencrance, chie o the l

wrote to Perry Merritt, a water ofcial in JacksonCounty, regarding tests on three o the samples

an evaluation of the three reports

(copies enclosed) would indicate that

this water supply is contaminated from a

chemical point of view, which may have

resulted from oil and gas drilling opera-

tions in the vicinity of the Parsons water

supply. It is not unusual to nd high alka -

linity, high uoride, high sodium and hightotal dissolved solids in the underground

water in that particular area of Jackson

County, but is (sic) would be unusual to

nd the gelatinous material which we

isolated unless it had been used by the

drilling industry. This laboratory has iden-

ti ed the presence of hydrocarbons in

one of the samples, which is indicativeof petroleum type products. The labo-

ratory is not familiar with the chemical

characteristics of this well previous to

the samples analyzed in July, August and
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September of 1984. Any attempt to lter

the water would be futile since the ge-

latinous material would clog the lter in a

very short period of time. Such things as

sodium, uoride, high alkalinities and ex -traneous materials are not easily removed

in home type supplies. A new source of

water is suggested for the Parsons resi-

dence. 28

In one o the lab reports, Rosencrance typed,Te gelatinous material in this sample is not o bacterial origin. It does appear to be a gel typematerial and perhaps used as a sealant in the oiland gas drilling industry. Microscopi[c] examsrule out bacterial populations.29 In another report,Rosencrance described dark and light gelatinousmaterial indicative o a gel.30 In a third report, henoted: Microscopic examination reveals large

glossy gelatinous masses indicative o a gel. Tere were numerous rod-shaped particles present which were not readily distinguishab[le] as a nuisance bac-terial growth. Teodor is o a putre ying descrip-tion.31

According to legal records in the Parsons case,Kaiser commissioned BCM, a company based in

Dunbar, W. Va., to conduct its own test o Parsons well in November 1984. In March 1985 it com-missioned a second testby NOWSCO Well ServiceLtd., based in Calgary, Canada. NOWSCO con-cluded that these results are indicative o very resh

water no contamination rom rac water is evidin the sample rom the water well. Te BCM repordid not draw a conclusion.32

BCM, NOWSCO and the West Virginia statelab did not report testing or benzene, toluene, etylbenzene or xylene (known as B EX), commpollutants in drilling and racturing, nor did thereport testing the chemical composition o tgel.33 An employee at BCMs ofce in PlymouthMeeting, Penn., said the company no longer haslaboratory and she did not know how to reach thos

who worked or the lab in the 1980s. NOWSCO now owned by B.J. Services, one o the worlds larhydraulic racturing companies, according to a repsentative who answered the phone at NOWSCO

ormer ofce in Calgary. A phone message le t lNovember or one o the NOWSCO representativlisted on the lab report was not returned.

On April 3, 1985, Rosencrance wrote to Parsonthat it is our understanding that a gas well was rtured within 600 eet o your water well and mayinvolved with the pollutants ound in the water. Terare no unds or programs available within the Sto West Virginia which would nancially assist yin correcting the pollution problem with your we

water.34 Rosencrance died on June 24, 1999, according to an obituary in the Charleston Gazette.35

On Feb. 4, 1986, Parsons and his wi e, N. RutParsons, led suitagainst Kaiser in the Circuit Couro Jackson County, W. Va., seeking $50,000 (equiv
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lent to $100,000 today) in compensation or damagesto their water well, according to court records. Kaiserdenied the charges. On May 29, 1987, the partiesagreed to anundisclosed settlementand the case wasdismissed.36

R.A. Pryce, the agent or Kaiser Gas listed in thestate records, passed away several years ago, said hisson, Lance, in a telephone interview.37 According tostate records, Kaiser has been taken over by a succes-sion o companies since it drilled the well on Parsonsproperty. It is now owned by Dallas-based EXCO

Resources (WV) Inc. Larry Sanders, the regulatory manager or EXCO, told EWG in November 2010,that he had passed questions about the companyspast and present drilling operations to EXCOs legaldepartment. Te legal department has not responded.

On the same day that the Parsons settled withKaiser, ed M. Streit, deputy director o West Vir-

ginias Inspection and En orcement Division, said ina letter to a lawyer representing several state oil andgas associations, including the West Virginia Oil andNatural Gas Association, that as a result o Parsonscase, the state had discovered a previously unknownsource o resh water underground near Parsons water

well and had implemented tougher requirements orcementing oil and natural gas wells nearby.38

Gel in Water Consistent with Fracturing While the West Virginia lab did not conclude

that hydraulic racturing caused the contamina-

tion o Parsons well, the gel ound in the wais consistent with contamination rom hydraul

racturing uid. Drilling companies have used gin hydraulic racturing since the process was developed in 1947, bolstering the EPAs conclusion that the gel in Parsons water came rom turing. In the Stimulation reatment Handbook,published by PennWell Books in 1985, chemiand industry consultant John W. Ely wrotthat, Te rst racturing uid, utilized in thelate 1940s, was war surplus napalm. Napalm

an aluminum gel used to thicken gasoline. Ithe 1960s, Ely wrote, companies began usinguar, an additive ound in ood, to make rturing gels. Ely noted that this material walso marketed as the toy called Slime.39

According to the EPAs 2004 study, gels aimportant in racturing uid because they c

carry sand or other proppants deeper introck ractures than water alone. Proppants lerally prop open the ractures to prevent the

rom closing. Diesel uel has been requeused in lieu o water to dissolve the guar powdbecause its carrying capacity per unit volumemuch higher, the EPA ound.40

Te act that Kaiser reported using nitrogencould mean that the company used a nitrogenbased oam, called a oamed gel by EPA2004. Te agency noted that the most widelyused oam racturing uids employ nitrog
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or carbon dioxide as their base gas oaming agents can be used in conjunction with gelled

uids to achieve an extremely e ective rac-turing uid.41 Richard Morris, who inspectedthe gas well drilled by Kaiser in 1982 whenhe worked or the West Virginia Oil and GasDivision, said he did not recall details about the

well, but that the racturing mix would likely have contained a gelling agent, along withnitrogen, water, sand and oam. He added that

while it is possible that hydraulic racturing

caused the contamination, he believes anotherexplanation is more likely. Morris le t the stateagency later that year to open his own naturalgas and oil drilling company.42

Te hydrocarbons in Parsons water could beexplained i Kaiser used diesel or other petro-leum distillates in its racturing uid. Ofcials

in Pennsylvania and New York report that com-panies currently use a variety o petroleum dis-tillates in racking uid.43 A liquid hydrocarboncalled condensate, which typically comes tothe sur ace with natural gas and contains car-cinogenic benzene, could also have accounted

or the hydrocarbons and putre ying odor inParsons well. Marathon, a natural gas and oilcompany, has reported that condensate soursmells like rotten eggs, a smell similar to thatreported by West Virginia inspectors.44

Aquagel: An Alternative ExplanationFormer West Virginia inspector Morris sai

that while it is possible that the gel in Parson water came rom hydraulic racturing uid,believes that an underground limestone lay

would have prevented the uid rom migraing upward enough toward the sur ace to entan aqui er. A more likely explanation or contamination, he said, is that the material iParsons water was Aquagel, a mixture o btonite clay and water. Companies regularly inje

Aquagel into a well bore a ter drilling is complto remove loose rock cuttings, he said. Tescuttings can prevent cement rom orming a tigbond with the adjacent rock when drillers subsequently cement a wells steel casing into plaMorris said the aquagel could have migrated inthe underground aqui er be ore the company

stalled the layers o casing and cement to protthe aqui er rom drilling uids.45 Maurice Dusseault, a pro essor at the University o WaterloOntario who specializes in rock mechanics anda member o the Society o Petroleum Enginesaid that this explanation is, indeed, possible.

Te only way to know the exact source o th

gel would have been to test it and compare to the aquagel and the racking uid. Howevthere is no record that West Virginias or Kaiserscientists conducted such testing. I they hathey would have had to know the composition o



Kaisers racking uid or comparison in orma-tion that companies have routinely kept secret.

Were Older Wells the Source?Morris and Dusseault also said, however, that

the water contamination could have come romhydraulic racturing uid that migrated intonearby abandoned gas wells that had not beenproperly plugged and cased to seal them o . Fromthere, the uid could have traveled up the wells,broken out near the sur ace and migrated into the

aqui er serving Parsons water well. In the 1980s,the EPA, state regulators in Illinois and exas,and Congress investigative arm, the Government

Accountability Ofce, all highlighted this type o contamination rom the injection o natural gasand oil industry waste uids into undergrounddisposal wells.46 Tere are our old natural gas

wells dating to the 1940s within 1,700 eet o thegas well drilled on Parsons property in 1982

well within range o hydraulic ractures, accord-ing to modern industry and government studies.

In its 1987 report, the EPA noted the risk o contamination via old wells, citing Illinois inves-tigation o drilling pollution. o avoid degrada-tion o ground water and sur ace water, it is vitalthat abandoned wells be properly plugged, theEPA noted. Plugging involves the placement o cement over portions o a wellbore to permanent-ly block or seal ormations containing hydrocar-

bons or high-chloride waters (native brines). Lao plugging or improper plugging o a well mallow native brines or injected wastes [ rom

waste uid disposal well] to migrate to reshwaqui ers or to come to the sur ace through t

wellbore.47

Te EPA did not speci cally address the risko contamination via old wells as a result o draulic racturing, but both hydraulic racturiand injection disposal wells involve undergrouninjection o uid under pressure.

In the les or EPAs 1987 report at the EPheadquarters in Washington, D.C., is a 1985study rom the exas Department o Agricultu( XDA), which investigated 4,658 complainrelated to natural gas and oil production. Whea water well is experiencing an oil eld pollutiproblem (typically, high chlorides), the ex

agency ound, the pollution source is o ten dcult to track down. Te source could be a leak inthe casing o a disposal well, leakage behind casing due to poor cement bond, old saltwateevaporation pits, or, most o ten, transport o cotaminants through an improperly plugged abandoned well (underscore in original).48

In 1989, the General Accounting Ofce (nowthe Government Accountability Ofce) oundthat i these abandoned wells are not propeplugged that is, sealed o and have crackecasings, they can serve as pathways or injec
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brines [waste uids rom natural gas and oildrilling] to enter drinking water. Because ground-

water moves very slowly, any contaminants thatenter it will remain concentrated or long periodso time, and cleanup, i it is technically easible,can be prohibitively costly.49

According to a 1999 report rom the Depart-ment o Energy, there were then approximately 2.5 million abandoned oil and natural gas wells inthe U.S.50 At least tens o thousands o these aban-doned wells are located in states that are home to

shale ormations that companies have been target-ing in recent years or natural gas. According to2010 data supplied by the West Virginia Geologi-cal and Economic Survey, there are nearly 39,000documented abandoned wells in that state.51 New

Yorks Department o Environmental Conserva-tion estimates that 75,000 wells have been drilled

in the state since the 1820s and that about hal are undocumented.52 Te Pennsylvania Department o Environmen-

tal Protection estimates that 325,000 natural gasand oil wells have been drilled in that state since1859. O these, about 130,000 are currently operating, 47,000 are known to be plugged andabout 8,500 are unplugged. Te status o the re-maining estimated 185,000 wells is either partial-ly documented or unknown.53 In Ohio, accord-ing to 2011 data rom the Ohio Department o Natural Resources, there were about 64,000 doc-

umented plugged or abandoned natural gas anoil wells and 40,000 wells o unknown status.54

Dusseault said that, in general, it is highlimprobable that hydraulic ractures could itersect with an abandoned well and cause contamination, noting that it would take a complexseries o events or this to occur. First, compan

would have to have used enough uid to createracture that extended as ar as an adjacent w

Te odds o such long ractures are probabgreater in shale ormations such as the o

involved in Parsons well, he said, because shhas ew pores into which uid can leak o ; allmost o the uid is channeled into the ractuSecond, ractures tend to spread in just one drection, depending on the ormation in which

well is located, reducing the odds that a ractu would spread in the very direction o an aba

doned well. Tird, the old well would have to beimproperly plugged, enabling uid to migraand break out into an aqui er. And last, the raturing uid or other contaminants would have thave enough orce to make it rom the bottomthe old well to the aqui er.

Tose things put together make it improb-able, he said. However, he added that in the caso the Parsons well, in which there were multipabandoned wells in several di erent directionyour probability o intersecting those wells

just gone up tremendously.



Four Old Wells Within 1,700 Feet According to digital latitude and longitude data

and satellite maps provided by the West Virginia Geological and Economic Survey (WVGES),

when Kaiser drilled its gas well in 1982 on theParsons property, there were our abandoned gas

wells within 1,700 eet well within the docu-mented distance that hydraulic ractures canspread. One o the old gas wells was drilled in1941 less than 1,100 eet north o the gas welldrilled in 1982 and about 700 eet northeast o the Parsons water well. Te old well is in thebackyard o Janet and Paul Strohl, located justacross the road rom the Parsons home.55

Te Strohls, who can light a ame rom a vent on top o their own salt-tainted water well,suspect that this old gas well is the source o theircontamination (salty water is o ten produced

along with natural gas), which they discoveredthe moment they moved into their home in 2004and drilled or water. For washing and cleaning,they ll a Volkswagen Beetle-sized plastic tank intheir basement with rain water rom their guttersand supplement that by paying $106 per truck-load to have water delivered. Tey drink bottled

water.56

A rusted metal pipe sticking out o the ground,marked as well number 470350160, is still visibleat the site o the old gas well next to their ence.

According to records on le at the state Oil and

Gas Division, United Carbon Co., based inCharleston, W. Va., drilled the well between Jun13 and Sept. 21, 1941. On the way down, thecompany hit gas once and water three times, including salt water at 1,455 eet, be ore it copleted the well in a layer o limestone 5,244 down, approximately 700 eet deeper than th1982 gas well drilled on Parsons property.

On Sept. 21, 1941, United Carbon used theracturing technique o its day when it shot

well by exploding 80 quarts o glycerin betw

5,161 and 5,201 eet underground in a sandstonormation.57

According to the 2007 edition o the exComptroller o Public Accounts Oil Well Svicing ax Manual, in the years between 189and 1950, the oil industry used liquid and latesolidi ed nitroglycerin to stimulate wells by det

nating an explosive charge in the wellbore. Tobject o shooting a well was to racture theor gas bearing ormation in order to increaboth the initial ow and the ultimate recovery ooil Shooting o the ormation with explosi

was very hazardous to those working with the eplosives and requently damaged the well casipreventing subsequent selective treatment o tproducing zone. Ten with the advent o commercial hydraulic racturing in 1948, shooting oil or gas well was practically eliminated.58

State records show that United Carbo
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removed most o the casing when it plugged the well between Sept. 28, 1945 and Oct. 12, 1946,including all seven-inch casing above a deptho 4,800 eet. Tis casing might have protectedthe well at the 4,216 oot-to-4,364 oot depth

where Parsons 1982 gas well was ractured. Tecompany installed our plugs above this level withred clay, wood plugs and cement, beginning at2,360 eet down and at several shallower depths.59

Dusseault said that removing casings has beena relatively common cost-saving technique in the

industry, because they can be reused on subse-quent wells. He said that plugging a well withcement in the absence o steel casing probably creates a more e ective seal because the casing can corrode over time, providing a pathway orgas and other contaminants to rise up the welland potentially contaminate aqui ers. Te 1987

EPA study, citing the state o Illinois research,indicated that casings could corrode and lead touid migration.60

Dusseault has also noted in a published paperthat vertical pathways are likely to develop due toshrinkage and racturing o cement placed betweenthe casing and rock wall. Te upward pressure o natural gas likely exacerbates the ractures, he wrote.Both Dusseault and the EPAs 1987 study also indi-cated that cement alone would not necessarily guardagainst the upward migration o contaminants.61

Dusseault said that it is virtually impossible to

know whether a company had properly sealed well.

Was the cement high-quality cement? Dusseault asked in an interview with EWG. Was properly placed or did they just ll out the ormTe records rom [old] wells are so bad, he saiNinety- ve percent o these things that are do[to plug a well] are done without the presenco a regulator, he said. He added that perhapthe only way to know whether an old well wproperly sealed would be to drill out the ol

cement and seal it again. Its a nightmare to trto x up those old wells, he said.62

Because o their own contaminated water wethe Strohls persuaded the state Department oEnvironmental Protection to re-plug the old ga

well in their backyard with cement in 2005. Ncasing in the well, the Ofce o Oil and Gasin-

spection and release orm read. Te agency re-plugged the well to a depth o 900 eet, but tStrohls have continued to see gas in their watand showed EWG researchers in June 2010 thathey could light a ame rom their well.63

Oil and Gas Divisionrecordsshow that UnitedCarbon Company drilled a second gas well neParsons property in 1941, this one approximate1,500 eet southeast o the gas well drilled in 19and about 2,000 eet southeast o Parsons wa

well. United Carbon drilled the well betwee Jan. 22 and May 13, 1941 to a depth o 5,21
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eet, approximately 640 eet deeper than the welldrilled in 1982. On the way down, the company hit water at our di erent depths. On May 13,United Carbon shot the well at a depth o 5,113 to 5,150 eet, using 75 quarts o glycerin.United Carbon plugged the wellbetween July 28and August 18, 1949. Te company pulled outmuch o its casing, but le t some o it in the wellat a depth o 4,216 to 4,364 eet, where Parsons

well was ractured. Te company plugged the wellusing alternating placements o cement, clay and

clay and stone.64 According to WVGES records, in 1941 the

Columbian Carbon Co. also drilled a gas well ata spot about 1,150 eet northwest o the 1982gas well on Parsons property and about 850 eetnorthwest o his water well the third documented

well within 1,700 eet o the 1982 gas well.

Te Columbian Carbon Company drilledthe old well between Sept. 16 and Dec.13, 1941 to a depth o 5,125 eet, 550 eetdeeper than Parsons gas well. Like UnitedCarbon, Columbian Carbon also shotthis well, this time on Dec. 14, 1941, at a depth o 5,051 to 5,106 eet. State recordsare unclear on exactly what substanceColumbian used to shoot the well, but itappears to have been 550 pounds o explo-sive, 80 percent o which was gelatin or, inthe terminology o the state orm, 550#

80% gelatin. Te Bureau o Alcohol, obaccand Firearms publishes an annual list o expsives that includes blasting gelatin, explosgelatins, gelatinized nitrocellulose and nitrgelatin explosive, suggesting that the compaused one o these types o explosives.65

According to the Oil and Gas Division recordColumbian Carbon plugged the well between Ju3 and July 13, 1944. Te company le t in placethe bottom 2,310 eet o seven-inch casing, whspanned the 4,216-to-4,364 eet depth at whic

Parsons 1982 well was ractured, and extracted rest along with portions o other casings. Recoindicate that the company set several cement pluin the well and injected aquagel between them ptentially an alternative source o the gel in Parso

water i it persisted underground or 40 years.66

Paul and Janet Strohl near their contaminated water well.
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Columbian Carbon drilled the ourth docu-mented gas wellnear the Parsons property in1941-1942 at a location about 1,700 eet north-east o the 1982 gas well and 1,600 eet northeasto the Parsons water well. Te company drilledthe well between Aug. 13, 1941 and Feb. 18, 1942to a depth o 5,160 eet, about 600 eet deeperthan the 1982 gas well. Columbian Carbon shotthe well between 5,073 and 5,133 eet deep with

what appears to have been 600 pounds o explo-sive, 80 percent o which was gelatin or, in the

terminology o the state, 600# 80% Gelatin.67 According to Oil and Gas Divisionrecords,

Columbian Carbon plugged the well between June 28, 1945 and July 9, 1945. Te company removed the casing at the depth o 4,216 to4,364 eet at which Parsons 1982 well was rac-tured, along with some o the other casing, and

set a series o cement plugs throughout the well.Te company used aquagel both in drilling andplugging the well, another potential source o thegel that later appeared in Parsons water well.68

Fractures Can Extend up to 2,500 FeetRecent industry and government studies show

that ractures can spread unpredictably under-ground, have broken into adjacent oil and gas

wells and can travel up to 2,500 eet horizontally,approximately 800 eet arther than the distancebetween the gas well ractured on Parsons

property in 1982 and the most distant o thnearby older gas wells.

On May 20, 2010, the British Columbia Oiand Gas Commission issued a sa ety advisa ter hydraulic racturing caused a large kickunintended entry o uid or gas, in an adjacegas well. Te commission reported that it waaware o 18 incidents in British Columbia anone in Western Alberta in which hydraulic ratures had broken into adjacent gas wells. Larkicks resulted in volumes up to 80m3 [about

100 cubic yards] o uids produced to sur aInvading uids have included water, carbodioxide, nitrogen, sand, drilling mud, other stimulation uids and small amounts o gas. Tesincidents occurred in horizontal wells with distance between wellbores o up to 2,300 the commission reported. It is recommended

the commission advised, that operators coopeate through noti cations and monitoring o adrilling and completion operations where raturing takes place within 1000m [3,280 eet]

well bores existing or currently being drilled.69

Engineer and drilling industry consultanM.C. Vincent echoed the British Columbia commission in a paper published by the Society Petroleum Engineers that he presented at a hydraulic racturing con erence held near Housin January 2009.

Contrary to common expectations, he wrot
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there are numerous examples o ractures inter-secting o set wells [existing oil or natural gas wellsnear the well being ractured] but subsequently providing little or no sustained hydraulic connec-tion between the wells. Tere is an understandablereluctance to publish reports documenting theintersection o adjacent wellbores with hydraulic

ractures. Such in ormation could unnecessar-ily alarm regulators or adjacent leaseholders whomay in er that well spacing or racture treatmentsare allowing unexpected capture o reserves.70

EWG asked Vincent about his ndings by tele-phone and email, but he declined to comment onthe record.

According to his paper, ractures have inter-sected with o set wells in the Piceance eld inColorado and Utah, Wyomings Jonah eld,

Alaskas Prudhoe eld, exas Barnett Shale,

the Middle Bakken ormation in Montana andNorth Dakota, and the Dan Field in the NorthSea. Vincent noted that in one case in the BarnettShale near Fort Worth, exas, racking uidsentered the wellbores o ve adjacent vertical

wells, temporarily halting gas production.71

In the design o hydraulic ractures, it isnecessary to make simpli ying assumptions,Vincent wrote. Although computing tools haveimproved, as an industry we remain incapable o

ully describing the complexity o the racture,reservoir, and uid ow regimes.72

Another paper highlighting the complexity o hydraulic ractures, co-authored by MFisher, vice president o Business ManagemenPinnacle, a service o Halliburton specializingthe optimization o hydraulic racturing, re eto the highly complex racture behavior in tBarnett shale and the shales extremely comp

racture network. In the paper, published by tSociety o Petroleum Engineers in 2005, Fishand his coauthors noted that in one well drillein the Barnett Shale, a racture spread appro

mately 2,500 eet horizontally in two directionTe authors include the case cited by Vincent in

which ractures rom a well in the Barnett Shbroke into ve adjacent wells.73

Because o several actors, including presence o natural ractures, the authors wroa racture treatment in the Barnett is more like

to look like the very complex racture desction than the simple case. Tis allows a ractuairway to be created during a treatment wi

many ractures in multiple orientations, resultiin large sur ace areas potentially contributingproduction.74

Natural ractures may be activated (iopened) during a hydraulic racture treatmentthey added.75

In a telephone interview, however, Fisher sait would be unlikely or racturing to contamnate underground water supplies. He said h




rm has collected microseismic data on thou-sands o hydraulic racturing operations in exasBarnett shale and the Marcellus shale beneathEastern states and has ound that the racturesremain thousands o eet below underground

water supplies, a conclusion that he published in July 2010 in the American Oil & Gas Reporter,a Wichita, Kan.-based publication that servesthe independent sector o the natural gas andoil industry. He said his rm has not conducted

water testing, and the possibility o ractures con-

taminating water supplies by intersecting withabandoned wells was outside his area o research.76

Monte Besler, a consulting petroleum engineer who specializes in hydraulic racturing, co-au-thored a 2007 paper that raised concerns aboutthe unpredictability o racturing behavior inMontana and North Dakotas Middle Bakken

Formation. Several operators have reported di -culty keeping ractures contained within thetarget Bakken horizon, Besler and his coauthors

wrote. Tey delivered the paper at the Society o Petroleum Engineers Annual echnical Con er-ence and Exhibition in Anaheim, Cali .77

Like Fisher, Besler said that despite some un-predictability o racture spread underground,there is little chance that racturing would con-taminate underground water supplies, in largepart because ractures would not rise high enoughto contaminate underground water sources that

lie thousands o eet above.He said, however, that there are three scena

ios in which racturing could potentially cotaminate water supplies: 1) i a well is drilleda shallow ormation within several hundred vertically and horizontally o a water source distance most ractures are likely to travel, 2)

well is improperly cemented, allowing the escao racturing uids or hydrocarbons up the wbore, where they could pollute water closer the sur ace; or 3) i the hydraulic racture in

sects with an old natural gas or oil well that wimproperly plugged and cased, allowing uid migrate up the well and burst out near the sur acHe said that he has personally ractured hundreo wells and has never seen water contaminati

rom hydraulic racturing.We dont want produced water, he said. W

want oil and gas; we go out o our way to avoracking into water.78

West Virginians Say Problems Persist West Virginia residents who live near th

Parsons property believe that drilling companithere are not doing enough to address water contamination problems that may have been causeby hydraulic racturing. In these cases, old wmay have played a role, too.

In the case o contamination that the Strohsay they witnessed in 2006,state records show
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that when EXCO drilled and ractured its gas well, there were ve old gas wells within 2,500

eet, including one within 440 eet and a second within 1,000 eet. Each o the older wells wasdeeper than the well EXCO drilled, meaning thata horizontal racture rom EXCOs well couldhave intersected with the old wells i it traveled

ar enough.79 EXCOs gas well was less than 1,000eet rom the water wells that the Strohls said

became polluted. A Well Operators Report o Well Work, led

with the West Virginia Ofce o Oil and Gas,shows that EXCO began drilling the well neartwo Jackson County homes on July 20, 2006. On

July 22, according to handwritten notes on anin-spectors permit orm led with the Ofce o Oiland Gas, EXCO hit water could not continue had to cement to shut o . Te next day, the

company started drilling hit water again cemented to sur ace with expanding cement.On July 31, a ter boring through 17 layers o

shale, sandstone and limestone, EXCO nally completed the well at a total depth o 4,426 eet.EXCO used three layers o casing and cementto seal o the well rom the surrounding orma-tions.80

Te company then hydraulically ractured twoormations where it intended to extract natural

gas, a berea sandstone between 2,560 and 2,564eet deep and a brown shale ormation between

3,936 and 4,380 eet deep. EXCO ractured tsandstone with 6,174 gallons o gelled wate29,500 pounds o sand and 340,000 cubic eetnitrogen. Te company ractured the shale with7,812 gallons o gelled water, 49,000 pouno sand and 608,400 cubic eet o nitrogen. Srecords do not indicate when the racturinoccurred, but it is likely that it was be ore Au28, when David L. Cox, manager o geologcompleted the well operators orm or EXCO81

Shortly therea ter, the Strohls reported th

water wells or the two homes became pollutTe Strohls had a keen interest in the residents

water because they wanted to compare it to theown polluted well.

Be ore the 2006 drilling, they were actuabragging about their water being good, Janet sao the other residents. Itwas good, said Paul. yle

Mountain Water, the company that began delivering water to the two homes according to the Strohldid not return two phone calls requesting commen

Te Strohls have petitioned the Southern Jackson County Public Service District, on whicPaul Strohl serves as a board member, to extenpublic water lines to their home and other home

with contaminated wells, including some wethat they believe were polluted by natural gdrilling. In November 2010, the district submitted an application to a clearinghouse or edein rastructure unds to extend public water li
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to the Strohls general area. Te project would costapproximately $3.6 million or 60 users. In April2011, the clearinghouse said that the project wastechnically easible and orwarded it to a unding committee or review to determine the most coste ective and environmentally sound alternativeto address the areas drinking water needs.82

Couple Says Home Became UnlivableIn June 2010, at a board meeting o the public

service district, Paul Strohl introduced EWG re-

searchers to Dennis and ammy Hagy o Sandyville, W. Va., both in their early 50s, who said that the area near Route 33 East is not the only part o JacksonCounty impacted by drilling and racturing.

Te Hagys, who once lived in nearby Romance,said drilling and racturing ruined their water andle t their home, set on 80 wooded acres, unliv-able. In this case, too, previously drilled wellsnearby may have played a role.

Records rom the West Virginia Departmento Environmental Protection show that betweenNov. 15, 2007 and June 11, 2008, Equitable Pro-duction Co. o Charleston, W. Va., drilled threehorizontal wells in a Devonian shale ormationabout 1,000 eet north o the Hagys home and

water well. At least part o the ormation is in theMarcellus Shale, which holds one o the nationslargest natural gas deposits. Equitable drilledthrough several layers o sandstone, salt sand,

limestone and shale to depths between 3,410 an4,712 eet. Ten, inside each well, the compansteered the drill bit to bore horizontally anothe3,000 to 4,000 eet be ore hydraulically racing the wells.83

Equitable racturedthe rst wellin the LoweHuron Formation seven times on Feb. 19, 2008at a depth o 3,410 eet, using a total o 7,3gallons o water, 7.1 million cubic eet o nitroand 7,152 gallons o acid at a maximum pressuo 5,692 pounds per square inch.84 Equitable rac

tured the well in the Marcellus Shalesix times onFeb. 22, 2008 at a depth o 4,712 eet, usingtotal o 6,817 gallons o water, 4.8 million cu

eet o nitrogen and 6,018 gallons o acid amaximum pressure o 5,798 pounds per squainch.85 Equitable ractureda third wellthree timeson Feb. 23, 2008 at a depth o 4,153 eet, usin

a total o 974 gallons o water, 1.4 million cueet o nitrogen and 2,030 gallons o acid amaximum pressure o 5,498 pounds per squainch.86 Tere is no record that Equitable complet-ed a ourth wellthat was permitted or the sitbut the Hagys say the company began drilling

ourth well and then stopped.87

Te Hagys said that their water, which had beenpristine, started turning brown in July 2008, vmonths a ter Equitable ractured its third weDennis Hagy said they experienced weakneheadaches, nausea, eyes burning.
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Youd get in the shower and when you gotout, youd be sick, he said. ammy Hagy saidshe developed a rash. She added that she stoppedbottling water rom their well or her son to takeback to his home in Columbus, Ohio.

My son called and said Im going to have tostop drinking your water because Ive got someproblems with my throat, she said. Te amounto water in the Hagys wells and springs hasdeclined signi cantly, they said.88

According to a Complaint In ormation

Form dated Feb. 12, 2009, on le with the WestVirginia Department o Environmental Protec-tions Ofce o Oil and Gas, Dennis Hagy rstcomplained to the agency about water quality onNov. 17, 2008, approximately nine months a terEquitable ractured its third well. He and his

wi e have been sick or over a year with Nausea

(sic) and cramping stomach, etc. Silver akes andblack goo in well water, the orm said. DEP/OOG Inspector Jamie Stevens made inspec-tions on several occasions. No violations were

written.89

Stevens re erred questions to James Martin,the chie o the Ofce o Oil and Gas. Martintold EWG that he had no more in ormation than

what appeared in the states les.90

Te state Department o Environmental Pro-tection le included several testso the Hagys

water on behal o the department, Equitable

Production Co. and Dennis Hagy. Te tests wereconducted both be ore and a ter Equitable drillHowever, none o the tests looked or commdrilling-related contaminants benzene, toluenethylbenzene and xylene.91

According to the West Virginia Code o StaRules, drilling companies must conduct tests

water supplies i they are within 1,000 eet

a natural gas or oil well; the Hagys water w was just outside this distance, according to thHagys.92 Te rules require testing only or pHiron, total dissolved solids, chloride, detergenand any others (sic) parameters as determinby the operator [drilling company].93 Martinsaid that the state might require additional test

Dennis and Tammy Hagy in front of their former home.
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based on the nature o a particular complaintand, indeed, in October 2010, the state tested the Hagyswater or benzene, toluene, ethylbenzeneand xylene (B EX), among other contaminants.Te state detected no B EX. However, the stateconducted the tests more than two years a ter theHagys rst noticed contamination. Te EPA has

ound that volatile organic compounds such asB EX can biodegrade over time, so it is possiblethat the chemicals were once present and biode-graded by the time o the states test.94

Te Hagys said that on Nov. 13, 2008, Jeremy White, an Equitable landman who negotiatesdrilling leases with landowners, told them thatthe company had contaminated their water. Tenext day, the company brought bottled water totheir home, and it later paid or them to stay ina local motel or two months. But when Dennis

re used to sign a orm releasing Equitable romlegal liability and retained an attorney, the Hagyssaid company ofcials stopped paying or themotel and denied that Equitable had contaminat-ed their water. In November 2010, in a telephoneinterview, Kevin West, Equitables managing director o external a airs, said he would look into the Hagys case. Tree days later, EWG le ta voicemail or West, but he has not responded.

Next door to the Hagys, Ben Tornton, 23,said his amilys water well also went bad a ter thedrilling and racturing. We had some black stu

coming out the well that wasnt there be ore, said. Everybody got sick there or a while bethe amily began buying bottled water.

Tornton added that arm animals that haddrunk the well water began to die a ter thdrilling. He said he lost 70 chickens, eight or ningoats and 15 rabbits.

I dont know i it was rom the water, but th was doin ne be ore the drilling, he said, addthat he now waters his animals with rainwatcollected rom the roo o a shed. Tornton sa

he complained to Equitable, but the compandid not o er help. Tey aint never give menothing, he said.

State records show that existing wells in the ar were close enough that they could have acted conduits or the spread o contaminants rom hydraulic racturing on the Hagys land. In 194

God rey L. Cabot, Inc. o Charleston, W.Vdrilled a gas wellapproximately 2,000 eet northeast o Equitables wells.95 Te company drilledthe well between June 8, 1940 and November 181940 to a depth o 5,256 eet, more than 500 deeper than the deepest o the three wells drillon the Hagys property, meaning that a horizontal racture rom one or more o Equitabthree new wells could have intersected with told well. God rey L. Cabot shot the old wtwice on Nov. 19, 1940 once with 20 quarts oexplosive between 5,196 and 5,206 eet deep a
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S h ale

A q ui fe r

1,000 ft.

3,000 ft.

4,000 ft.

7,000 ft.

500 ft.

2

4 4

3

3

2007-08

2007

19402

2007-081

11 2007-08

Hydraulicfracturingfluid injected

Cracked or absent cement/ casing

Hagy Home

ThorntonHome

Hydraulic Fracture1

In 2007 and 2008, a Charleston, W.Va.-based natural gas company, Equitable Production Co., drilled andhydraulically fractured three natural gas wells on the property of Dennis and Tammy Hagy in Jackson Co.W.Va. In July, 2008, five months after Equitable fractured its third well, the Hagys say their water startedturning brown and they became sick. A neighbor, Ben Thornton, said his familys water also became pol-luted and that he and his family got sick until they switched to bottled water.

Families Say Drilling, FracturingPolluted Their Water

Jackson County, WV

Breakout into AquiferThese fluids can break into aquifers near thesurface if the old wells have deterioratingcasings, lack cement plugs or contain crackecement. This phenomenon is known as saltwater breakout. It is possible that hydraulicfracturing fluids migrated in a similar way inthe Hagys and Thorntons water wells.

Fluid MigrationGovernment studies have found that oil andnatural gas waste fluids injected underground canmigrate up old oil and natural gas wells.

Hydraulic FracturesAccording to industry studies,hydraulic fractures can extend up to2,500 feet horizontally within rangeof two preexisting natural gas wellsnear the Hagys and Thortons homes.Studies found that fractures elsewherehave broken into nearby oil and gaswells and that fracturing fluid hasmigrated up the old wells to surface.

Two Preexisting Wells NearbyTwo natural gas wells, one drilled in1940, the other in 2007, were locatedwithin 2,300 feet of the wells drillednear the Hagys and Thorntons.

43

2

1

Old Wells

Drilled 1940-2007

New Wells

Drilled 2007-08




then a second time with 15 quarts o explosivebetween 5,243 and 5,250 eet deep.

Te company sealed the wellbetween Sept. 13,1948 and Oct. 1, 1948 using several cement plugs.Te company removed some o its casing romthe well, including almost all o the casing below 2,019 eet, which would have been adjacent tothe depths at which Equitable ractured its threenearby wells.96

Equitabledrilled a wellin June and July o 2007approximately 2,300 eet west rom the three

wells it later drilled on the Hagys property.97 Eq-uitable drilled this preexisting well between June23 and July 26 to a depth o 5,130 eet, about400 eet deeper than the deepest o the three

wells drilled on the Hagys property. Equitableractured the preexisting well three times, once

with 900,000 standard cubic eet o nitrogen and

750 gallons o acid at a maximum pressure o 3,135 psi, a second time with 900,000 standardcubic eet o nitrogen and 600 gallons o acid at a maximum pressure o 2,155 psi, and a third time

with 247,226 standard cubic eet o nitrogen and350 gallons o acid with a maximum pressure o 2,145 psi. Tere is no plugging data or the wellin the public record; the state lists it as active.98

Te Hagys said nearly 70 people in their com-munity have signed a petition to the Southern

Jackson County Public Service District requesting public water by an extension o public water lines.

At least some o their neighbors signed becathey believe natural gas drilling had polluted the

water, they added. As o February 2010, the esmated project cost was $1.7 million, accordinto the Southern Jackson County Public ServicDistrict, though there is no guarantee that thiproject will be unded.99

In October 2010, the Hagys led suit against odrilling companies, including Equitable, in JacksoCounty Circuit Court seeking damages or impacto their property and health. In December 2010

the case was moved to U.S. District Court or thSouthern District o West Virginia, where it is nopending be ore Chie Judge Joseph R. Goodwin100

Summary and Recommendations:Contrary to industrys insistence that hydraul

racturing is sa e or underground water suppEWGs investigation established that hydraul

racturing poses signi cant risks to the drinki water sources on which more than 100 millio Americans depend. Te EPAs 1987 report,combined with industry and government papershowing that ractures can spread unpredictaband can intersect with adjacent wells, strongindicate that hydraulic racturing puts the

water supplies in danger. Fracturing involves thuse o toxic chemicals and is designed to open uderground passages or natural gas and oil, who ten come to the sur ace with naturally occ
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ring toxics such as benzene. Te prevalence o abandoned wells that could serve as conduits orcontamination, current allegations o racturing contamination, a lack o rigorous water testing and the industrys secretive practices all intensi y the concern. Local, state and ederal governmentsshould take the ollowing steps to protect watersupplies and human health, recognizing that hy-draulic racturing is only one part o the drilling process and that other components o drilling carry their own risks:

1. Implement a moratorium on hydraulicracturing near drinking water supplies

until rigorous scienti c investigation es-tablishes the risks o racking. Be ore

racturing is allowed near water supplies,citizens and policymakers must know therisks so that they can make in ormed de-

cisions about when and how it shouldbe permitted. Industry and governmentstudies show that ractures can spread upto 2,500 eet underground and that hy-draulic racturing can open natural rac-tures, suggesting that the moratoriumshould apply to a considerable margin

around water sources.2. Repeal the exemption or hydraulic rac-

turing under the Sa e Drinking Water Act. Te act is speci cally designed toprotect underground drinking water rom

the spread o contaminants through underground injections. It already covetens o thousands o disposal wells i

which the drilling industry injects wasteincluding racturing uid. Te law shoulapply to hydraulic racturing, too.

3. Require pre-drilling surveys to identi yand remediate old abandoned and deteriorating wells and conduct seismic testinto locate and avoid natural ractures.Mandate testing o water supplies with

2,500 eet o drilling operations:a. be ore drilling beginsb. a ter drilling and be ore racturing, determine i the drilling process itsel an e ect on water supplies, andc. a ter racturing, to determine i raturing is having an e ect on drinking

water supplies.Labs should conduct tests or benzene,toluene, ethylbenzene, xylene and otherlikely contaminants rom natural gas anoil operations. ests should use standardtest methods and should be designedto determine whether chemicals exceed

established sa e levels.4. Require companies to publicly disclo

the contents o their racturing uids that the public can know whether th

uids are sa e and researchers can kn




what chemicals to test or. Disclosureshould occur be ore and a ter racturing and should be accessible to the public,including mailing notices to nearby resi-dents and identi ying each chemical by itsunique Chemical Abstracts Service (CAS)registry number. CAS numbers wouldallow scientists, regulators and citizens toknow precisely what substances are being used and would acilitate accurate testing o potentially contaminated water sources

such as wells and springs.5. Require all drilling companies to use non-

toxic tracers in their racturing uid andrequire testing o nearby water supplies orthese tracers a ter racturing. Te presenceor absence o the tracers months or yearslater would enable scientists to link con-

tamination to racturing or determinethat there is no link.



References1. West Virginia Division of Environmental Protection. Office of Oil andGas, Well Operators Report of Well Work, API No. 47-035-02717, Aug.28, 2006. West Virginia Department of Environmental Protection. Inspec-tors Permit Summary Form, API No. 47-3502717, received Oct. 10, 2006.

2.Interview with Janet and Paul Strohl (June 16, 2010). Telephone inter-views with Janet and Paul Strohl (Oct. 27 and 28, 2010).

3. U.S. Geological Survey. Briefing on Contaminants in GroundwaterUsed for Public Supply, News Release, May 14, 2010. Accessed onlineDec. 6, 2010 at http://www.usgs.gov/newsroom/article.asp?ID=2462.

4. U.S. Environmental Protection Agency, Report to Congress: Manage-ment of Wastes from the Exploration, Development, and Production ofCrude Oil, Natural Gas, and Geothermal Energy, Dec. 1987 [hereinafterEPA 1987].

5. EPA 1987, supra note 4, at IV-11.

6. American Petroleum Institute. API Comments on Preliminary Draft Re-port to Congress on Oil, Gas and Geothermal Wastes, Aug. 10, 1987, at1375, 1416 (on file at EPA Docket Center, F-88-OGRA-SO679.) An on-line glossary on the website of Schlumberger Limited, one of the worldslargest hydraulic fracturing companies, says that a workover operationinvolves the repair or stimulation of an existing production well for thepurpose of restoring, prolonging or enhancing the production of hydro-carbons. See Schlumberger, Oilfield Glossary, Workover, noun, drilling.Accessed online Oct. 28, 2010 athttp://www.glossary.oilfield.slb.com/ Display.cfm?Term=workover. Hydraulic fracturing is a form of stimulation;hydrocarbons include natural gas and oil. The detail write-up may havebeen the second document about the West Virginia case included withAPIs comments. See U.S. Environmental Protection Agency. DamageCases Report Form and Summary, File Ref# WV17, Mar. 4, 1987 (on fileat EPA Library, Washington, DC).

7. Independent Oil and Gas Association of New York et al. Com-ments Regarding the United States Environmental ProtectionAgencys Report to Congress with Respect to the Management ofWaste from the Exploration, Development and Production of CrudeOil, Natural Gas and Geothermal Energy, Mar. 14, 1988, at 1223(on File at EPA Docket Center, F-88-OGRA-00073).

8. EPA 1987, supra note 4, at IV-9 and IV-11.

9. EPA 1987, supra note 4, at IV-1, IV-2, IV-9..

10. Wilson, Weston. Letter from Weston Wilson, EPA Employee, Denver

Colorado to U.S. Senator Wayne Allard et al., Oct. 8, 2004. Acceonline November 8, 2010 athttp://www.earthworksaction.org/publtions.cfm?pubID=372. Hamburger, Tom and Alan C. Miller. A ChanLandscape: Halliburtons Interests Assisted by White House, Los AnTimes, Oct. 14, 2004, at A1.

11. Safe Drinking Water Act Hydraulic Fracturing Exemption. Pub. 109-58 (codified at 42 USC 300h (d)(1)(B)(ii) (2008)). Congress exed fracturing from the Safe Drinking Water Act except for fracturindiesel fuel.

12. U.S. Environmental Protection Agency. Evaluation of Impacts tderground Sources of Drinking Water by Hydraulic Fracturing of CoMethane Reservoirs, Final, June 2004, at ES-7 [hereinafter EPA 20Accessed online Mar. 13, 2009 athttp://www.epa.gov/safewater/uwells_coalbedmethanestudy.html.

13. Vincent, M.C. Examining Our Assumptions Have Oversimptions Jeopardized Our Ability to Design Optimal Fracture TreatmPresented to 2009 Society of Petroleum Engineers Hydraulic FractuTechnology Conference held in The Woodlands, Texas, Jan. 19-21, 20Published by Society of Petroleum Engineers, Number SPE 1192009. Schlumberger, Oilfield Glossary, Flowline. Accessed online N2010 at http://www.glossary.oilfield.slb.com/Display.cfm?Term=fl(defining a flowline as a pipe on the surface that directs drillingflowing out of the wellbore into equipment for treating the mud; aline can also be a surface pipeline for oil, gas or water that connectswellhead to production facilities or to an arrangement of piping uscontrol or monitor fluids known as a manifold). Schlumberger, OilfieGlossary, Test Separator. Accessed online Nov. 2, 2010 athttp://wwwglossary.oilfield.slb.com/Display.cfm?Term=test%20separator(definingsurface test separator as a vessel used to separate and meterrelativelsmall quantities of oil and gas.

14. EPA 1987, supra note 3, at III-48. Illinois Oil Field Brine Dispossessment, Staff Report, Illinois Environmental Protection Agency, Illinois Oil Field Brine Disposal Assessment, Phase II Report, Illinovironmental Protection Agency, 1981. Status of the Brine Problemlinois, Illinois Department of Energy and Natural Resources, DocuNo. RE-EA-85/05, 1985. Texas Department of Agriculture, Deparof Natural Resources. Agricultural Land and Water Contamination Injection Wells, Disposal Pits, and Abandoned Wells used in Oil andProduction, 1985. U.S. General Accounting Office, Report of the Cman, Environment, Energy, and Natural Resources, Subcommittee, C

mittee on Government Operations, House of Representatives, July 1

15. Texas Department of Agriculture, supra note 14, at 13.

16. EPA 2004, supra note 11, Appendix A. Texas Comptroller of PuAccounts, Oil Well Servicing Tax Manual, Chapter 3, Description and Gas Well Services. Accessed online Oct. 22, 2010 athttp://www
http://www.glossary.oilfield.slb.com/Display.cfm?Term=workoverhttp://www.glossary.oilfield.slb.com/Display.cfm?Ter

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