Bishop comment on FDEP Orangetree test of 1 July 2014

[Text of Dr. Bishop's email reply to Preserve Our Paradise's inquiry concerning the FDEP water quality tests trumpeted through the media on 1 July 2014.  PoP did not request a full report from Dr. Bishop because the tests were (a) conducted too late and  (b) drilled too shallow to be meaningful.  Also (c) the DEP conceded these test results were incomplete, with complete results, apparently in conformance to the DEP-Hughes consent order, apparently have not been conducted yet, are not scheduled for release until 1 December 2014, and even then may be suppressed as "trade secrets", per the consent order.]


The chemicals for which tests were done were indeed a cookie-cutter list, cheaper by the hundred, and arguably intended to obfuscate the purpose of the tests.  This is not even a close call; the list includes benzoic acid, which is so sparingly soluble in water that it cannot physically dissolve at hazardous levels, a fair number of phthalates (plasticizers) which are not used by the petroleum industry, and a large number of halogenated organics which may be problematic for water treatment systems that use chlorine, but not for drillers anywhere.  
Here are some chemicals, for which you provided photographs, which were conspicuously absent from the list:
Borate (or any boron), methanol and ethylene glycol, used in XLW-30G for cross-linking cellulose-based gelling agents.  
Mineral spirits (also known as deodorized kerosene), used in FRW-18 along with polymer microbeads as a lubricant.  If included in the tests, the material might have been referred to as C-20 to C-22 hydrocarbon, but it was not there under any name.
Inorganic peroxides of any kind, including the magnesium peroxide found in GBW-23. 
And although they were not photographed, there were no tests for any biocides (bromine-based or aldehyde), corrosion inhibitors (acetophenone derivatives, propargyl alcohol or thioglycolic acid), multi-purpose solvent additives (especially 2-butoxyethanol, used ubiquitously in petroleum projects), or flocculants (especially ammonium chloride).  There were also no tests for chemicals such as acrylonitrile, which are commonly used to coat sand particles in deep well projects.
Therefore, the simplest explanation is that the chemicals for which Hughes / FDEP conducted tests were carefully chosen to avoid any which are commonly used by the petroleum industry.
Also, as you pointed out, such shallow monitoring wells would capture only surface spills.

Date: Wed, 2 Jul 2014 13:28:22 -0400
Subject: Can anyone help determine if this testing was adequate?

The headline from the Preserve Our Paradise website reads as follows:

Tuesday, 1 July 2014.  FDEP announces no contamination at the Orangetree well in a press release that includes detailed results (pdf).  This was no real surprise, because the fracking at the Orangetree well occurred some 12,000 feet deep, while the USDW — the geological boundary of the Orangetree Underground Source of Drinking Water — begins about 2,200 feet deep.  Since the six monitoring wells only went down thirteen feet, the testing would only have been adequate to establish that no significant surface spillage had occurred at the wellsite.  However we cannot even reach this conclusion because nearly six months have passed since the fracking operation took place.  We also do not know if the Hughes/FDEP conducted tested specifically for the hazardous chemicals photographically identified at the wellsite.

Can anybody on this list comment further on the completeness of the contaminants the FDEP tested for or the adequacy of their methodology?  Specifically, I wonder if they tested for contamination by the fracking chemicals that were photographically identified at the well site.  They’ve been so disingenuous, it would not surprised me if they used some standard contaminant list that by-passed the photographed (proprietary Baker-Hughes) formulations.



Don Loritz
Vice President
Preserve Our Paradise, Inc.
239.449.8049 (voip)
937.361.0774 (cell)

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