Marcellus Shale Baseline water testing or Water Testing for Informational Purposes

What I have to test my water?

For the past 20 years, I have stressed the importance of water testing for private wells. In Pennsylvania, there are no statewide regulations that truly guarantee that a private well is properly constructed and that the water from the well is potable, i.e., drinkable. In Pennsylvania and other states, a private well is not defined as a public water supply system and not regulated by the PADEP or EPA.

There are some counties in Pennsylvania that do provide some regulatory oversight with respect to the siting, construction, and water quality for a private well beyond the generalized recommendation that private wells be located 100 feet from a septic system. In general, the EPA and other organizations have recommended that private wells are tested at least annually and the testing should be conducted using certified and approved procedures and/or conducted by a certified laboratory. Because of the large-scale and extent of the Marcellus Shale Formation and concerns related to the chemical and biological nature of the formation fluid and frac fluids, the primary recommendation from professionals, state agencies, and others is that private wellowners should have their water tested following the same process that is used for regulated water supplies.

 Now - it is even more critical to get your water tested. 
Water Testing Options-

Option 1- Testing Provided or Conducted by Gas Company.
Option 2- Legal Baseline Assessment
Option 3 - Informational Water Testing- not a legal baseline.

Option 1 - Gas Company Baseline Testing- Marcellus Shale
The gas companies may be required to collect baseline water quality samples from wells and possibly surfacewater features (springs) within a 1000 feet of the well.  They should be using third party contractors - hired professionals that are experience or trained and not empolyees of the Company.  Since there is no certification as a water sampler, the individuals should be working directly under the supervision of a PA licensed professional with expertise in groundwater systems/wells/ water treatment,  a certified water or wastewater operator, or an agent of a certified laboratory.  The Gas company should give you a copy of the results, on laboratory letterhead, and you should get a copy of the chain-of-custody sheet, field notes, and quality control data.

If the gas company collects and pays for the water analysis, the laboratory records will be owned by the gas company and will be maintained by the certified laboratory for up to 5 years. If you rely on this type of testing, it is critical that you maintain multiple copies of your report in a secure location. If you are negotiating a lease to permit the drilling on your property, it is critical that you include the baseline testing and frequency of the testing, i.e., before and post drilling monitoring, as part of your lease.  If possible - include some neighboring properties and surfacewater features.  YOUR COST is Zero.

In some cases, the gas companies are sampling larger areas and proposed changes in the regulations require a large radius.  This type of testing may not include all the parameters that may be critical to you.  If you had baseline tesitng completed and you want someone to review the results (NO Charge) - you can contact us (PA Residents - Others)

Option 2 - The Legal Baseline Assessment  - If you are outside of this 1000 foot zone or want to conduct your own baseline.

The sampling process used for regulated water supplies follows a protocol known as a Chain-of-Custody. For this process, a third-party person, i.e., not the wellowner or an interested party, that has been trained and approved by a certified laboratory will collect a water sampling following approved and standard practices. This individual will document the time and location of the testing, provide a specific listing of parameters to be tested, document the water conditions in the field, and in some cases conduct some type of field testing or analysis. The sample must be collected to document the water quality in the aquifer and not the well.  Therefore, it may be necessary to purge the well by running the water for 30 minutes or more. The proper purging process is discussed in our new booklet. The third party sampler should document the type of water source, i.e., well, spring, or surfacewater. If the water is treated, the third party sampler should document the type of treatment system. If the private well has a treatment system, it may be advisable to collect a water sample before and after the existing treatment system.

The sampler then properly labels the containers, completes the chain-of-custody documents, and transports the samples as required by the state-certified or National Environmental Laboratory Accreditation Program (NELAP) certified laboratory. The sampler's role is to make sure the samples were properly collected, preserved, and transported to the laboratory. When the sampler returns to the laboratory, the certified laboratory will review the sampling and collection process, check sample temperature, and review chain-of-custody sheet. If the sampler followed the laboratory protocols, the laboratory will accept the samples and sign the chain-of-custody documents. These documents will follow the sample through the laboratory testing process and a copy of this sheet will typically be provided with the laboratory results. The certified laboratory is required to maintain a copy of these records for a period of at least five years.

Parameters

Regarding the baseline water testing - it is recommended that the water testing be conducted for the parameters recommended by the PADEP, plus VOC's, MTBE, and surfactants. If your budget permits, it may be advisable to test for select semi-volatile organics (SOC's) and radionuclieds (Note Working on a Follow-up article). By using this process, the data that is collected should withstand cross-examination and be supportive of any legal action.  If you have other commercial or agricultural development in your area, it may be necessary to expand the baseline analysis to cover potential pollutants from these land uses and past practices.   Need some help or questions

Comment on Third Party Water Samplers

There are no statewide certification for water samplers, but it would be advisable to use an individual that is approved by the laboratory, an individual that carries a professional  license, an individual working under the direct supervision of a PA licensed professional, or by an agent for the laboratory. Because the sampling and laboratory testing may be part of a legal action, it would be advisable to use an individual that is a licensed professional or an employee of a certified laboratory. It would be best if this individual is experienced and has provided expert testimony in the Commonwealth.


Option 3 Informational Water Testing
Under this protocol, you are not trying to establish a legal baseline, but you are trying to check or monitor the status or condition of your water.  There are a number of laboratories that offer affordable water informational testing kits.  In some cases, you can purchase a mail order kit that cost less than $ 250.00 that provides the equivalent testing as a $ 1500.00 certified test kit.  For a partial listing of informational water testing services, please go http://www.check-water.com/

If you are looking for monitoring equipment or standards for your watershed group or organization - Visit the Water Quality Store.  There are some relatively inexpensive water testing kits and monitors for home use.

Thanks and Good Luck
Mr. Brian Oram, PG
http://www.bfenvironmental.com/

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