This is still being editted.
This is my comments related to a questions regarding the potential for Free Water Testing to citizens on low to fixed income as it relates to Marcellus Shale Drilling
1. The presumption should be that the water is potable and we do not have elevated levels of barium, strontium, salts, Volatile Organics, SOCs, or radiologicals. In general, this is true for most PA, but 30 to 50% of private wells have issues NOW, but these problems tend to be related to pH, bacteria, corrosivity, iron, manganese, sulfur, and in some regions methane gas.
2. If the Gas Company or other business or entity that plans to conduct work or operate in this area does not agree with this assumption, then the Gas Company or entity needs to conduct baseline testing.
3. The state regulates the minimal radial distance for this testing currently at 1000 feet, this should be increased. This distance needs to be reflect the actual extent of the horizontal legs for the well. Therefore, it is likely that regional water testing (surface and groundwater is needed) - probably we are looking at radii approaching 1 mile with a good minimum being about 0.25 miles. It would be advisable for the companies to compile information on well depth, yield, static water level, and well construction.
4. The person requesting the permit or conducting the activity may want to protect themselves by testing a larger area or taking a regional approach. This way they would protect themselves from pushes or migration of gases or other substances, not related to their activities.
5. The Gas Companies or entities need to use third party contractors that carry a professional license in PA to conduct this sampling or to oversee the baseline testing and third party certified laboratories. There can be no ownership or interest in either. Also, the baseline testing should be done only after the well has been properly purged. See presentation at http://www.water-research.net/powerpoint/index.htm
6. If every citizen could get basline testing for free - What to test? - we have other problems or concerns than natural gas drilling.
Free Water Testing - Some have offered a Government Approach
1. Personally - It may be difficult to give monies to families or pay for their water testing because it opens a large can of "worms":
a. Funding Source – some state funding sources does not permit the use of the data for legal actions. I think there would be a solid push back if tax revenues or fees or fines were used for this effort. Fees and fines should go to help implement change in Pennsylvania.
b. I do not believe everyone needs at $ 1000.00 water test and some need way more, but who decides? Who does the work the state, local certified lab, - who collects? Fees will not be the same statewide and we do not need MORE State Empolyees.
Baseline sampling is not just about getting a water sample – but also includes documenting static water well, well flow, and type of existing system. We would not want to create a false sense of hope. Also, there is no way we (the state) can afford comprehensive testing that includes synthetic organics for every private well.
c. We test for Marcellus shale impacts, but what if the impact is a geothermal well leaking glycols, a fuel station, road salt and not brine water, etc.
Who is liable? Who is the collector- remember there are not “state approved collectors” ? Are we maintaining chain-of-custody?
Well drillers our licensed – but there is not real training or education requirements in PA.
Water treatment plant operators – licensed have experience, but do they want this liability and would they make the best expert witness for these low income homeowners?
d. Privacy –Does the citizen have to release the data if they get funding? If there is a problem with the water what is done ? Remember – it is common that 30 to 50+ % of private wells have a problem with meeting the total coliform standard- again this does not relate to Marcellus or industrial contamination may be agriculture or land-based wastewater. Also - Does this open the door to commercial solicitations for water treatment systems- If the Data is public???
e.Lack of support
In most counties, private wells are not regulated, no funding to help private well owners fix , and there are no formal statewide private well construction standards- a lot of recommendations.
Do we force people to fix wells? I know people that drink water from a stream, from cisterns, etc – Does this have to change?
I know people that purchase homes and only tested for total coliform and the problem was arsenic - What NOW?
What if these low income individuals rent? Is it the landlords obligation? (I would say yes and the landlord should pay for the testing).
f. Reliability and Need– the type of water quality baseline testing is not a one test fits all situation. Also – there is no state-wide certification for water samplers and what happens if someone needs to go to court?
g. What happens when we (the state) test a persons well and everything looks fine, but when it is retested the problem is a parameter that may have been high prior to drilling and that parameter was not tested. Who’s fault is this ??
A person receiving the free water test – may claim that the free water testing program was the expert and they are responsible or partially responsible – because the program should have recommended this parameter.
h. What about impacts related to chemicals that do not have a drinking water standard?
Personally – I am not a big fan of this approach. I think very basic water testing / screening is affordable and should be the responsibility of the well owners. Also, I think the regulations regarding baseline testing need to be expanded to include a slightly larger radius and may need to include other activities and industries. We do baseline testing for Marcellus shale, large volume wastewater, and mining, but how about gasoline stations, storage areas, pipelines, industrial / manufacturing sites, and large commercial.
Personally, I think one of the biggest problems is that individuals and some organizations are only recommending the very comprehensive testing– I no longer have a well and my annual water bill is over
$ 700.00 per year and when I did have a well I had it tested annually for total coliform, pH, and conductivity – cost about $ 40.00.
My recommendation on baseline testing:
1. Require gas companies or anyone seeking a permit to develop to conduct baseline testing? This would apply to a quarry, natural gas drilling site, gas station, or single family residential development. This testing should be specific to the potential impacts or concerns.
2.For citizens that want a third party test - Foundations and other could help support this effort through a 501 c3 with this mission. Some are forming - One example is Shale Test
I think the natural gas companies need to pay for water testing when they are working within a specific area. I think it is important that most of our groundwater contamination problems NOW, predrilling, are related to poor well construction and siting, underground storage tank program, stormwater runoff, and not the gas industry. I am not saying that natural gas may not be a problem, but we have a lot of other problems.
I would rather see the state do the following: (excluding issues related to natural gas)
a. Develop Private Well Construction and Placement Standards This could be a state program or implemented by the local township or county ! State, Industry, or Professional Association could develop the outline and allow local agencies to implement and run. Use state monies to support the implementation of this program.
b. Develop better standards for geothermal wells. This could be a state program ! State, Industry, or Professional Association could develop the outline and allow local agencies to implement and run. Use state monies to support the implementation of this program.
c. Require monitoring wells at gasoline stations and under facilities storing gasoline and oil. This could be a state program and paid by the developer.
d. Develop a program to fund repairing, replacing, and fixing private wells. This is better for a foundation or non-profit- not the state. Curent Program in NEPA - http://www.pnesolutions.org/
e. Providing a funding program to properly abandon private wells- through a microloan program that is funded by a charge on consumptive water use or a portion of fines associated with contamintation. This could be a state program - managed by a non-profit organization.
How about the state via the Basin Commissions and others establishing a fee of $ 0.005 per 1000 gallons of water used for consumptive water uses go into a micro-loan program to help fix private wells? - A local Non-profit organization is running a program and could implement a state-wide effort. A loan program is preferable, because this makes the program sustainable. The program could use a portion of the funds that have been paid back for direct grants to fix hardship cases, invest in other infrastructural improvements, and reinvest in the community.
f. I would hope the industry would fund community based private well programs either loan or direct grant programs that are direct grants than a state-wide effort – this way all businesses can participate in a local community effort.
g. We need to work as a community – this is the one reason I am working on the citizen database. The citizens release the data, but the dataset only includes approximate position and zip code, plus the data. If this is not done, the gas industry will know and control all baseline testing data in our state - they will be the only ones with all the data - NOT a GOOD Idea - please support the "Citizens Groundwater / Surfacewater Database- http://www.wilkes.edu/water.
h. Encourage local municipalities to develop well water construction standards and ordinances. I have been pushing this for 20+ years.
To this end, the Pocono Northeast RC&D Council has rolled out an educational program and a potential funding program for private well owners to fix problems. The program would offer a low interest loan (I think 1 %) to fix problems with private wells for families with income less than median and seniors within our 10 county area. To learn more – sign up for the Pocono Northeast RC&D Council newsletter – http://www.pnercd.org/
Test the water is only half the problem.
I think this may be a perfect role for a foundation, Business/ Community Network, but not PA Government or another Government Agency. If you interested- contact the Pocono Northeast RC&D Council
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