Saturday, December 1, 2012

COGCC Colorado Baseline Water Testing Groundwater Rulemaking 2012 Comments by Brian Oram

COGCC Commission Oil and Gas State of Colorado Groundwater Rulemaking 2012 - Revised Proposed Rule 609  - Colorado Baseline Water Testing.

1.Sampling locations: Initial baseline samples and subsequent monitoring samples shall be collected from two (2) groundwater sources or springs within a one-half (1/2) mile radius of the proposed Oil and Gas Location.
There is suggestive evidence of issues with water quality issues that extent beyond a half mile, but this is a great starting point, but all sources surfacewater, springs, and groundwater (shallow and deep) should be tested - Just just 2.  This approach does not adequately characterize the natural variation temporally (travel time), vertical, and related to surface activities. Extending to 1 mile if no sources are present is a good approach.

Previously sampled domestic wells. An operator may rely on groundwater sampling data collected from any domestic well located within one-half mile of a proposed Oil and Gas Location, provided the data was collected within the 18 months preceding construction of the Location, to satisfy one of the two sampling locations required by this subsection
This should not be used to preclude pre-existing data that may be in the hands of the private well owner as long as the data was collected using a chain of custody process with a third party sampler. and testing done by a certified laboratory.

d. Subsequent monitoring sampling: Subsequent monitoring sampling shall be conducted:

(1) Not less than 12 months, nor more than 18 months, following any well completion or facility installation; and
(2) Not less than sixty (60) months, nor more than seventy-eight (78) months, after the last sampling event performed pursuant to Rule 609.d.(1). Wells that are drilled and abandoned without ever producing hydrocarbons are exempt from this requirement.
If there are so few sources, I would recommend some type of annual screening for general water quality and then the full screening every 2 years.

Can a private well owner request monitoring if a problem is suspected?  Who do they contact?

e. Sampling and analysis

(1) Sampling and analysis shall be conducted in conformance with an accepted industry standard as described in Rule 910.b.(2).
I could not find Rule 910.b

pH, specific conductance, total dissolved solids (TDS), dissolved gases (methane, ethane, propane), alkalinity (total bicarbonate and carbonate as CaCO3), major dissolved anions (bromide, chloride, fluoride, sulfate, nitrate and nitrite as N, phosphorus), major dissolved cations (calcium, iron, magnesium, manganese, potassium, sodium), other elements (barium, boron, selenium and strontium), presence of bacteria (iron related, sulfate reducing, slime and coliform), total petroleum hydrocarbons (TPH) and BTEX compounds (benzene, toluene, ethylbenzene and xylenes). Hydrogen sulfide shall also be measured using a field test method. Field observations such as odor, water color, sediment, bubbles, and effervescence shall also be included. The sample location shall be surveyed in accordance with Rule 215.

First baseline sampling should include: arsenic, ammonia, copper, lead, aluminum, zinc, heterotrophic bacteria, pH (field), conductivity (specific conductance)(field and lab), TDS (lab), Total suspended soilds (lab), turbidity (field), ORP (field), foaming agents,  and all 21-regulated and unregulated VOC, plus TIC (tentatively identified compounds).

Add alpha, beta, and uranium.

Analysis should require a cation and anion balance analysis and other QC/QA procedures to screen the data.
Note: I well that has a problem with nuisance bacteria will have a corrosion related problem that could impact the copper, lead, and zinc content of the water.

(3) If free gas or a dissolved methane concentration greater than 1.0 milligram per liter (mg/l) is detected in a water well, gas compositional analysis and stable isotope analysis of the methane (carbon and hydrogen – 12C, 13C, 1H and 2H) shall be performed to determine gas type.

(3) Copies of all test results described above shall be provided to the Commission Director and the water well owner within three (3) months of collecting the samples. The analytical data and surveyed well locations shall also be submitted to the Director in an electronic data deliverable format.
Hopefully - mailing is not the only notice and if a problem occurs it would be advisable to provide some guidance with respect to this notice. In cases where the results do not violate a health or a potential health hazard- getting a report in 3 months may be ok - a month is more reasonable 
If the results suggest a potential health concern, then the homeowner should be notified in a much quicker fashion - especially if this is a private water well.  Again there should be some specifics.

Just my thoughts

Training - we offer training courses for individuals that conduct baseline water sampling.
Private Well Owners - we provide assistance to private well owners with reviewing and evaluating water quality data.
Plus we have a Free Water Quality Helpguide.
Plus if you (private water system owner) need assistance inside of PA - PA Survey
If outside of PA - Go to USA Survey
We facilitate - Informational and Certified Water Testing


  1. Very interesting article! It's really on of the best things that should be regularly done. It's for the safety of many people. Drinking water should really be clean and potable.

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