Tuesday, July 15, 2014

Baseline Water Testing in Michigan - Protecting Private Well Owners

Baseline Water Testing the Michigan Approach

We recently had the opportunity to review the recommendations for baseline water testing in Michigan.  We completed this review based on a review of published geological data, historic land practices, and the potential for oil and gas development.   We have conducted a review of baseline water testing programs for Colorado, Ohio, Kansas, Texas, Pennsylvania and other areas and we have conducted training courses related to baseline water sampling.  In addition, we have reviewed a few 1000 baseline water quality test results and reviewed the common complaints associated with baseline water testing.    For Michigan, The Michigan Department of Environmental Quality Office of Oil, Gas, and Minerals has developed the Oil & Gas Pre-Drill Water Well Testing in September of 2012.    We looked to see if an updated document was available and would could not be found.   

The 2012 document indicates the following:

Tier 1 - General Oil and Gas Pre-Drill Screening- Basic Suite
Benzene, Toluene, Ethylbenzene, and Xylene (BTEX)
Total Dissolved Solids


Tier 2 - More Comprehensive Test
Oil and Gas

Specific Conductance
Total Dissolved Solids
Total Suspended Solids

T. Hardness

Methane, Ethane, Propane
Nitrate as N
As, Ba, Pb, Se, Sr, Ca, Fe, Mg, Mn, K, Na

Total Coliform
E. coil. 

On a separate website - I found the following comment:
*DEQ includes hardness in combined test for Chloride, which also 
includes Fluoride, Nitrate, Nitrite, Sulfate, Sodium and Iron.

**DEQ includes Ethane and Ethylene in its Methane test.

The DEQ document also states " should be noted that water well sampling provides water quality data for a single point in time. Water quality results can  vary considerably because of many factors, including: seasonally fluctuating static water levels, water well construction, use of the water supply, sampling technique, weather and atmospheric conditions. It is recommended that homeowners who wish to perform pre-drill sampling work with a professional environmental consultant and certified laboratory in order to: understand these natural variations in water quality; choose an appropriate sample suite of parameters; and to ensure the quality of the data obtained from pre-drill sampling and analysis. "

Overall, I agree with the concept of baseline testing, but at no time should document be interpreted to mean that the Tier 1 test will cover you in all cases and concerns and to be honest in most cases and concerns. The Tier 1 test, as proposed,  is NOT all you will need. 

Our general recommendations
1. The LEL, lower explosion level, of the wellhead space should be document during non-pumping and pumping conditions and the dynamic water level and pumping rate should be documented.

2. The most common water quality problems associated with oil and gas activity is dirty and discolored water, change in gas concentration, loss of circulation during drilling, and maybe changes in corrosion.  Therefore, water quality parameters such as iron, manganese, aluminum, lead, ethane, propane, barium, sulfate, turbidity, bromide, sodium, foaming agent, observation of the aesthetic quality of the water, and field monitoring for at least pH, conductivity, and ORP.

3. Will these additions be enough - Maybe / Maybe NOT- this is why you need to seek the advice of an expert.

4. Baseline water testing is not just about collecting a water sample and the court case starts when the third party agent walks into your home. 

Need more information - please do not hesitate to Contact the Keystone Clean Water Team at 

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