Pittsburgh, Pa. – Today, the Marcellus Shale
Coalition (MSC) released a Recommended Practice (RP) for pre-drill water supply
surveys. This is the third in a series of recommended practices, all aimed at
reinforcing the MSC’s Guiding
Principles to “continuously improve our practices and seek transparency
in our operations” while furthering a fact-based dialogue that encourages
responsible American natural gas development.
Pennsylvania regulations require
natural gas producers to sample and test – with the owner’s consent – all water
supplies within 2,500 feet of a proposed Marcellus Shale natural gas well. These
pre-drill tests, which are conducted by certified laboratories, provide a
baseline analysis of water chemistry prior to site preparation and development
activities. Many natural gas producers test well beyond the 2,500 feet
requirement, and were doing so prior to Pennsylvania enacting these new
regulations.
According to the Center for Rural
Pennsylvania, nearly 40 percent of Pennsylvania’s water wells do not meet at
least one safe drinking water standard and another 20 percent of wells contain
pre-existing methane.
“For years, well before shale gas
production began in the Commonwealth, straightforward science has informed us
that Pennsylvania’s groundwater chemistry drastically varies across regions,”
said MSC president Kathryn Klaber. “This Recommended Practice builds upon what’s
required by law and lays out in great detail steps operators can take to help
ensure homeowners have a clear understanding of their water quality before
natural gas-related activities begin. These tests, paid for by the natural gas
producer, are shared with the well owners and state regulators, serving a
critical public health function in many cases.”
Developed by technical experts from a
host of MSC member companies, this RP recommends the following steps:
- A pre-drill survey should be
conducted on all identified water supplies within a given area of the well pad
surface location as required by the State Regulatory Agency
(SRA).
- Water supply sources such as wells,
springs and ponds should be evaluated prior to earth disturbance for site
construction or prior to spud. Consideration should also be given to sampling
water supply sources that are not currently in use.
- With the assistance of the water
supply owner, locate the water supply(ies) and sampling location(s). Use GPS
(preferably NAD83 datum) to determine and record the latitude and longitude of
each water supply.
- The samples shall be collected, in
accordance with all appropriate sample collection, preservation, handling, and
defensible chain-of-custody procedures. Appropriate sample collection procedures
can be found on the United States Environmental Protection Agency (USEPA)
website (www.epa.gov).
- Water samples shall be analyzed by an
SRA certified laboratory using USEPA SW-846 methods or drinking water methods
(where drinking water methods exist). For parameters that have a Maximum
Contaminant Level (MCL), the laboratory should be instructed to provide a
laboratory reporting limit no greater than the published MCL.
- Operators should inform the water supply owners and/or residents that any and all information/data collected will be provided to the owner/occupant and to the SRA (if required by state regulations) and, as such, the information could be disclosed as public information upon inquiry to the SRA.
Continued Klaber: “Additionally, the MSC is developing a
robust pre-drill water quality database. When complete, this first of a kind
library will serve as an important environmental and public health tool to help
address water quality challenges that have persisted in rural communities for
decades.”
The parameters they recommended
Alkalinity
Total Chromium
Oil & Grease
Total Arsenic
pH
Total Barium
Specific Conductance
Total Lead
Total Dissolved Solids
Total Selenium
Total Suspended Solids
Total Strontium
Chloride
Total Calcium
Sulfate
Total Iron
Total Hardness
Total Magnesium
Surfactants (MBAS/foaming agents)
Total Manganese
Benzene, Toluene, Ethylbenzene, Xylenes (BTEX)
Total Potassium
Dissolved Methane*
Total Sodium
Dissolved Ethane
E. Coli
Dissolved Propane
Total Coliform
Nitrate as N
Turbidity**
Comments
1. I am glad that a more uniform list is being recommended.
2. I would like to see the full range of VOCs and MTBE.
3. I would like to see glycols added to the list or at least added when the conditions seem correct.
4. I think the Guidance should include more on purging and documenting the water quality during the purging process to make sure the purge was adequate, but it is a good start.
5. During purging, the pH, mv or ORP, Conductivity, and Temperature should be documented. If possible, this is also a great time to measure turbidity.
6. I strongly recommend adding Total Aluminum to this testing.
7. I strongly recommend adding Bromide to this testing.
8. It would be nice if the guidance provided more information on detection limits, but I do like the fact that want the results reported in a uniform manner.
9. Would like to see testing for nuisance bacteria or heterotrophic bacteria when the conditions seem appropriate - probably 50% of the time.
B.F. Environmental Consultants Inc. provides training in proper baseline sampling practices, review and use of baseline testing data, and educating professionals to work with private well owners, plus we provide training and educational programs for private well owners.
B.F. Environmental Consultants Inc also does post drilling assessments and reviews.
The actual guidance document can be found here.
