The Baseline Water Testing Process It is NOT Just About Getting a Sample

The Baseline Water Testing Process It is NOT Just About Getting a Sample
By Brian Oram, Professional Geologist
B.F. Environmental Consultants Inc.
Published in March ONG Marketplace

We have had the opportunity to witness a wide range of practices that have been called baseline testing. We have seen a team of 4 professionals working for the EPA in Dimock, Pennsylvania, take 4 to 5 hours to collect one water sample and we’ve seen a single sampler with virtually no training take 15 minutes to purge and sample a private well with no field measurements or even gloves. The potentially negative impacts of this wide variation in sampling techniques and experience is compounded by the lack of field documentation and a quest for that “single” list of parameters. This approach will make for great future lawsuits and media stories, but does little to generate the reliable data required by professionals, scientists, regulatory agencies, and the public.
The key elements to effective baseline testing should include:
a. A selection of parameters and indicators that meets the regional environmental conditions and addresses the historic and proposed activities and practices in the region and not just a simple list provided or recommended by a regulatory agency;
b. chain-of-custody practices with internal and external quality control (QC) and quality assurance (QA) that start and end with the certified laboratory working with a trained third-party professional;
c. field documentation, including notes, field measurements, and photos, that includes a summary of the existing condition of the private water distribution system;
d. field sampling done by third-party samplers that are either licensed professionals or specifically trained in the standard operating procedures of the certified testing laboratory, plus these individuals must have a working understanding of common water treatment systems; and
e. prior to releasing the data, the certified laboratory must validate and review the data, plus work with the third-party professional to confirm or check the reliability and validity of the results.
As part of our outreach efforts, we have been able to review baseline testing conducted by multiple entities. Here is just one example for your consideration.
The sample was collected by a non-professional, third party sampler, tested by a certified testing laboratory, and then given by a natural gas company to a private well owner. The sample was collected only a few weeks before drilling started. The well owner was given a report with the raw data, spike and recovery analysis, surrogate testing results, field data sheet, and a full listing of the methods and the laboratory certifications. When the homeowner, a royalty owner, asked if there was any problems, we provided them a list.
1. The field conductivity was reported at 250 uS/cm, but the certified laboratory data had reported a total dissolved solids of 1500 mg/L;
2. The cation and anion mass balance was out of balance by over 25 %;
3. Total metal values less than dissolved metal values; and
4. The well had arsenic at over 10 times the primary drinking water standard, but this was never flagged as a problem for the private well owner.
This data is not scientifically valid and does not make sense. It may be certified, but it is wrong and there is no time to collect another pre-drill sample.
As professionals, we have the obligation to attempt to get it right and to properly inform citizens when a problem is identified. It is critical that we implement a process to screen the water quality data before it is distributed to the community. To build trust, the data must be provided to the private well owner in a format they can understand.
Baseline testing can be a valuable tool for the environmental professional, gas drilling industry, and community. With proper planning, baseline testing can used to determine where additional documentation or monitoring is needed and to determine the location of systems or wells vulnerable to influence.
In our opinion, baseline testing is not just part of an environmental audit, but in many ways, it is an opportunity for the company and consultant to build trust in the community. At the same time, the company is attempting to mitigate risk by documenting pre-existing conditions, the data collected during this baseline assessment should be used to make critical decisions related to the use of best management practices and build trust in the community through education and outreach.
Baseline testing is a community issue. We ALL live downstream and we need to solve problems as a community. This is a great opportunity to make a positive difference in your host community
About the author:

Mr. Brian Oram is a licensed professional geologist with over 25 years experience in water quality, water testing, and environmental training and analysis. For Pennsylvania, B.F. Environmental Consultants Inc. just released a new booklet to help educate and inform private well owners and the company has been providing education and outreach throughout the United States through the Water Research Center. The Center is an internet hub where private well owners can access free information and request assistance for water quality issues. For more information, please visit http://www.bfenvironmental.com or http://www.water-research.net.

Published in March ONG Marketplace - very good issue on water, Naturally Occuring Radiation, water management, TENORM and much more.

New Education Guide for Private Well Owners (What Do the Numbers Mean?) - Published 2012
Guide that has been written to help educate private well owners on drinking water quality, water quality standards, assist in reviewing laboratory reports, and fixing a problem.

New Portal - http://www.private-well-owner.org  - Free Educational Resources and links to videos to help educate private well owners (not funded by any group, person, govt, or agency).

Private Well Water Quality Susquehanna County Dimock PA

Comment

1. Without predrilling data, it is not possible to comment on the cause for any water quality problems.

2. Where possible, I have noted situations where elevated levels of a water quality parameter exists in Pennsylvania.

3. If duplicate analysis provided, I attempted to use the highest reported value.

4. New Document - http://water.epa.gov/action/advisories/drinking/upload/dwstandards2011.pdf

5. This is not about cause and effect; it is about a review of the data.

Well – HW-20 (1/30/2012)

With the exception of the following parameters, the remaining values were reported as NOT Detected (U)

Heterotrophic Bacteria – 67 colonies per 100 ml ( I do not understand the J value).  The drinking water limit is < 500 colonies per 100 ml (OK).

Total Coliform < 1 colony per 100 ml (OK)

Aluminum – < 0.030 mg/L (Total) - drinking water standard ranges from 0.05 to 0.2 mg/L.   This parameter is regulated as a secondary drinking water standard, because of aesthetic reasons.   The treated water level of aluminum is < 0.030 mg/L.  (OK)

Anionic Surfactants –< 0.01 mg/L – the secondary drinking water standard for foaming agents is 0.5 mg/L.  (OK)

http://www.chemetrics.com/products/pdf/detergents.pdf

Arsenic – < 0.002 mg/L – drinking water standard is <  0.010 mg/L – this does not suggest any specific impact and arsenic is a common problem in NEPA – about 6 % of private wells have arsenic above 0.010 mg/L.  The treated water level of arsenic was

< 0.002 mg/L and treated and filtered < 0.002 mg/L.  (OK)

http://www.water-research.net/arsenic.htm

Barium – 0.0328 mg/L – the primary drinking water standard for barium is 2.0 mg/L –– this does not suggest any specific impact and barium is typically detectable in non-saline impacted water at a level of less than 1 mg/L. After treatment, the concentration is 0.0329 mg/L.  (OK)

Bromide – < 0.5 mg/L - In freshwater, bromide is typically less than 0.05 mg/L. Therefore, it would be advisable to retest using a method with a lower detection limit.

Other References

http://www.cdph.ca.gov/certlic/drinkingwater/Pages/MCLReview2012.aspx
http://water.epa.gov/scitech/drinkingwater/dws/ccl/ccl3.cfm#chemical

Boron –< 0.050 mg/L (Total) – no specific drinking water standard drinking water standard is available. EPA appears to have a long-term health advisory of 2.0 mg/L, but other states have limits that range from 0.6 to 1 mg/L.  

Source: http://www.epa.gov/ogwdw/ccl/pdfs/reg_determine2/healthadvisory_ccl2-reg2_boron_summary.pdf

http://www.who.int/water_sanitation_health/dwq/boron.pdf

Calcium- 22.40 mg/L (Total)– no specific drinking water standard drinking water standard is available.  After treatment, the level of Calcium is 22.10 mg/L.(OK)

Chloride –3.41 mg/L (OK) – drinking water standard is <  250 mg/L – this does not suggest any specific impact.   After treatment, the reported value was 3.1 mg/L (OK).

Chromium-< 0.002 mg/L (D) and the EPA/ PADEP primary drinking water standard is

< 0.100 mg/L (OK).

Copper – 0.0045 mg/L  (Untreated) - the secondary drinking water standard is 1.0 mg/L and the primary drinking water standard is 1.3 mg/L. (OK)  At the tap the level was 0.0039 mg/L.

Ethane –< 0.0012 mg/L  – No specific drinking water standard (OK)

Fluoride – 0.109 mg/L – drinking water standard is < 2 mg/L- PADEP drinking water standard is 2 mg/L.   After treatment, the reported value was 0.124 mg/L (OK).

Iron – < 0.100 mg/L (Total) – Iron is regulated as a secondary drinking water standard in Pennsylvania and the action limit is 0.3 mg/L.  Therefore, the total iron content does not exceed the secondary drinking water standard.  (OK)

Lead – 0.0024 mg/L (Total) - Lead is regulated as a primary standard (EPA and PA) at 0.015 mg/L, but the action level in PA for source water is 0.005 mg/L. (OK)

Lithium – < 0.200 mg/L (Total) – no specific drinking water standard drinking water standard is available, but EPA has recommend a level be below 0.7 mg/L    (OK)

http://www.water-research.net/Waterlibrary/privatewell/lithium.pdf

Methane –  < 0.0095 mg/L   – No specific drinking water standard.  The well water is below the new action limit of 7 mg/L.   After treatment, the level of methane is < 0.0095 mg/L. For more details, go to http://www.water-research.net/methanegas.htm

Magnesium-5.71 mg/L– no specific drinking water standard drinking water standard is available.  (OK)  The treated water level of magnesium was 5.57 mg/L.

Manganese– 0.0026 mg/L (Total) – Manganese is regulated as a secondary drinking water standard in Pennsylvania and the action limit is 0.05 mg/L.  Therefore, the total manganese content does not exceed the secondary drinking water standard.   After treatment the level is 0.0023 mg/L. (OK)

Nickel – < 0.001 mg/L  – no specific drinking water standard drinking water standard

is available, but the EPA has suggest a MCL of 0.1 mg/L.   (OK) 

http://www.epa.gov/ogwdw/pdfs/factsheets/ioc/tech/nickel.pdf

Potassium – <  2.0 mg/L (Total–  no specific drinking water standard drinking water standard is available (OK)

Sodium –6.21  mg/L  – no specific drinking water standard drinking water standard is available, but the EPA has added it to the Candidate List to provide more analysis.  The EPA’s initial value of 20 mg/L has been clearly identified as not realistic.  When chloride (salt is sodium chloride) is present at a concentration of over 250 mg/L, the water can have an “off” taste. At 400+ mg/L chloride, the water will taste definitely salty. (Source- Dr. Brian Redmond, Professional Geologist).  After treatment, the level was 6.04 mg/L. (OK)

Sulfate –5.73 mg/L (OK) – drinking water standard is <  250 mg/L – this does not suggest any specific impact.

Strontium – < 0.200 mg/L   – no specific drinking water standard drinking water standard is available, but it is on the EPA Candidate List.  The EPA recommends that drinking water levels of nonradioactive strontium should not be more than 4 mg/L.  The report limit is consistent with background levels in Northeastern Pennsylvania.  If the background level was above 4 mg/L, it would be advisable to test for radiological parameters, especially alpha/beta.  (OK)  After treatment, the level is < 0.200 mg/L.

Total Dissolved Solids  – 48 mg/L  (Value appears low) – Total Dissolved Solids is regulated as a secondary drinking water standard by the PADEP in Pennsylvania and the action limit is 500 mg/L.  After treatment, the level was 109 mg/L (OK- Retesting Recommended).

Total Suspended Solids - < 10 mg/L – no standard, but would recommend retesting to obtain a lower detection limit.

Uranium –< 0.001 mg/L (Total) – Uranium is regulated as a primary drinking water standard by the EPA and PADEP in Pennsylvania and the action limit is 0.030 mg/L.  (OK)

Zinc  –0.0127 mg/L – Zinc is regulated as a secondary drinking water standard by the PADEP in Pennsylvania and the action limit is 5.0 mg/L. After treatment, the level of zinc was 0.0158 mg/L. (OK)

Nitrate+Nitrite- N – 0.42 mg/L, this is well below the EPA / PADEP drinking water limit of 10mg N/L for nitrate-N and would also be below the limit of 1.0 mg N/L for nitrite-N. (OK)

Acetone - the reported value was < 0.002 mg/L.  PADEP has a Medium Specific Concentration (MSC) for aquifers with a TDS of < 2500 mg/L of 33.0 mg/L and Massachusetts appears to have a drinking water standard of 6.3 mg/L. (OK)

http://www.mass.gov/dep/water/drinking/standards/acetone.htm

Bromoform – < 0.0005 mg/L – the Total Trihalomethane Group has a limit of 0.08 mg/L, but bromoform should be less than 0.004 mg/L.  (OK)

http://www.water-research.net/trihalomethanes.htm

Methyl ethyl ketone – < 0.002 mg/L in the treated water and untreated water. (OK)

Methyl ethyl ketone is a colorless volatile liquid that is soluble in water. The odor threshold for methyl ethyl ketone is 5.4 parts per million (ppm), with an acetone-like odor reported. Methyl ethyl ketone is also referred to as 2-butanone.   The EPA and PADEP has not set a drinking water standard, but it appears that Massachusetts has set a level of 4 mg/L.

http://www.epa.gov/ttn/atw/hlthef/methylet.html

http://www.npi.gov.au/substances/methyl-ethyl-ketone/health.html

http://www.mass.gov/dep/water/drinking/standards/meketone.htm

Ethylene glycol –  the reported value is < 10 mg/L – there is not standard, but the EPA has a guidance limit of < 7 mg/L.  Other states have lower and higher standards:

New Jersey 0.300 mg/L (300 ppb)

Arizona 5.5 mg/L (5500 ppb)

New Hampshire 7.0 mg/L (7000 ppb)

Florida, Massachusetts, and Minnesota14.0 mg/L (14,000 ppb)

Minnesota

At a minimum, I would recommend retesting for ethylene glycol other and glycol-type compounds using a method that is more sensitive or conducting some type of standard additions analysis.  In addition, it would be advisable to retest the level of total dissolved solids and conduct a first flush test for copper, lead, and zinc.

This document can not be copied in whole or part without the expressed written permission of Mr. Brian Oram, B.F. Environmental Consultants Inc. http://www.bfenvironmental.com

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