EPA Dimock Well Water Data HW 6 January 2012

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-06

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

Total Coliform – < 1 colony forming units (Ok)

Ethylene glycol –  the reported value is < 10 mg/L – there is no 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 and related glycol compounds using a method that is more sensitive or conducting some type of standard additions analysis.

Chloride – 3.42 mg/L (OK) – drinking water standard is <  250 mg/L – this does not suggest any specific impact.

Fluoride – 0.63 mg/L (OK) – drinking water standard is < 2 mg/L- PADEP drinking water standard is 2 mg/L.

Sulfate –9.24 mg/L (OK) – drinking water standard is <  250 mg/L – this does not suggest any specific impact.

Aluminum – 2.02 mg/L (Total) and < 0.030 mg/L (D)- 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.   Because the total content is high and so is the Total Suspended Solids Results (see below), this would suggest two possible causes:

a. Sample contains particles or colloids in the water that when acid was applied the aluminum leached from the colloids (See Total Suspended Solids Results).

b. Aluminum is high because of corrosion.  Since the methane level is also elevated, it could be possible there is come chemical corrosion of leaching.

c. Since the iron is also high this could suggest an elevated level of aluminum may be related to MIC – microbiologically induced corrosion.

The issues

a. the well could have been over pumped,

b. the well produces water that is highly turbid and may suggest a poor well casing,

c. if drilling, earth moving, or blasting was occurring, this well could be highly vulnerable to these activities, and/or

d.if it was raining, this would suggest a connection between surfacewater and groundwater.

Arsenic – 0.0076 mg/L (Total) and 0.0063 mg/L (D) – 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.  It would be advisable to monitor the arsenic level of the well on an annual basis. (OK)

Barium - 0.164mg/L (Total) and 0.0924 mg/L (D) – drinking water standard is <  2 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. (OK)

Boron – 0.325 mg/L (Total) and 0.321 mg/L (D) – 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.   Therefore, this does not appear to suggest any form of impact.  (OK)

Source:

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

http://www.greenfacts.org/en/boron/boron-greenfacts-level2.pdf

http://water.epa.gov/scitech/swguidance/standards/criteria/aqlife/upload/2009_01_13_criteria_goldbook.pdf

Note: In the US, the concentration is less than 0.1 mg/L, but 10% may be above 0.4 mg/L.

Calcium- 2.570 mg/L (Total) and 2.370 mg/L (D) – no specific drinking water standard drinking water standard is available.  (OK)  - to be honest this value seems low for the region.

Chromium- 0.0108 mg/L (Total) and 0.002 mg/L (D) and the EPA/ PADEP primary drinking water standard is < 0.100 mg/L (OK).

Cobalt - 0.0013 mg/L (Total) and < 0.001 mg/L (D) – there is no drinking water standard, but the PADEP has a medium-specific standard for low TDS water (< 2500 mg/L) of 0.011 mg/L and the EPA documents indicate a trigger level of 0.0047 mg/L.  Since the concentration is below the guidance limits, the level would appear OK.

Copper – 0.0072 mg/L (Total) and < 0.002 mg/L (D)- Copper is regulated as a primary standard (EPA and PA) and secondary drinking water standard in Pennsylvania.  Primary standard 1.3 mg/L and secondary standard 1.0 mg/L.   (OK)

Iron – 2.97mg/L (Total) and < 0.1mg/L (D) – 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 exceeds the secondary drinking water standard.  Since the total value exceeds the limit and not the dissolved, this suggests that the primary recommendation would be to install a water treatment system to filter the iron colloids or particles from the water. Before installing treatment, the standard plate count and the presence/concentration of iron-related bacteria may be necessary.

Action is Recommended, because of an aesthetic issue.

Lead – 0.0018 mg/L (Total) and < 0.001 mg/L (D)- 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. Because of the hits for copper, iron,  and lead, it is possible that the nuisance bacteria may be causing some corrosion related problems – Call MIC – Microbiologically Induced Corrosion – Problem recommend inspection of the well, camera survey, shock disinfection, and retesting.  This is a common problem in NEPA.  (Action Needed may be a warning sign of corrosion)

Lithium – 0.236 mg/L (Total) and 0.228 mg/L (D) – no specific drinking water standard drinking water standard is available, but EPA has recommend a level be below 0.7 mg/L    (OK)

Magnesium- 0.799 mg/L (Total) and < 0.50  mg/L (D) – no specific drinking water standard drinking water standard is available.  (OK)  Again this level appears low.

Manganese– 0.0653 mg/L (Total) and 0.089 mg/L (D) – 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 exceeds the secondary drinking water standard.  Since the manganese is in a dissolved form, the water could become browner in color over time.  Because the water coming out of the well has dissolved manganese, the water treatment system would require either chemical oxidation or some type of ion exchange system. Elevated level of manganese is a common water quality problem in Northeastern Pennsylvania.  Action is Recommended, because of an aesthetic issue and it could be related to Iron-Related Bacteria and MIC. 

Nickel - 0.0068 mg/L (Total) and < 0.001 mg/L (D) –  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 – 2.1 mg/L (Total) and < 2 mg/L (D) –  no specific drinking water standard drinking water standard is available (Ok)

Sodium – 83.7 mg/L (Total) and 83.3 mg/L (D) –  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). (OK)

Strontium – 0.229 mg/L (Total) and 0.212 mg/L (D)  – 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)

Thallium- < 0.001 mg/L (Total) and < 0.001 mg/L (D)  – Thallium is regulated as a primary drinking water standard by the EPA and PADEP in Pennsylvania and the action limit is 0.002 mg/L.  (OK)

Uranium – 0.0021 mg/L (Total) and 0.0019 mg/L (D)  – 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  –0.0337  mg/L (Total) and 0.0150 mg/L (D)  – Zinc is regulated as a secondary drinking water standard by the PADEP in Pennsylvania and the action limit is 5.0 mg/L.  (OK)

Ethane – 0.820  mg/L  – No specific drinking water standard (OK)

Methane – 23  mg/L  – No specific drinking water standard, but the level indicates supersaturated conditions.  This means the well pump is pulling in water that is not in equilibrium with the atmosphere.  The well is above the new action limit of 7 mg/L and methane gas mitigation measures should be employed.  These measures not only include venting the well, but also potentially modifying the well, installing treatment, or taking other action.  For more details, go to http://www.water-research.net/methanegas.htm

There are places in PA were baseline levels of methane gas are at or above 7 mg/L. In general, I would estimate that 1 to 3 % of private wells may have elevated levels of methane.  In addition to modifying the well, it would be advisable to conduct isotopic analysis.  Based on the ratio of methane to ethane, the ratio is 28.  Since a ratio of methane to ethane of over 1000 typically suggests a biogenic source and a value of under 100 suggests a thermogenic source, the available information would suggest a thermogenic source for the gas.  As a guide, it may be possible to use a ratio to suggest the source of the gas- “ if the ratio of methane to ethane is 25, the source is thermogenic, but if the ratio is over 2500, then it is biogenic" (Mr. Bob Pirkle, President of Microseeps, Inc.), but between 25 and 2500 this is where isotopic analysis is critical.  

No specific health concern, but a health risk associated with the potential for a flammable environment.  


Action needed to properly vent gas from the well, perhaps modifying the well, water treatment to reduce methane level in the water to < 7 mg/L or more,  and isotopic analysis recommended.

May be advisable to check the level of other gases, such as propane.

Total Dissolved Solids  –112  mg/L   – Total Dissolved Solids is regulated as a secondary drinking water standard by the PADEP in Pennsylvania and the action limit is 500 mg/L.  (OK)

Total Suspended Solids- 44 mg/L (high) – may be associated with the presence of corrosion by-product, soil separates, or oxided forms of iron, manganese, etc.  Treatment needed – possibly wholehouse particle filter. (Action required).

Butyl benzyl phthalate – the reported level was 0.00009 mg/L – “Benzylbutylphthalate, also called n-butyl benzyl phthalate (BBP) or benzyl butyl phthalate, is a phthalate, an ester of phthalic acid, benzyl alcohol and n-butanol.”   The health based screening level appears to be 0.100 mg/L and the EPA Human Health Equivalent is 1.4 mg/L. Butyl benzylphthalate is an industrial solvent and additive used in adhesives, vinyl flooring, sealants, car-care products and some personal care products.  (OK)

http://www.ewg.org/tap-water/chemical-contaminants

Caprolactam- the reported level was 0.00019 mg/L -Based on a maximum  exposure limit is 35 mg/d/2 liters/d (adult) – this is equivalent to 17 mg/L.  EPA cites a limit of 7.7 mg/L, but NJ cites a limit of 3.5 mg/L for groundwater.  (OK)

U.S. Environmental Protection Agency (EPA). Dallas, TX (2000-05)."Chapter 3: Exposure Scenario Selection". http://www.epa.gov/earth1r6/6pd/rcra_c/pd-o/chap3.pdf. Retrieved 2007-02-19.  RCRA Delisting Technical Support Document. p. 8.

http://www.state.nj.us/dep/standards/pdf/105-60-2.pdf

Fluoranthene (Benzo(j, k)fluorene) was reported at a level of 0.03 ug/L or 0.00003 mg/L and there is a trigger level reported at 0.63 mg/L.  It has been suggested that the EPA has set for total PAHs of 0.2 ug/L or 0.0002 mg/L and I can not find an EPA reference that confirms this statement, but Florida has a health advisory level  of 0.5 ug/L or 0.0005 mg/L for benzo(k)fluorene.  (OK)

Note: “Polycyclic aromatic hydrocarbons are a group of chemicals that occur naturally in coal, crude oil, and gasoline. PAHs are also present in products made from fossil fuels, such as coal-tar pitch, creosote, and asphalt.  Fluoranthene adsorbs strongly to soil and would be expected to remain in the upper layers of soil. However, it has been detected in groundwater samples which demonstrates that it can be transported there by some process(es). It slowly degrades in soil (half-life ca 5 mo to 2 yr).”  Based on the reported trigger level and the standard used for Florida, this value does not appear to violate a trigger level, but monitoring is advisable. http://www.doh.state.fl.us/environment/community/health-advisory/HAL_list.pdf

Fluorene was reported at 0.010 ug/L or 0.00001 mg/L and the reported EPA trigger level is 0.220 mg/L, but has a DWEL of 1.00 mg/L.  Florida  has a health advisory at 0.500 mg/L. (OK)

Still researching- “Fluorene is a polycyclic aromatic hydrocarbon (PAH) released from the incomplete combustion of fuels including oil, gasoline, coal and wood, as well as waste materials; it is an intermediate in production of dyes and other chemicals”- The reported health based standard was 0.3 mg/L or 300 ug/L.

http://www.ewg.org/tap-water/chemical-contaminants?file=contaminant&contamcode=2264

http://water.epa.gov/action/advisories/drinking/upload/dwstandards2011.pdf

n-Nitrosodimethylamine  (NDMA) - the reported value was < 0.005 mg/L and the EPA indicates that there is  “Trigger Level” at 0.00004 mg/L.     It appears this could be a by-product of chlorination.  NDMA can be produced and released from industrial sources through chemical reactions, such as those that involve alkylamines with nitrogen oxides, nitrous acid, or nitrite salts. Potential industrial sources include byproducts from tanneries, pesticide and rocket fuel manufacturing plants, rubber and tire manufacturers, alkylamine manufacture and use sites, fish processing facilities, foundries, and  dye manufacturers (ATSDR 1989).  In 2011, Health Canada established a drinking water guideline at a maximum acceptable concentration (MAC) of 0.00004 mg/L, based on an assessment by the Federal-Provincial-Territorial Committee on Drinking Water (CDW). EPA has a 10^-4 Cancer Risk of 0.00007 mg/L.

Therefore, the primary recommendation would be to resample and use a method with a lower detection limit.  

http://www.rpc.ca/english/info/NDMAAnalysis.pdf

http://www.epa.gov/fedfac/documents/emerging_contaminant_ndma.pdf

Note: 10-4 Cancer Risk: The concentration of a chemical in drinking water corresponding to an excess estimated lifetime cancer risk of 1 in 10,000.

Pryene - the reported value was 0.00004 mg/L and the reported trigger limit is 0.087 mg/L. Florida has a health advisory level of 0.210 mg/L for Pryene.  (OK)

T. Phosphorous – 0.10 mg/L – no EPA or PADEP standard.

Summary

1. Total Aluminum and Total Suspended Solids very high – this suggests a problem with turbid water, corrosion, or suggests a vulnerability to contamination.

2. Calcium and Magnesium seem very low for the region – because of the high sodium and potassium with a low chloride this may suggest a well that is partially influence by alkaline water, but no alkalinity or pH was provided.  The primary recommendation would be to document the level of alkalinity and conduct a geochemical analysis and this could suggest the well water is slightly influenced by saline water.   It would be interesting to conduct a conductivity surface for this well

3. Iron and Manganese were high and above the SMCL (Seconday maximum contaminant level) – set for aesthetic reasons, in addition Lead, Copper, Zinc, Nickel,  Cobalt, and Cobalt were measurable, but not above recommended standard levels.   It may also be advisable to check for iron related or nuisance related bacteria because of concerns related to corrosion.

4. Methane level is high and at a level were action is recommended.

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

5. n-Nitrosodimethylamine  (NDMA) - the reported value was < 0.005 mg/L and the EPA indicates that there is  “Trigger Level” at 0.00004 mg/L.  Recommend resampling using a lower detection limit.

Reference

EPA Water Quality Criteria 1986 -http://water.epa.gov/scitech/swguidance/standards/criteria/aqlife/upload/2009_01_13_criteria_goldbook.pdf

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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Pennsylvania Court Petitioned to Stop Act 13 Municipalities, Delaware Riverkeeper Network, and a Physician File Lawsuit

My perception - Not MY professional Opinion
Posted for Informational Purposes Only and as a place holder for me to review.  It does look like a case that is based on a conceptual ordinance that was deemed to be inconsistent with the Municipal Planning Code and authority given to municipalities by the PA.  

Counsel for Petitioners: John M. Smith, Esq., 724-745-5121; 

Jonathan M. Kamin, Esq., 412-281-1119;

Jordan B. Yeager, Esq., 267-898-0570;

William A. Johnson, Esq., 724-225-3955

Maya van Rossum, the Delaware Riverkeeper 215-369-1188 x102 (rings cell & office)

Tracy Carluccio, Deputy Director, DRN (o) 215-369-1188x104 (c) 215-692-2329

Pennsylvania Court Petitioned to Stop Act 13

Municipalities, Delaware Riverkeeper Network, and a Physician File Lawsuit

Based on Unconstitutionality of Act 13; Injunction Sought

                Harrisburg, PA – Seven municipalities, Delaware Riverkeeper Network, and Dr. Mehernosh Khan filed a legal pleading in Commonwealth Court today challenging Act 13, also known as HB1950, which was signed into law by Governor Corbett on February 14, 2012.  The municipalities are: Township of Robinson, Washington County; Township of Nockamixon, Bucks County; Township of South Fayette, Allegheny County; Peters Township, Washington County; Township of Cecil, Washington County; Mount Pleasant Township, Washington County; and the Borough of Yardley Bucks County.  Act 13 amends the Pennsylvania Oil and Gas Act, preempting municipal zoning of oil and gas development.  It also establishes an impact fee on natural gas.  The plaintiffs are challenging the new law on the grounds it violates the Pennsylvania and United States Constitutions and endangers public health, natural resources, communities and the environment.  “The Petition for Review in the Nature of a Complaint for Declaratory Judgment and Injunctive Relief” was filed today in Commonwealth Court in Harrisburg; the docket number is 284-MD-2012.  Read and download the Petition at (it is in two parts, due to large size file): 

http://www.delawareriverkeeper.org/resources/Comments/FINAL%20PETITION%20PART%201.pdf

http://www.delawareriverkeeper.org/resources/Comments/FINAL%20PETITION%20PART%202.pdf

The lawsuit details how the constitutional rights of all citizens of the Commonwealth are egregiously infringed upon by Act 13. The legal filing explains how the law strips away constitutional rights and violates equal protection principles; illegally benefits the oil and gas industry who are basically put in charge of future land use in the state; extinguishes all existing zoning and planning by permitting oil and gas operations anywhere in a municipality (including residential neighborhoods, by schools, hospitals, and day care centers, and sensitive natural and public resources); deprives municipal officials of carrying out their legally-binding duty to protect air, water, and natural environmental values as agents and trustees of the Commonwealth; prevents municipal officials from serving and protecting their jurisdictions through encouraging beneficial and compatible uses and planning through the Municipalities Planning Code, making predictable and comprehensive planning an exception rather than the rule; perverts the Commonwealth’s Police Powers by forcing oil and gas activities into municipalities through a state-mandated ordinance that does not serve the public health, safety, morality and general welfare interests of the community; economically devastates municipalities through sanctions and unreasonable unfunded demands; among other violations. 

As stated in the Petition: “By attempting to preempt and supersede local regulation of oil and gas operations, the Pennsylvania General Assembly, through Act 13, has assumed the power to zone for oil and gas operations, which is manifested through the promulgation of a uniform set of land-use regulations governing oil and gas operations throughout the Commonwealth. By crafting a single set of statewide zoning rules applicable to oil and gas drilling throughout the Commonwealth, the Pennsylvania General Assembly provided much sought-after predictability for the oil and gas development industry. However, it did so at the expense of the predictability afforded to Petitioners and the citizens of Pennsylvania whose health, safety and welfare, community development objectives, zoning districts and concerns regarding property values were pushed aside to elevate the interests of out-of-state oil and gas companies and the owners of hydrocarbons underlying each property, who are frequently not the surface owners.” (Petition, page 4) 

Jordan Yeager, Esq., representing Nockamixon Township and Delaware Riverkeeper Network, said, “Harrisburg sold out the citizens of the Commonwealth.  Harrisburg sold out our locally elected municipal governments.  Harrisburg sold out our state’s precious water resources, our agricultural soils, the clean air we need to survive.  We’re asking the court to say what we all know to be true:  Harrisburg went too far.”

"Act 13 must be challenged since it is unconstitutional and unfair, which is why Delaware Riverkeeper Network is joining forces with municipalities to overturn it. Among the many wrongs we're fighting is the violation of Article 1, Section 27 of the Pennsylvania Constitution -- municipalities are being stripped of their ability to protect public natural resources like water and air. By depriving municipal elected officials of their ability to use zoning and community decisionmaking to protect precious natural resources, schools, hospitals and homes from damaging industrial practices, and to ensure the rights of everyone are honored and protected, this law has undermined the very fabric of municipal and constitutional law in the Commonwealth. As a result, our water, air, kids and communities will be subjected to more pollution and degradation from gas development," said Maya van Rossum, the Delaware Riverkeeper and co-plaintiff in the case.

The filing today is expected to be filed by a request for a preliminary injunction, aimed at keeping Act 13’s zoning provision from going into effect on April 14, 2012.

###

Note = I know there are webinars planned on this HB1950

Attend the Webinar and Get the Facts (PADEP Webinar Act 13)