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

Do you want to make a positive change in PA - that will cost you NO Money?
Help Support the Citizens Groundwater and Surfacewater Database and Submit Your Baseline Data !

Democratic Policy Committee Hearing August 2011 Testimony by Brian Oram geologist and citizen of Pennsylvania

My name is Brian Oram and I wanted to thank you for this opportunity. I am a licensed professional geologist, owner of B.F. Environmental Consultants Inc. and a lifelong resident of Northeastern Pennsylvania. I am here today as a citizen of Pennsylvania.


I would like to start of with two statements.

1. Methane Gas Migration- The recent updates to Chapter 78- Pennsylvania Oil and Gas Law will go a long way to aid in preventing future cases of methane gas migration and the well reporting requirements includes language that requires listing of the quantity and type of chemicals used as part of the Well Reporting Process. This requirement appears to meet the informational goal of the proposed legislation HR 1084. In addition, the industry has responded to the need to disclose this information through the creation of “FracFocus”- http://fracfocus.org/.  FracFocus, the hydraulic fracturing chemical registry website. This website is a joint project of the Ground Water Protection Council and the Interstate Oil and Gas Compact Commission- I have attached a copy of a report that was available for a well in Bradford County PA..
Changes - Well Control, Well Construction (casing and cementing operations), Mechanical Integrity of Existing Wells, Gas Migration Response, and Well Reporting

2. Hydrofracturing is regulated by the EPA via the Underground Injection Control Program when diesel fluids are used as part of the frac mixture or in Alabama when coal-bed methane is being developed.

Talking Points and Points of Concern

1. I do not believe that the hydrofracturing process as being employed by the natural gas companies that have released information on the chemicals used for unconventional natural gas development needs to be regulated under the UIC program, but there should be a Memorandum of Understanding between PADEP and EPA. The EPA needs to be notified and informed of natural gas drilling permits to ensure that these permits will not conflict with EPA mandates and existing programs. In addition, it would be advisable that the unconventional natural gas wells be constructed to meet the requirements of Class II injection wells, since we may need to utilizes these secure boreholes in the future.

I do believe that hydrofracturing of formations for gas development above the Marcellus Shale and hydrofracturing for coal-bed methane development should be regulated and permitted by the UIC program in PA.

2. The current PADEP regulations, i.e., Chapter 78, may not be consistent with the requirements to protect Drinking Water as provided by the Safe Drinking Water Act and UIC Program. Pennsylvania protects freshwater < 3000 mg/L, but EPA protects freshwater and “useable Quality Water” or potential freshwater, i.e., water with a TDS of 3,000 to 10,000 mg/L ( water that is 99 % pure). The current PADEP regulations may not adequately protect this potentially usable water, but more importantly, the formations that contain this water may be the pathways that helps facilitate methane gas migration, the PADEP standards need to be updated to be consistent with the EPA Program.

3. The regulations, i.e., Chapter 78, need to be more proactive and not only require baseline testing, but real-time monitoring of “freshwater wells”, natural saline seeps, and other features during the drilling and development process. This monitoring would likely include general water quality, water level, radon flux, and methane flux. This would provide an early warning system before a major release occurs and/or confirmation that the process is safe.

4. Since private well owners do not have the ability to develop sourcewater or wellhead protection plans, the permitting process should put in place contingency plans to properly and quickly respond to incidents of methane gas migration or other releases. When contamination or releases do occur, the site, groundwater, and/or soils need to be evaluated, clean-up, and monitored.

For community water supplies – these systems should develop sourcewater protection plans and wellhead protection plans that apply to all industries and not just natural gas development. In general, the local sourcewater protection plans for the reservoirs that service major cities in Northeastern Pennsylvania are inadequate and out-of-date.

5. Citizens need to be informed of this process and this process should be relatively easy to follow. Since citizens are not accustom to requesting file reviews or travelling to a regional PADEP office to review permit applications, a copy the PADEP permits for natural gas wells should be maintained at a local office, such as the local municipality or county office.

6. No waiver should be granted if the natural gas well is within 100 feet of a stream, wetland, or body of water. There should be no waiver for drilling a natural gas well within 200 feet of a private well. The private well may be owned by a citizen, but the well is connected to the Waters of the Commonwealth.

7. It is sad to say, but 30 to 50 % of private wells currently do not meet drinking water standards, we should take advantage of this opportunity to fix private wells using funding from consumptive water permits, permit fees, and fines. Fixing private wells is a benefit to the wellowner, the residents of PA, and the Natural Gas Industry. Poorly sited and poorly constructed private wells may act as a conduit to facilitate the migration of gas and other fluids. We have to remember – we all live downstream.

8.Regarding well cutting disposal, if encapsulation or on-site disposal is proposed, this activity and other natural gas activity should be outlined in the deed for the property along with the coordinates of the buried infrastructure.

9. Regulations are only as good as the enforcement. To encourage companies to adhere to regulations, the fines should be significant. We need to start adding zeros. Please remember – one well can generate over 30,000 per day in profit to the company. They can afford to do this work the right way.

10. Since the mission of PADEP is not to compile and interpret water quality data and information, it is critical that some organization or network of organizations work together to compile the environmental monitoring data that is generated by this activity. This information needs to be compiled and presented in a manner that is readily available to the public and in a language that will educate and inform.
With this goal in mind, I have been working with Wilkes University/ Dr. Brian Redmond/ Dr. Sid Halsor to compile the Citizen Groundwater and Surfacewater Database and we have utilized this database to conduct an initial groundwater vulnerability analysis for a portion of Luzerne County. With additional work, this type of analysis may help to identify regions or zones more susceptible to contamination from any surface, near surface, or subsurface activity.

Outside of the Marcellus Shale Issues -
We need to make sure that Pennsylvania develops a set of private well construction standards and encourages municipalities to develop land-use and zoning ordinances.
Again thank you for this opportunity and I will do my best to answer any questions.

Prepared by:
Mr. Brian Oram, PG
B.F. Environmental Consultants Inc.
15 Hillcrest Drive
Dallas, PA 18612
http://www.bfenvironmental.com/
bfenviro@ptd.net

EPA's Draft Hydraulic Fracturing Study Plan Marcellus Shale Study

"EPA's Draft Hydraulic Fracturing Study Plan


In its Fiscal Year 2010 budget report, the U.S. House of Representatives Appropriation Conference Committee identified the need for a focused study of this topic. EPA scientists, under this administration and at the direction of Congress, are undertaking a study of this practice to better understand any potential impacts of hydraulic fracturing on drinking water and groundwater. EPA consulted with experts in the field through peer review, and technical workshops and engaged stakeholders in a dialogue about the study through facilitated public meetings.

EPA has submitted its draft study plan on hydraulic fracturing for review to the agency's Science Advisory Board (SAB).
The overall purpose of the study is to understand the relationship between hydraulic fracturing and drinking water resources. The scope of the proposed research includes the full lifespan of water in hydraulic fracturing, from acquisition of the water, through the mixing of chemicals and actual fracturing, to the post-fracturing stage, including the management of flowback and produced water and its ultimate treatment and disposal.
The SAB plans to review the draft plan March 7-8, 2011. Consistent with the operating procedures of the SAB, an opportunity will be provided for stakeholders and the public to provide comments to the SAB during their review. The Agency will revise the study plan in response to the SAB's comments and promptly begin the study. Initial research results are expected by the end of 2012 with a goal for a report in 2014."


For additional information:

•Science Advisory Board Review Request PDF
•Hydraulic Fracturing Draft Study Plan PDF
•Press release on Draft Hydraulic Fracturing Study Plan



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Hydraulic Fracturing is Regulated by EPA via UIC if diesel fuel is used or proposed

The following is text from EPA Site.

"Water is an integral component of the hydraulic fracturing process. EPA Office of Water regulates waste disposal of flowback and sometimes the injection of fracturing fluids as authorized by the Safe Drinking Water Act and Clean Water Act.


Safe Drinking Water Act

Several statutes may be leveraged to protect water quality, but EPA’s central authority to protect drinking water is drawn from the Safe Drinking Water Act (SDWA). The protection of USDWs is focused in the Underground Injection Control (UIC) program, which regulates the subsurface emplacement of fluid. Congress provided for exclusions to UIC authority (SDWA § 1421(d)), however, with the most recent language added via the Energy Policy Act of 2005:

“The term ‘underground injection’ –
(A) means the subsurface emplacement of fluids by well injection; and
(B) excludes –
(i) the underground injection of natural gas for purposes of storage; and
(ii) the underground injection of fluids or propping agents (other than diesel fuels) pursuant to hydraulic fracturing operations related to oil, gas, or geothermal production activities.”

While the SDWA specifically excludes hydraulic fracturing from UIC regulation under SDWA § 1421 (d)(1), the use of diesel fuel during hydraulic fracturing is still regulated by the UIC program. Any service company that performs hydraulic fracturing using diesel fuel must receive prior authorization from the UIC program. Injection wells receiving diesel fuel as a hydraulic fracturing additive will be considered Class II wells by the UIC program. The UIC regulations can be found in Title 40 of the Code of Federal Regulations Parts 144-148. State oil and gas agencies may have additional regulations for hydraulic fracturing. In addition, states or EPA have authority under the Clean Water Act to regulate discharge of produced waters from hydraulic fracturing operations.
Clean Water Act

Disposal of flowback into surface waters of the United States is regulated by the National Pollutant Discharge Elimination System (NPDES) permit program. The Clean Water Act authorizes the NPDES program.
State regulations

In addition to federal authority to regulate the hydraulic fracturing process, states may have additional regulations on hydraulic fracturing and the production of fossil fuels."

*********
1. Good
2. They are regulated as Class 2 UIC Wells

What is a Class II well?


Class II wells inject fluids associated with oil and natural gas production. Most of the injected fluid is salt water (brine), which is brought to the surface in the process of producing (extracting) oil and gas. In addition, brine and other fluids are injected to enhance (improve) oil and gas production. The approximately 144,000 Class II wells in operation in the United States inject over 2 billion gallons of brine every day.

Sources
http://water.epa.gov/type/groundwater/uic/class2/hydraulicfracturing/wells_hydroreg.cfm
http://water.epa.gov/type/groundwater/uic/class2/index.cfm

Hydraulic Fracturing Comments Sent to EPA

To Whom It May Concern:

My primary concerns and comments on this matter are as follows:
1. It is my professional opinion that is it not necessary to regulate the fracturing process under the UIC program, but I believe it would be advisable to track the location and development of these oil and natural gas wells as a sister program or a component of the UIC program. This is especially true for states like New York and Pennsylvania that did adopt primacy for the UIC program and it is EPA obligation to implement the UIC program.
2. The development and operation of oil and gas production needs to be done in a manner that does not conflict with the UIC program. If not properly tracked, monitored, and governed- deep oil and gas wells with horizontal drilling has the potential to adversely influence or affect the operation of existing or future injection wells or cause movement of contaminated water, i.e., water with a TDS greater than 10,000 mg/L, into the USDW waters.
Therefore – without the involvement of EPA – Oil and Gas Development in NY and PA may be done in a manner that is not consistent with the UIC program. This involvement does not need to be a new regulatory process, but mostly like a cooperative agreement or interagency agreement or memorandum of understanding.
Even though chemicals are added to the “frac” water – the state program should be encouraged to require the use of “green” frac chemicals and practices that have a lower impact on the environment. With respect to fracturing, it is my professional opinion the primary concern would be the induced movement of deep biogenic or thermogenic gas or connate water from the deeper portions of the geological structure into the USDW water. Therefore, we need to have protection in place so the development process does not facilitate the movement of water that has been trapped in the formation for 400 million years into the USDW water.
From my perspective and assuming the use of diesel, BTEX compounds, aromatic hydrocarbons, and other toxic chemicals are prohibited in the fracing process - the primary concern is not the relatively low levels of organics in frac water, but the elevated levels of sodium, chloride, barium, strontium, gross alpha, lithium, iron, manganese, and sulfur compounds or gases that may come from the Marcellus Shale or other formations between the shale and USDW. This includes the migration of flammable gases and other noxious gases because of fracking pressure or poorly constructed/cemented wells.
3. The industry is creating a boring and stabilized hole that has the potential of becoming, after the gas is withdrawn, a regulated injection well – even if the goal of the injection is to enhance oil and gas recovery or to carbon sequester. From the start – the wells cement and casing requirements should be constructed to meet or exceed the standards required for Class I injection wells.
4 Without tracking the installation, pressurization, use and redevelopment of each well, tracking the movement and quality of the fluids, and tracking the abandonment of these wells – these wells have the potential for having both short-term and long-term consequences.
In the short-term, these well could cause or induce a push of contaminated water, i.e., water with a purity of less the 99%, or biogenic gas or interfere with UIC wells permitted by EPA.
In the long-term, these gas and oil wells have the potential for adversely affecting existing injecting wells, siting new injection wells, adversely affecting the utilization and siting of carbon sequestration systems, and the drilling and development process has the potential to adversely affect the Underground Sources of Drinking Water (USDW). The definition of USDW is defined as an "aquifer or its portion which supplies any public water system, or contains less that 10,000 milligrams per liter total dissolved solids and is not an exempt aquifer."
5.Because the deep oil and gas wells have the potential for interfering with existing or future UIC program wells, the drilling, construction, and development process for these oil and gas wells needs to be consistent with the goals of the UIC program and should not interfere with the UIC program. Therefore, in states like PA – the EPA should take a more proactive role in at least tracking and being informed about the oil and gas wells to ensure that the PA State Oil and Gas Regulations are consistent with the goals of the EPA Managed UIC program in PA. This involvement does not need to be a new regulatory process, but mostly like a cooperative agreement or interagency agreement or memorandum of understanding.


6. My specific suggestions (Interim Measures – Assuming no moratorium) :

a. EPA and individual states should review state Oil and Gas Regulations to ensure the regulations are consistent with the goals and objectives of the Federal UIC program and the regulations represent the Best Industry Practices to protect the health, safety, and welfare of the community and environment.
b. During the permitting process, the process should document if there are any injection wells or saline seeps within an area being developed or leased for natural gas or oil development, plus a distance of at least 2500 feet from the production zone. The 2500 feet distance was recommended because it has been reported that hydraulic fracturing can initially induce fracturing a distance of at least 1000 - 1500 feet from the pressurization point (therefore a 1000 foot buffer has been added) and the sand is used as a proppant can create a 300 to 500 feet (Producing Zone).
See Attached report- World Watch Institute- July 2010.
http://www.bfenvironmental.com/pdfs/Hydraulic_Fracturing_Paper_-_World_Watch.pdf
Therefore – the available data indicates that hydraulic fracturing should not induced saline water or gas migration, but gas is migrating
I do not believe gas is migrating because of fracing, but because of poor drilling and cementing practices. This conclusion does not mean that we need to ignore the problem – we need to fix the problem so this leakage does not interfere with the UIC program and does not induce contamination of the USDW.
c.Chemicals, Water Tracking, Waste Tracking – The chemical types and volumes injected into the well during the drilling and development need to be disclosed in the well completion report, a cradle to grave tracking system of waste and produced water volumes is required, and chemical analysis of the production water used include a complete listing of regulated chemicals, chemicals used in the development process, and chemicals that have established drinking water limits (plus chemicals that have been added to the EPA Candidate List) . This industry should not be exempt from the Toxic Release Reporting Process. This needs to be completed because sometime in the future, it may be necessary to identify the source of a contamination event or situation. In order to evaluate and identify the source of contamination – we need the data. If you do not collect the data – it will not be possible to scientifically or legally prove a cause-effect relationship.
d. Monitoring- For each production well site – a monitoring program is needed. This program is needed because it is not known what the true depth and thickness of the Underground Sources of Drinking Water (USDW) and there are basically no private well construction standards within Pennsylvania.
The predrilling monitoring should include the following components:
1. Monitoring a radial distance of at least 2500 feet from a production well, plus up to 1000 feet from a horizontal leg for the well. This monitoring needs to include existing private wells, springs, and streams, plus the monitoring should include the installation of multiple deep monitoring wells that isolate the deepest portion of the USDW in the region. Baseline monitoring needs to include a comprehensive listing of cations/anions, VOCs, SOCs, radiological, and other unregulated chemicals.
2. Monitoring should be conducted prior to drilling and then conducted 6 months and 1 year after completion and then immediately prior to and after any subsequent re-pressurization/ re-fracturing of the wellbore.
e. Public Outreach – the public should be informed and it should be encouraged that a copy of the permit be maintained at a local state office or office for a local township or municipality.

f. The EPA, other federal agencies, states, and the industry should fund a detailed investigation of the production and development process. The goal of this investigation should include baseline environmental testing prior to drilling, monitoring during the drilling and development process, and post production monitoring at representative terrestrial sites in the Unites States. This study should not result in the implementation of a drilling and gas development moratorium.

e. Memorandum of understanding with Teeth – Recommend Building from this original MOU and putting together a document with a downside.

http://energycommerce.house.gov/Press_111/20100218/hydraulic_fracturing_memo.pdf

The EPA, PA and other states, and Natural Gas Companies and Development Companies should not be voluntary and should prohibit the use of toxic chemicals and require the use of Best Industry Practices and at a Minimum Recommended Industry Standards fro Natural Gas and oil development. If a company is found not to follow these practices – they should be prohibited from conducting business in a given state or commonwealth.
7. Specific Recommendations on EPA Study

a.EPA whould work in partnership with State Agency, Industry, and local Universities to select sites throughout the US and NEPA to complete a detailed investigation of natural gas development. The study should be a cradle to grave investigation that evaluates the various types of drilling, development techniques, and fracturing processes.
Sites selection should be based on a combination of geological site conditions and location to urban corridors and high profile/ environmental areas. The investigation should not just be a comparison of vertical and horizontal drilling – but vertical, horizontal drilling using individual vertical wells with one horizontal leg, and a single vertical well with multiple horizontal leg (“tree design”).
b.The study should include the comprehensive evaluation of a site prior to gas development- air soil and water and a general biological diversity study. This would include the detailed mapping and understanding the quality and movement of shallow and deep USDW waters and the water quality and hydraulic pressures of the formation water to a depth that extends beyond the Marcellus Shale, habitat studies, and air monitoring. The habitat studies should use control areas that include areas that have been cleared for other activities.
c. The study should include the comprehensive evaluation of the site during the construction and development process. The baseline monitoring will need to extent at least 2500 feet from the vertical boring and than up to 1000 feet from a horizontal leg. The monitoring should be adequate enough to actually document the extent of fracture development during pressurization and the actual width of the production zone.
Personal Note- I do not conduct any consulting for gas companies. I do assist in conducting baseline testing for citizens.
Respectfully submitted

Mr. Brian Oram, PG
B.F. Environmental Consultants Inc
15 Hillcrest Drive
Dallas, PA 18612
http://www.bfenvironmental.com/
570-335-1947 – cell phone

Hydraulic Fracturing - Induced Fractures and the Freshwater Aquifer

I came across these Industry Articles and a resource guide from the League of Women Voters- they do not appear to be peer reviewed, but I think it is good starting point in the discussion. 

http://www.pinntech.com/pubs/NL/Frac_Attack_Eprint.pdf
or
http://www.bfenvironmental.com/pdfs/inducedfracturingoilreporter.pdf

http://www.bfenvironmental.com/pdfs/Hydraulic_Fracturing_Paper_-_World_Watch.pdf

http://www.bfenvironmental.com/pdfs/HydraulicFracturingReport1.2008.pdf
http://www.bfenvironmental.com/pdfs/Sample20Fluid20Composition-BJ20Services.pdf

http://www.bfenvironmental.com/pdfs/Sample20Fluid20Composition-Halliburton.pdf


http://www.bfenvironmental.com/pdfs/Marcellus_Shale_Study_Guide_Parts_1-5.pdf

It is my understanding from a different report that fracing process may initially create fractures that radiate about 1000 to 1500 feet from a well, but the production zone is limited to a distance of about 300 to 500 feet because the fractures beyond this distance do not stay open. (Source World Watch Report)

Instructions for the tipline can be found at: http://www.epa.gov/region03/marcellus_shale/tipline.html

EPA Hydraulic Fracturing Public Informational Meeting in Binghamton, NY Register NOW EPA Time Line

Registration: EPA Hydraulic Fracturing Public Informational Meeting

September 13 & 15

Broome County Forum Theater, Binghamton, NY

The U.S. Environmental Protection Agency has selected a new venue and dates for the public meeting on EPA's upcoming hydraulic fracturing study originally scheduled for August 12, 2010. The meeting will now be held at the Broome County Forum Theater in Binghamton, New York, on September 13th and 15th, 2010.
EPA will hold four identical sessions:
Dates: Monday, September 13, 2010 and Wednesday, September 15, 2010
Location: Broome County Forum Theater, 236 Washington St., Binghamton

Time:
•12:00pm - 4:00pm (pre-registration begins at 10:30am)
•6:00pm - 10:00pm (pre-registration begins at 4:30pm)

All individuals who pre-registered for the August 12 meetings will retain their registration for the September 13 and 15 meetings. Because the timing of the sessions has changed from a one-day event to a two-day event and EPA has added another meeting session, EPA needs pre-registered individuals to specify the session they would like to attend.
If you registered as an attendee for the August 12 session, please enter your information in the space provided below, and select the session you would like to attend. If you are registering for the first time, please follow the same procedure. Please note that a limited number of speaking slots are available on a first-come, first-served basis. You may only speak at ONE session. If you would like attend multiple sessions, please register for one session at a time.

EPA is expecting room-capacity crowds. Pre-registering helps EPA plan the meeting logistics and increases the likelihood that individuals will be able to attend their preferred sessions. Online and telephone registration (1-866-477-3635) will remain open through 5:00 pm, September 10, 2010. Those who are not pre-registered may still register to attend or provide verbal comment on the day of the meeting, time permitting.
Written comments can be sent to hydraulic.fracturing@epa.gov, or to Jill Dean, 1200 Pennsylvania Ave. NW, Mail Code 4606M, Washington, DC 20460.
For additional questions or comments, please email hydraulic.fracturing@epa.gov or call 1-866-477-3635. Meeting information may be found on the EPA Hydraulic Fracturing Study website at http://water.epa.gov/type/groundwater/uic/class2/hydraulicfracturing/wells_hydroout.cfm

Credentialed members of the media are encouraged to RSVP to senn.john@epa.gov by 5;00 pm, September 10, 2010. There will be a separate media registration table at the venue.

Remember
The U.S. Environmental Protection Agency today announced the creation of the “Eyes on Drilling” tipline for citizens to report non-emergency suspicious activity related to oil and natural gas development.


The agency is asking citizens to call 1-877-919-4EPA (toll free) if they observe what appears to be illegal disposal of wastes or other suspicious activity. Anyone may also send reports by email to eyesondrilling@epa.gov. Citizens may provide tips anonymously if they don’t want to identify themselves.

In the event of an emergency, such as a spill or release of hazardous material, including oil, to the environment, citizens are advised to call the National Response Center at 1-800-424-8802.

Instructions for the tipline can be found at:
http://www.epa.gov/region03/marcellus_shale/tipline.html