Marcellus Shale Coalition Pre-Drilling Water Sampling

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.

Baseline Testing Results Wayne County Pennsylvania

 Memo

August 18, 2012

To: Wayne County, Manchester Township, PA 18436

From: Brian Oram, PG

B.F. Environmental Consultants Inc.

15 Hillcrest Drive

Dallas, PA 18612

Sample Information- Sample # 1 (Well)
Wayne County, Manchester Township

Site: 

Drilled Well- no data

Purge Time –12/16/2010 at 12:15 am

Estimated – 

Lab Number – XX-XXXX-20101216-PST - Test America / Tetra Tech

Parameter	Result	Standard	Comment
Ethylene Glycol	0.76 mg/L	< 0.3 to 14 mg/L R	Detection Limit Issue
Ethane	< 0.00049 mg/L	no standard	OK
Ethene	< 0.00052 mg/L	no standard	OK
Methane	< 0.00022 mg/L	< 7 mg/L	OK
Propane	< 0.010 mg/L	no standard	OK
Surfactants (MBAS)	< 0.013 mg/L	< 0.5 mg/L	OK
T. Kjeldahl Nitrogen	< 0.15 mg/L	no standard	OK
Radium 226	0.15 pCi/L	< 5 pCi/L	OK
Radium 228	0.06 pCi/L	< 5 pCi/L	OK
Gross Alpha	1.46 pCi/L	< 15 pCi/L	OK
Gross Beta	0.72 pCi/L	< 4 pCi/L	OK

Parameter	Result	Standard	Comment
Thorium	< 0.002 mg/L	see gross alpha	OK
Uranium	0.0011mg/L	< 0.030 mg/L	OK
Thallium	< 0.010 mg/L	< 0.002 mg/L	Detection Limit Issue
Silver	< 0.005 mg/L	< 0.05 to 0.10 mg/L	OK
Aluminum	< 0.200 mg/L	< 0.05 to < 0.2 mg/L	OK
Arsenic	< 0.010 mg/L	< 0.010 mg/L	OK
Barium	< 0.200 mg/L	< 2 mg/L	OK
Beryllium	< 0.004 mg/L	< 0.004 mg/L	OK
Boron	< 0.200 mg/L	< 0.6 mg/L R	OK
Calcium	28.4 mg/L	no standard	OK
Cadmium	< 0.005 mg/L	< 0.005 mg/L	OK
Cobalt	< 0.050 mg/L	< 0.011 mg/L R	OK
Chromium	< 0.005 mg/L	< 0.1 mg/L	OK
Copper	0.0713 mg/L	< 1 mg/L	OK
Potassium	0.660 mg/L	no standard	OK
Lithium	< 0.050 mg/L	< 0.7 mg/L R	OK
Magnesium	3.99 mg/L	no standard	OK
Manganese	0.0012 mg/L	< 0.05 mg/L	OK
Mercury	< 0.0002 mg/L	< 0.002 mg/L	OK
Molybdenum	< 0.040 mg/L	< 0.040 mg/L R	OK
Sodium	4.56 mg/L	no standard	OK
Nickel	< 0.040 mg/L	< 0.1 mg/L	OK
Lead	< 0.003 mg/L	< 0.005 mg/L	OK
Selenium	< 0.005 mg/L	< 0.05 mg/L	OK
Strontium	0.319 mg/L	< 4 mg/L R	OK
Zinc	0.0047 mg/L	< 5 mg/L	OK
Iron, T	< 0.100 mg/L	< 0.3 mg/L	OK
Iron, D	< 0.100 mg/L	< 0.3 mg/L	OK

Parameter	Result	Standard	Comment
pH	7.4	6.5 - 8.5	OK
Acidity	< 5 mg/L	no standard	OK
Ammonia Nitrogen	0.17 mg/L	no standard	OK
Bromide	< 0.20 mg/L	no standard	OK
Chloride	6 mg/L	< 250 mg/L	OK
Hardness, T	84 mg CaCO3/L	no standard	OK
Nitrate-Nitrite	0.17 mg/L	< 10 mg/L	OK
Oil and Grease	< 4.8 mg/L	no standard	OK
Conductance	230 uS/cm	no standard	OK
Sulfate	6.7 mg/L	< 250 mg/L	OK
T. Alkalinity	80.3 mg/L	no standard	OK
T. Dissolved Solids	111	< 500 mg/L	OK
Ratio TDS/ Conductivity	0.48	*****	OK
Total Rec. Phenolics	< 0.010 mg/L	no standard	OK
T. Suspended Solids	< 4 mg/L	no standard	OK

Parameter	Result	Standard	Comment
Benzene	< 0.005 mg/L	< 0.005 mg/L	OK
Ethylbenzene	< 0.005 mg/L	< 0.700 mg/L	OK
Toluene	< 0.005 mg/L	< 1.0 mg/L	OK
T. Xylenes	< 0.015 mg/L	< 10 mg/L	OK
alpha-BHC	< 0.000048 mg/L	no standard	OK
beta-BHC	< 0.000048 mg/L	no standard	OK
delta-BHC	< 0.000048 mg/L	no standard	OK
Lindane	< 0.000048 mg/L	< 0.0002 mg/L	OK
Heptachlor	< 0.000048 mg/L	< 0.0004 mg/L	OK
Aldrin	< 0.000048 mg/L	no standard	OK
Heptachlor epoxide	< 0.000048 mg/L	< 0.0002 mg/L	OK
Endosulfan I	< 0.000048 mg/L	no standard	OK
Dieldrin	< 0.000048 mg/L	no standard	OK
4, 4' DDE	< 0.000048 mg/L	no standard	OK
Endrin	< 0.000048 mg/L	< 0.002 mg/L	OK
Endrin Ketone	< 0.000048 mg/L	no standard	OK
Endrin Aldephyde	< 0.000048 mg/L	no standard	OK
Endosulfan II	< 0.000048 mg/L	no standard	OK
4,4'-DDD	< 0.000048 mg/L	no standard	OK
Endosulfan sulfate	< 0.000048 mg/L	no standard	OK
4,4'-DDT	< 0.000048 mg/L	no standard	OK
Methoxychlor	< 0.000048 mg/L	< 0.040 mg/L	OK
alpha Chlordane	< 0.000095 mg/L	no standard	OK
gamma Chlordane	< 0.000048 mg/L	no standard	OK
Toxaphene	< 0.0038 mg/L	< 0.003 mg/L	OK
2,4-D	< 0.0038 mg/L	< 0.070 mg/L	OK
Dalapon	< 0.0048mg/L	< 0.2 mg/L	OK
2,4-DB	< 0.0038 mg/L	no standard	OK
Dicamba	< 0.0019 mg/L	no standard	OK
Dichlorprop	< 0.0038 mg/L	no standard	OK
Dinoseb	< 0.00086 mg/L	< 0.007 mg/L	OK
MCPA	< 0.380 mg/L	no standard	OK
MCPP	< 0.380 mg/L	no standard	OK
Pentachlorophenol	< 0.00048 mg/L	< 0.001 mg/L	OK
Silvex	< 0.00095 mg/L	< 0.050 mg/L	OK
2,4,5-T	< 0.00095 mg/L	no standard	OK

The following are my general comments:

1. Based on the available data, I do not see any specific problems or concerns.

2. It would have been advisable to test for more of the regulated and unregulated volatile organics and MTBE.  They only tested for BTEX (Bold).

3. It would have been good if the arsenic was tested to a lower detection limit.

4. The letter R- means it was a recommended standard – not regulated.

5. Ethylene glycol – the method did not have a detection limit that is below the lowest standard for a state in the United States.  There is no Federal Drinking Water Standard. The same comment applies to Cobalt.

6. Thallium – the detection limit was not below the limit for the Safe Drinking Water Act.

Recommend retesting.

Thanks for supporting the Citizens Groundwater Database - Submit your data today - get a free evaluation and help your community.

I would like to personally thank Sylcosan Inc. Manchester Wayne County PA and a proud member of the NWPOA for releasing data to the Citizens Database.

Thanks for Helping to Track Change in Pennsylvania

Mr. Brian Oram, PG
Water-Research Center – Free Information on Water Quality

http://www.water-research.net

Questions – 570-335-1947

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