MSC Issues Guidance on Responding to Stray Gas Incidents

MSC Issues Guidance on Responding to Stray Gas Incidents
Fourth in a series on recommended practices for responsible natural gas development

Pittsburgh, PA – Today, the Marcellus Shale Coalition (MSC) published its Recommended Practices for Responding to Stray Gas Incidents, the fourth in a series of such guidance documents. Stray gas -- which can originate from various sources, including coal beds, oil and natural gas wells, landfills, pipelines, naturally occurring methane and microbial gas -- is the migration of gas from one of these sources into groundwater, a structure, surface water and soil. There is a long, well-document history of stray gas incidents occurring in rural communities across the country, including many areas throughout Appalachia.
 

“Over the past several years, our industry has frequently identified the presence of stray gas during pre-drill baseline water surveys,” said MSC president Kathryn Klaber. “This document provides detailed steps that operators can take when stray gas is encountered – from developing proper plans of action, to notification of regulators as well as initial response actions and performing site reconnaissance surveys. Each of these key steps helps ensure that public safety and environmental concerns are mitigated and resolved in a responsible and timely manner.”

Stray gas can be influenced by a number of factors, including changes in barometric pressure, soil and bedrock permeability, temperature contrasts and other weather related conditions, such as rain or snow among others.

When responding to a stray gas incident, maintaining lines of communication with state regulators, local officials, first responders and homeowners is crucial. Depending on the identified levels and location of the methane, oil and natural gas producers can take a number of steps based upon initial response and assessment. Should stray gas be detected in a structure, ventilation and methane-specific alarms may be installed as a precautionary measure.

Similarly, vents may also be installed if methane is detected in water wells at heightened levels. When dissolved methane is detected in a water source servicing a structure, operators should consider providing an alternate water source until additional testing is completed to determine the source of the stray gas.
 

“Our organization, as laid out in our Guiding Principles, is committed to operational transparency and environmental protection,” continued Klaber. “This product will further assist operators in addressing cases of stray gas when encountered. Core to this document is the importance of safety of our employees, contractors and the general public.”

To review this full document online, click HERE. 

Our Website On Methane Gas Migration and some pdf files on the subject

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

Our New Booklet for Private Well Owners

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

HW-19 EPA Water Test Dimock PA Pennsylvania Natural Gas Migration

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-19

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

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

Heterotrophic Bacteria – 24 colonies per ml – the general guidance for “standard plate count” or total bacterial count is < 500 colonies per ml (OK)

http://health.mo.gov/lab/heterotropicbacteria.php

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

Methane – < 0.002 mg/L  – No specific drinking water standard. (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 other other glycol compounds using a method that is more sensitive or conducting some type of standard additions analysis.

Chloride – 19.10 mg/L (OK) – drinking water standard is <  250 mg/L – this does not suggest any specific impact.

Sulfate – 18.20 mg/L (OK) – drinking water standard is <  250 mg/L – this does not suggest any specific impact.

Arsenic – < 0.001mg/L (Total) and 0.002 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.  

Barium - 0.229 mg/L (Total) and 0.234 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)

Calcium- 37.6 mg/L (Total) and 41.6 mg/L (D) – no specific drinking water standard drinking water standard is available.  (OK- but there is either a contaminant added during filtration or this represents lab error – Higher Filtered Sample Higher than Total)

Chromium- 0.002 mg/L (Total) and 0.0032 mg/L (D) and the EPA/ PADEP primary drinking water standard is < 0.100 mg/L (OK).

Copper – 0.0074 mg/L (Total) and < 0.069 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)

Magnesium- 7.12 mg/L (Total) and 7.72 mg/L (D) – no specific drinking water standard drinking water standard is available.  (OK)

Manganese– 0.0082 mg/L (Total) and < 0.001 mg/L (D) – Manganese is regulated as a secondary drinking water standard in Pennsylvania and the action limit is 0.05 mg/L.  (OK)

Nickel - 0.0016 mg/L (Total) and 0.0017 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

Sodium –9.03 mg/L (Total) and 10. 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)

Zinc  – 0.0069  mg/L (Total) and 0.0053 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)

Total Dissolved Solids  – 148 to 173  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)  This is a significant range in TDS – it may be worth checking to see if the “P” sample was field contaminated or if there was an increase in the conductivity during the purging process. (OK)

Nitrate+Nitrite – 2.38 mg N/L, the EPA drinking water for nitrate-N/L is 10, but the primary drinking water standard for nitrate is 1 nitrite-N/L.  It is probably be ok, but it may be advisable to test for nitrite-N.  (OK)

No major problems

1. Heterotrophic bacteria present- but that is common in NEPA. 

2. Nitrate-Nitrite at 2.38 mg/L – it may be advisable to check the level of nitrite in the water.

3. Retesting for glycols using a more sensitive technique is recommended.

4. Water did not contain methane gas, it was not detected.

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 !

 Free Information on Drinking Water Quality - http://www.water-research.net

EPA Dimock Well Water Pennsylvania Water Quality Dimock HW-4 Janurary 2012 EPA Data Private Well Review by Oram

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-04

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

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 using a method that is more sensitive or conducting some type of standard additions analysis.

Chloride – 12.5 mg/L (OK) – drinking water standard is <  250 mg/L – this does not suggest any specific impact.

Sulfate – 17.1 mg/L (OK) – drinking water standard is <  250 mg/L – this does not suggest any specific impact.

Barium - 0.231mg/L (Total) and 0.215 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)

Calcium- 32.3 mg/L (Total) and 31.7 mg/L (D) – no specific drinking water standard drinking water standard is available.  (OK)

Copper – 0.0052 mg/L (Total) and 0.0022 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 – 0.106mg/L (Total) and 0.100 mg/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 does not exceed the secondary drinking water standard.   (OK)

Lead – 0.0014 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 and lead, it is possible that there is some corrosion within the system.   (OK)

Magnesium- 6.65 mg/L (Total) and 6.475 mg/L (D) – no specific drinking water standard drinking water standard is available.  (OK)

Manganese– 0.0169 mg/L (Total) and 0.0.0149 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 does not exceed the secondary drinking water standard.  (OK)

Sodium – 17.3 mg/L (Total) and 17.1 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 – 0.273 mg/L (Total) and 0.271 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 – 0.0012 mg/L (Total) and 0.0011 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  – 0.099  mg/L (Total) and 0.0945 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 – 0.025  mg/L  – No specific drinking water standard (OK)

Methane – 1.7  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 well below the new action limit of 7 mg/L and methane gas mitigation measures that could be employed is the use of a standard vented well cap. For more details, go to http://www.water-research.net/methanegas.htm

If the gas concentration was higher -  isotopic could be used to suggest that source of the gas.  At this time, it is not clearly biogenic or thermogenic.

Total Dissolved Solids  – 158  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)

Benzo(a)pyrene – the reported level was 0.00005 mg/L.   The EPA and PADEP have a primary drinking water standard of 0.0002 mg/L.  The value is below the maximum contaminant level for a regulated water source. (OK)

4-Bromopheyl-Phenyl Ether – the reported level was < 0.005 mg/L – there does not appear to be a federal drinking water standard but Florida does appear to have an upper limit of 0.0010 mg/L.  It might be advisable to retest using a method with a lower detection limit. (OK)

http://www.epa.gov/iris/subst/0490.htm

http://www.atsdr.cdc.gov/toxprofiles/tp68-c10.pdf

Fluoranthene (Benzo(j, k)fluorene) was reported at a level of < 5 ug/L or 0.005 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, but Florida has a health advisory level of 0.5 ug/L or 0.0005 mg/L for benzo(k)fluorene.  Might be advisable to retest using a lower detection limit.

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

Nitrate+Nitrite- N – 0.64 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)

In general,

1. the available data does not indentify a parameter that would result in the classification of the water as not potable.

2. it was suggested that at least one parameter be retested using a method with a lower detection limit.

3. Methane/ethane ratio - 68

Again – this is not about cause and effect- it is an honest review of the data.  (Period)

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 !

Methane Gas Migration and Your Water Well- A Pennsylvania Perspective and Action Plan

Final Draft - Post for final review and comment

This is a free resource that is being provided by Mr. Brian Oram, Professional Geologist and owner of B.F. Environmental Consultants Inc. and the Water-Research Center.  This fact sheet is part of our on-going education program for private well homeowners, i.e.,  as The Homeowner Outreach Program.  B.F. Environmental Consultants, Inc. and Mr. Brian Oram support the Citizens Groundwater/Surfacewater Database, which is a grassroots effort to compile the water quality data for Northeastern Pennsylvania.  To learn more, please contact the Water-Research Center- http://www.water-research.net.

Introduction

Methane gas has been a “hidden” problem in Northeastern Pennsylvania.  The gas is typically associated with wetlands, bogs, landfills, coal-producing formations, natural saline seeps, some glacial deposits, and gas storage areas.  Because of the development of the Marcellus Shale, the presence of methane gas and the potential for methane gas migration is a growing concern.   Methane is a colorless, odorless gas that is lighter than air.   Natural gas is mostly methane (70 – 90 % CH₄), carbon dioxide (0 to 8 % CO₂), plus other gases.  The other gases may include ethane (C₂H₆), propane (C₃H₈), butane (C₄H₁₀), and hydrogen sulfide (H₂S) as well as small amounts of helium.

Methane gas is highly flammable between a lower explosion limit (LEL) of 5.53 percent by volume in air and an upper explosion limit (UEL) of 15 percent.  The minimum concentration level at which the gas has the potential to explode is called the lower explosive limit (LEL); below the LEL level there is not enough gas to cause an explosion.  Above the UEL, there is inadequate oxygen to fuel combustion, but if the space is vented and the gas concentration drops below the UEL, the gas can explode.  Methane is not considered toxic, but it is an asphyxiant at a concentration of over 50 percent in air (it displaces oxygen).  Therefore, the primary risks for methane would be asphyxiation in a confined or poorly vented area or a potential explosion hazard.   As a safety measure, the natural gas industry adds mercaptans to the produced methane gas that enters the pipeline and your home. The mercaptans produce a very pungent odor so that gas leaks will be noticed, but unprocessed methane gas tends to have NO ODOR.  It is critical to note that some unprocessed methane gas may contain long chain hydrocarbon molecules that can create an odor.

From the available data in the Citizen Groundwater/Surfacewater Database, it would appear that the natural background level of methane in private wells in Northeastern Pennsylvania ranges from not detectable or trace levels to over 28 mg/L.  You may suspect the presence of methane gas in your water if you hear a “gurgling noise”, sputtering at the tap, the water has a lot of gas bubbles, is effervescent or fizzy.  

Note: If the pumping level of water in your well starts to fall below your pump intake, ordinary air may mix with the water and produce similar symptoms. When in doubt, contact a professional to determine the nature of the observed gas.

Water hammer or pressure surge is another potential sign of a methane or entrapped gas-related problem. These conditions do not necessarily mean you have a methane problem but it does suggest that additional water testing and possibly more aggressive venting would be needed.  Methane gas typically out-gases very quickly from water.  Therefore, if it takes over 2 minutes for the gas and water to separate, it is most likely carbon dioxide.   If you have a lot of gas and the methane content of the water is low, it may be a mixture of carbon dioxide or air entrapment within the system.   If there is a strong odor and the level of methane is low, you may want to test for sulfur (hydrogen sulfide; odor of rotten eggs) or propane.  Testing for propane would be advisable if you or your neighbors use propane gas.

Note:  Some articles suggest that you should try to collect the water and allow the gas to outgas in a sealed container and then attempt to light the accumulated gas – we do not recommend this practice. This practice is not safe, especially if you do not know the level of methane gas in the water, your home, or under the wellhead.  This may make a great “YouTube” video or “Facebook” post, but it is safer to purchase a small methane gas or flammable gas detector.

There are two main types of methane found in rock formations and groundwater.  The types are based on a difference in origin, not composition:

1. Thermogenic methane, which is formed from buried organic matter at considerable depths where the rocks are compressed and heated; this includes the methane found in coal, gas from some Devonian sandstones/shales, and gas from the Marcellus and Utica Formations.  Methane is produced by the inorganic breakdown of organic matter (heat and pressure). 

2. Biogenic or bacterial methane which formed closer to the surface by the action of bacteria (methanogens- “bacteria that produce methane and cannot live in an environment with oxygen).  This would include methane generated in landfills, lake sediments, wetlands/swamps, organic-rich glacial deposits, other recently buried organic deposits, and other carbon rich environments that are without oxygen.

Natural gas formed by thermogenic processes contains small amounts of ethane and propane and may contain very small amounts of butane and pentane as well as methane. Some coals, like from the anthracite region, contain thermogenic gas, but some coal bed methane could be either biogenic or thermogenic gas. When bacteria generate “biogenic” gas, they create mainly methane.

The source of the natural gas can to some extent be determined by the relative proportion of methane, ethane and propane within the gas, i.e., gas fingerprinting.  Even very small amounts of ethane and propane may be important in helping to identify the source of the gas, i.e., gas composition analysis. Unfortunately, gas composition analysis is expensive, requires an expert, may require large volumes of sample, and a reference sample.   The primary difficulty with the analysis and interpretation of methane by either composition or isotope ratios is that after the gas is created it can be altered during the migration process.  This alteration affects the relative proportions and isotopic composition of the gases, thus making it more difficult to distinguish and identify a specific source.  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.

Methane Gas Concerns and Concentrations

Just like radon gas, methane gas migrates naturally up through the soil, geological materials, and through the groundwater and into your home or well.  Some gas naturally enters houses through the foundation, which is why some homes can have a radon problem if the gas entering the home happens to have a relatively high concentration of radon.  When your water well is pumped, the drop in the level of the water in the wellbore reduces the pressure within the formation and permits more gas to migrate toward the wellbore.  If the well is not properly vented and there happens to be substantial amounts of methane, the gas could accumulate under the well cap near the electrical connections for your well or the methane could enter with the well water and outgas in your home.   The US Department of the Interior, Office of Surface Mining, suggests that when the level of methane gas in the water is less than 10 mg/L it is safe, but monitoring is required at 10 to 28 mg/L, and immediate action is needed above 28 mg/L.  At a level of 28 mg/L, the water is fully saturated with methane and it is likely that any air space in the well is at or approaching the LEL.  The air and out-gassing methane, not the water, is now flammable.

Based on a review of regulations and guidance from other states, the following are our professional recommendations related to suggested actions for your well depending on the level of methane gas detected in the water:

u < 2 mg/L – Make sure your well is fitted with a passive venting system using a vented sanitary well cap.

u > 2 to 7 mg/L – Monitor quarterly for one year and install a passive venting system using a vented pipe and vented sanitary well cap.

u > 7 mg/L to < 10 mg/L – Corrective Action is Needed! – Seek help from a professional.
Install active venting and monitor quarterly for one year. Consider Isotopic Analysis – “Like fingerprinting the source of the gas.” Remove ignition sources - if the well is in a well pit or basement, corrective action is needed and you should seek guidance from a licensed professional.

u > 10 mg/L to < 20 mg/L –  Corrective Action and Additional Testing are Needed! – Seek help from a professional.

Install active venting system, an in-home methane detection system, and a gas shroud on the pump.  If the well is very deep or deeper than the surrounding wells, it may be advisable to consider cementing the lower portions of the well (which could be another problem if most of the water in the well is entering the well from its lower section).  Monitoring and Testing - isotopic analysis with monitoring is recommended and the gases and gas concentrations should be tested multiple times during a year with at least one test under conditions when the greatest out-gassing is anticipated.  If there is natural gas development in your area, contact the PADEP and the local Natural Gas Company.  Seek help from a licensed professional !

u  > 20 mg/L – Immediate Corrective Action is Needed! – Seek help from a professional.

Install active venting and active point-of-entry treatment system, remove ignition sources, install a gas shroud on the pump, consider raising the pump,        and consider cementing the lower portions of the well.   Monitoring and Testing – there should be real-time monitoring in the home and a treatment system, regular monitoring of the untreated water and treated water from the system, and isotopic analysis.

It would be advisable to test for methane, ethane, and propane by a certified testing laboratory.  With respect to baseline testing, it would be wise to test for all three gases but if you’re on a budget at least test for methane and ethane and seek guidance from a professional. 

Note: Corrective action is recommended if the well is in a well pit or in the basement and the initial methane in water concentration is above 2 mg/L. 

When to Test for Methane?

This is a common question and to be honest all we can say is that the level of methane in well water is controlled by many factors and conditions and it can be highly variable. If you want to test under the conditions most favorable to methane gas migration or leakage, it would be advisable to conduct testing when one or more of the following conditions exist:

a. barometric pressure is low and soils are saturated;

b. when snow cover is just beginning to melt;

c. the ground is frozen or ice covered; or

d. under long-term pumping conditions for the well when the well is experiencing the lowest dynamic water level and greatest drawdown.

The variability in methane gas concentrations may require you to sample the well three to four times per year to establish a realistic baseline and provide some insight into background levels of methane gas.  You can visually monitor the quality of the water, if the amount of dissolved gases increase, i.e., if there are more bubbles and fizz, maybe it is time to check the water.   If you see a foam, you would probably want to test the water for surfactants.

Taking Action – Based on Your Level of Methane

Level 1- Passive Venting: Methane Levels < 2 mg/L
Passive venting could simply include checking the electrical connections at the top of the well and installing a vented sanitary well cap.  Wells should not be vented to a well pit, inside the home, or within any structure, but vented to the outside atmosphere. The well casing should extend at least 3 feet above the local flood stage for your area.  

Level 2 – Monitoring, Source Identification, and Passive Venting: Methane Levels 2 to

< 7 mg/L

At this stage, a passive venting system should be installed.  At this level, the venting system would consist of a vented well cap using a vented piping approach.  The vent piping should have an inside diameter of 0.5 inches , extend 6 to 12 inches below the sanitary well cap, at least 12 inches above the well cap, and the end of the pipe that extends above grade should be turned down and fitted with a corrosion resistant fine screen.  The screen should have a mesh size of  25 mesh or less. The vent piping should use watertight connections that extend above flood level and local ignition sources. A screen is added so insects cannot enter or clog the pipe and the pipe is turned down to prevent precipitation from directly entering the well.   The well casing should extend at least 3 feet above the local flood stage for your area.  

Level 3 – Active Venting, Removing Ignition Sources, and Seasonal Monitoring: Methane Level 7 to < 10 mg/L

Because the level of methane gas in the well water will fluctuate as the water level in the well changes, it would be advisable to conduct seasonal monitoring to better understand the variation in the gas concentration.  In addition, this level of action would also include installing additional monitoring devices, an active venting system on the well, and an evaluation of the well to determine if a modification to the well would reduce the level of methane gas.  The main goals are to attempt to understand the natural variation in methane levels, provide a venting system that will ensure your family and home is safe, and to proactively manage the potential risk. At this concentration, the venting system should vent the gas above local ignition sources, above flood level, and above a human exposure level, i.e., at least 6 feet or more.

At this time, it may be advisable to conduct an isotopic analysis to determine the likely source of the methane gas.  Isotopic analysis can determine if the source of the methane gas is from a landfill gas, sewer gas, biogenic gas, or thermogenic gas.  Isotopic analysis is a specialty test and costs approximately $ 450.00 to $ 500.00 per sample.  The primary reason for testing the gas at this point is not just to document the concentration, but also to obtain some information related to the source of the methane gas. 

Note:  Any time the level of methane is at or greater than 7 mg/L - Contact- PADEP and the Local Natural Gas Company in Your Area – Under Oil and Gas Law- Section 78.89 – “When an operator or owner is notified of or otherwise made aware of a POTENTIAL natural gas migration incident, the operator shall immediately conduct an investigation of the incident”.

Level 4 – Aggressive, Potentially Long-Term Treatment: Methane Levels > 10 mg/L to

< 20 mg/L.

At this level, it is most likely that a treatment system will be needed and it would be necessary to install intrinsically safe equipment, i.e., switches, pumps, fixtures, etc.  Intrinsic safety is a requirement that applies to devices that are being operated in areas with flammable gases or fuels. It means that the device is incapable of igniting those gases. In short, an intrinsically safe piece of equipment won't ignite flammable gases even if the unit is in a flammable environment.   Additional real-time monitoring equipment and a gas shroud should be installed around the pump. 

Before installing the treatment system, it would be advisable to complete a baseline analysis of the source, plus conduct additional water quality and wellbore analysis to evaluate the potential for modifying the well and aid in the design of the water treatment system.  Aeration or degasification is the primary way to eliminate the problem of methane gas in water.  There are a number of methods for venting the methane, which includes a vented tank, an air release valve, and an air separator.  Because elevated levels of methane gas may be associated with other water quality problems and atmospheric venting may introduce or facilitate bacterial growth it may be necessary to first vent the gas and then install secondary treatment systems.  In some cases, this may mean the treatment system may need to include some form of disinfection.  To maintain the removal efficiency of the methane reduction system and because of our cold climate, it may be necessary to put the treatment system in a climate-controlled space.  

Level 5 – Immediate Action – Aggressive Response, Mitigation and Long-Term Treatment: Methane Levels > 20 mg/L.

An immediate response and action is needed.  At this level, it is likely the water has a number of aesthetic and safety issues and concerns and it may be advisable check if the water is also influenced by elevated levels of pH, ORP (oxidation/reduction potential), barium, strontium, chloride, iron, manganese, bromide, total dissolved solids, and other elements associated with saline water.    Your first response should be to contact the PADEP and the local Natural Gas Company so they can conduct an investigation and seek the advice of a licensed professional.

Because a response at this level of methane gas is very site-specific, the following should only be used as a guide.

1.      Seek advice from a licensed professional.

2.      Conduct an assessment of the methane level in the water, space under the well cap, and methane level in the air in your home or other confined spaces.

3.      Mitigate any immediate hazards that could result in an explosion.

4.      If possible, modify the wellhead to properly vent the gas and upgrade electrical connections to reduce the level of methane in the water to less than 7 mg/L.

5.      This modification may include raising the well pump, installing a pump shroud, installing an active venting system, cement sealing a portion of the well, and any other modifications to make sure the well is properly and safely vented.

6.      Conduct biological and chemical analysis to determine the source of the methane gas and general quality of the water.

7.      If necessary, install a long-term treatment system.  This should include some type of aeration and degasing system.  Special precautions and additional testing will be needed if disinfection will be a component of the system. 

If the water is saturated with methane, i.e., > 28 mg/L, it may be advisable to retest the water/air using the IsoBag sampling method recommended by Isotech Laboratories, Inc. and conducting an isotropic analysis of the gas/water and seek the assistance of a professional.

Well/ System Modifications

The Gas Shroud - In some cases, well contractors have reduced or eliminated methane or other gas problems in the well by installing a gas “shroud” on a submersible pump. This involves placing a pipe or tube, often a thin-walled plastic pipe, from the top of the submersible pump motor, a distance of 10 or more feet above the pump. This method only works with 6-inch or larger diameter wells with standard well pumps, and wells that pump relatively small quantities of water at one time.  Because the gas shroud may interfere with cooling the motor, this modification to your system should be done under the supervision of a licensed professional.

Cementing – If the source of the methane gas is from a formation near the base of the well, it may be advisable to consider abandoning a portion of the well.  To make this decision, it would be advisable to have a copy of the well drillers log, so you have some idea of the type of rock units and location of water bearing zones; you don’t want to seal off the source of most of your well water.  For this option, it may be necessary to camera survey the well and use other tools to evaluate the change in water quality with depth in the well.

Raise the Pump – If the well is deep and the pump is set near the base of the well, it may be advisable to raise the level of the pump.  Do not raise the pump intake above its pumping level because you will then start to pump air along with the water (air bubbles in the water). 

Install a Dole Flow Control Valve- This modification has been successful in preventing gas locking in submersible pumps.  This modification would include the installation of a number of dole flow control valves to divert 1/3 of the pumped water back to the well. The bypass should be located at a point where the water will cascade back to the well.

Maintenance and Monitoring

After you have taken the necessary corrective action, it will be necessary to maintain the equipment and monitor your drinking water quality.  If you hire a water treatment specialist, you may want to consider a licensed or approved contractor who is certified by the Water Quality Association (WQA) and someone that is using an NSF Approved Process or components.  For water quality monitoring, there is some self-monitoring equipment for this task.  You should also conduct an annual water analysis and annual assessment of your system.

For more information, please do not hesitate to contact the Water-Research Center at bfenviro@ptd.net, http://www.water-research.net , http://www.bfenvironmental.com or 570-335-1947. 

Related Tags: methane, ethane, propane, aeration, ventilation, disinfection, radon, baseline testing, water treatment, well water, biogenic gas, water treatment,  thermogenic gas, methane gas migration, methane in drinking water private wells

Special Recognition

We want to take this opportunity to thank Dr. Brian Redmond, Professional Geologist at Wilkes University; Mr. Burt Waite, Professional Geologist at Moody and Associates, Inc., Mr. Bob Pirkle, President of Microseeps, Inc.; Mr. Tom Reilly, Jr. , Reilly Associates for providing a technical review of this factsheet.

Our company accepts no liability for the content of this document, or for the consequences of any actions taken on the basis of the information provided.  This document is being provided as an educational and informational tool, but before you take action you should seek advice from a professional.

© 2011 by B.F. Environmental Consultants Inc.
All rights reserved. No part of this document may be reproduced or transmitted in any form or by any means, electronic, mechanical, photocopying, recording, or otherwise, without prior written permission of B.F. Environmental Consultants Inc., but the document may be reproduced in whole, without modification, for an educational purposes.

Gas company whistle-blower details spills, errors - Cabot - Dimock PA

Not my work - I am reviewing this article.

"DIMOCK TWP. - On a bright fall day in 2008, Scott Ely arrived at the natural gas well a few hundred feet from his home to find work strangely stilled.

His fellow employees of Cabot Oil and Gas Corp.'s drilling subsidiary were watching the only thing moving: a huge plume of gas "like Niagara Falls going upwards" buffeting the drilling rig from below, he remembered.

The gas in the air was sickening.
"They told me they hit a methane pocket," he said. "We're waiting for Cabot to tell us what to do, whether we should try to punch through it or plug it."
They punched through it - a pocket of shallow gas about 1,500 feet down that pumped out the equivalent of 900,000 cubic feet of gas per day, according to a report later commissioned by Cabot.

When drilling was finished, muddy puddles on the pad bubbled with the gas seeping through the gravel.
"Right next to the wellhead it looked like 1,000 Alka-Seltzers going off," he said

Mr. Ely, a GasSearch Drilling Services employee from spring 2008 until mid-2010, is one of more than a dozen Dimock residents suing the company because of what happened next: his family, including three small children, began to get cramps, rashes and headaches. Months after Mr. Ely noted something was not right with his water and first warned his employer to test it, a company representative asked his family to evacuate to a Tunkhannock hotel because dangerous levels of methane seeped into the home with every shower or load of laundry.

Now, state officials have found that Cabot met the obligations necessary for the driller to stop delivering replacement bottled and bulk water to 19 homes, including Mr. Ely's, where the methane tainting the water has been linked to Cabot's faulty wells.
Cabot, which says the water is safe to drink and use, plans to stop the deliveries in 10 days.
'We're the sacrifice'

Long silent about reckless practices, unreported spills and buried problems he said he witnessed on Cabot's well sites, Mr. Ely said the prospect of losing fresh water twice to drilling forced him to speak out

"It's terrible that we're the sacrifice," he said. "We're the sludge that comes off and then we're just washed away."

In an interview with The Sunday Times, Mr. Ely outlined allegations he first shared with Cabot officials and state regulators in the month after his attorneys filed a lawsuit against the driller in November 2009.
In the two years since he led the officials on a tour of every failure he witnessed at Cabot's Dimock sites, he said he has received no answers from the company about what they found in the soil and streams.

Cabot officials told the newspaper that a report proving its operations had no negative environmental impact is ready to be released this month, but they would not disclose the findings until the final report is submitted to the Department of Environmental Protection.

According to Mr. Ely:

Cabot tried to hide, minimize or ignore at least five diesel spills or their impacts between 2008 and 2009. After an 800-gallon diesel spill in June 2008, a drilling supervisor instructed him to move a reference point hay bale away from a spot where lab tests showed persistently contaminated soil after treatment.

"I said, 'So you want them to test where there's no hot dirt?' " he recalled. "He said, 'That's the idea.' "

 Company pits leaked or their plastic liners were carelessly torn before their contents were buried on 13 occasions. The earliest, haphazardly constructed pits were used to catch toxic fluids that flowed out of the wells, but the spray frequently missed the pits or blew out of them.

"In the beginning we would dig a hole and then we'd just throw plastic in it," he said. "That was more or less to make the homeowners feel comfortable about us drilling on their property."

 On at least two occasions, Cabot employees scraped contaminated soil, sand or gravel from a drilling pad then pushed it over the pad's bank.

At one site, Mr. Ely watched a bulldozer operator clear a pad covered in a "big, goopy concoction" of sand and spilled gels and acids by pushing the mess over a bank, he said. State files for the second site show that an inspector from the Department of Environmental Protection discovered an unreported pile of diesel-soaked soil dumped at the edge of a farmer's field.

Cabot had well-control or casing problems on three wells other than the Gesford 3 site where Mr. Ely saw the plume of shallow gas. A "wild well" specialist from Texas was called to a site on Mr. Ely's father's property in late 2008 after a failed valve made it impossible to shut off the spewing well, forcing the family to evacuate overnight.

Something loose in the well jammed the flow, and workers resorted to dumping buckets of methanol on dry ice stacked around the wellhead to freeze it.

"That well could have let loose at any moment, at any time," he said. "We didn't know what was stopping it from blowing out of there but we knew the well was full of fluids."

Cabot files report
After Mr. Ely described what he saw to Cabot officials, the company contracted the environmental consulting firm URS Corp. to investigate any environmental impacts from the alleged incidents.
A final report of the investigation, which was initially outlined by URS in March 2010, will be submitted to the Department of Environmental Protection by Nov. 30, Cabot spokesman George Stark said.

"We have worked with the past administration and we're working with this administration to demonstrate soundly that none of the areas laid out in the accusations exceeded the cleanup standards or were outside the norms of protective health and safety," he said.

Mr. Stark said the 20-month investigation involved close consultation with the DEP and required a year of groundwater monitoring at one of the suspect sites, but ultimately revealed that "there really wasn't anything there."

The company will not release any data from the report before it is submitted to the department, he said.

A DEP spokeswoman confirmed that the agency has been in "constant contact" with URS about the investigation and is anticipating "a report to see what steps they have taken as far as all of the violations."

"We expect a report shortly as to how they are complying with the recommendations we gave them," spokeswoman Colleen Connolly said.

Mr. Stark would not address many of Mr. Ely's specific allegations, since they are dealt with in the report, but said Cabot "takes environmental stewardship seriously and thoroughly investigates all environmental claims."

Asked if he disputes that the incidents alleged by Mr. Ely ever happened, Mr. Stark said, "Each of them has been investigated and the resulting analysis shows that either there was something to investigate further or nothing to investigate."

He said he would not dispute that shallow gas escaped from the Gesford 3 site, but he challenged Mr. Ely's "visual opinion" of the event.

"I'm not saying it didn't happen," he said. "But, if it did occur, we're not aware of any problems as a result of it."

Spills documented

Many of the spills described by Mr. Ely were also documented during state inspections of the well sites, often after Cabot reported the incidents to regulators. Some of the incidents described by Mr. Ely have already gone through state-reviewed remediation and been cleared, Mr. Stark said.

According to agency records, the DEP issued violations at Cabot sites for at least 51 separate incidents involving spills, seeps or releases between 2008 and 2010, including after a July 2009 inspection found stained sand on the well site where Mr. Ely said the "goopy" concoction was later pushed off site.

In a document compiled for the federal Environmental Protection Agency, Cabot reported 19 spills and releases of hazardous substances or wastewater at its Susquehanna County well sites and 14 additional spills "where Cabot does not have sufficient information to confirm that a release of a hazardous substance ... occurred" between June 2008 and May 2011.

The company explicitly did not include instances of methane migration into water supplies in its EPA report because "Cabot disputes the validity of these allegations," the company wrote.

Cabot claims elevated levels of methane reach Dimock water supplies through natural pathways. It has produced data showing detectable amounts of methane naturally occur in 80 percent of the water wells it has tested in Susquehanna County in a geological pattern that mirrors the occurrences in Dimock.

Cabot was forced by the DEP to plug three of its gas wells suspected of allowing methane to taint water supplies, including the Gesford 3 and 9, the twin wells where Mr. Ely saw the methane plume and where Cabot lost a drill bit in unconsolidated rock about 800 feet down.

In correspondence with the DEP in September 2010, Cabot called the three wells "safe, properly constructed and valuable" even though the company proposed earlier the same year to drill a relief water well at the Gesford pad "in an attempt to degas the aquifer," according to DEP documents.
"The department has many reservations concerning this course of action," a regional DEP oil and gas manager wrote.
The last three years in Dimock have been remarkably caustic, with the driller at times pitted against state regulators and neighbors who embrace the company at odds with those suing it.
Mr. Ely has stood at the heart of that division.

A Dimock native whose grandparents' name was given to a creek that runs through town, he is building a new house and raising a family on his father's homestead.

With a speciality in spill prevention and response for gas stations and other petroleum services, he joined GasSearch as a heavy equipment operator and later helped set up the subsidiary's drilling rigs.

He found that the companies working on the drilling sites "had no care for what spilled anywhere. It was the most reckless industry I've ever seen in my life," he said. "I stood up because I couldn't see them just wrecking everybody's properties."

The roles he has been given in the last few years have forced him to split his loyalties: a leaseholder with tainted water, an employee of the company blamed for the contamination, a plaintiff in the case against his employer, a neighbor trying to protect his neighbors and, in return, being accused of blowing their best chance at financial comfort.

"I'm not against the oil industry," he said. "I am not against any of my neighbors extracting the gas from the land to achieve wealth, small or large. I am not here to deprive them at all of that."

In fact, he said, "I know they can do this in a safe manner" and in many ways he has seen that Cabot and others have improved: The driller no longer uses pits and now uses liners and other containments on its well pads to protect against spills reaching the ground.

"Things are different because of what happened at the beginning," he said. "Things are different because we spoke out."


He fears that the state will set a low bar for the Marcellus Shale industry if the DEP does not change course and require Cabot to continue water deliveries - something DEP Secretary Michael Krancer says he will not do because Cabot met the legal obligations outlined in an order drafted during the Rendell Administration.

According to the order, Cabot could stop the deliveries after it offered to install methane-removal systems and funded escrow accounts with twice the tax-assessed value of each affected home. The quality of the residents' drinking water was not a factor in that aspect of the agreement.
"How can they retract all that science?" Mr. Ely said of the DEP's record of Cabot's violations. "They can't go through and say that Cabot's findings clear them of all charges."
On a cold morning last week, he pulled the handle on a spout above his water well and let the water run for half an hour.
Clear and effervescent for more than 20 minutes, the spray of water then turned a milky brown. He caught it in a glass.
"All we want is water," he said, standing outside his soaring, half-finished home that is waiting for its brick walls.

"We are pleading for help. We are on our last straw."

Read more: http://thetimes-tribune.com/news/gas-company-whistle-blower-details-spills-errors-1.1234817?fb_ref=.Tsj8zNn589c.like&fb_source=home_oneline#ixzz1eGjyUV00

Dialogue and Working as a Community – The Marcellus Shale Factor

Dialogue and Working as a Community – The Marcellus Shale Factor


In Pennsylvania, Commercial Oil and Natural Gas Development dates back to 1859 and Colonel Edwin Drake work in Northwestern Pennsylvania, but in 1795 settlers in the Montrose area talked about water that would “bubble and catch fire like black powder”. Later it was determined that the salt spring contained methane gas and in late 19th and early 20th century a commercial salt and oil operation was attempted. This site is now known as Salt Spring State Park in Susquehanna County, Pennsylvania and it is a great historic site.

Unlike the attempts at Salt Spring that failed, it appears that the commercial development of the methane gas in the Marcellus Shale will be commercially viable. It is clear that methane gas is not uniformly distributed in the Marcellus Shale, but methane gas if virtually everywhere in our environment. Remember, methane gas has no color and no odor. Methane gas can be found in saturated soils, lake sediments, glacial materials, wetlands, landfills, buried floodplains, Catskill Formation (primary source of drinking water for NEPA), coal deposits, and the unconventional gas reservoirs like the Marcellus Shale. There is no primary or secondary drinking water standard for methane gas, but there are some guidance levels because of concerns related to the potential for accumulation of the gas and the creation of an explosive environment. The new guidance level in Pennsylvania is 7 mg/L methane in water (For the record, the old action level was 10 mg/L) and we have action levels with the airborne concentrations reach 10 percent of the lower explosive limit. This means that if the explosive value was 1, we take corrective action and provide venting, passive or active, when the airborne level is at 0.1. The level of methane in water and the level in a confined headspace do not correlate well. If gas is building up in the headspace of a well or other confined area, the problem is that the space is NOT properly vented and this needs to be corrected.
Regarding the level of methane gas in our region prior to Marcellus Shale Development, it has been my professional experience that the level of methane gas can range from not detectable to greater than 28 mg/L and in fact I lit my first tap in 1989. The concentration of methane gas in water is highly variable from well to well, region to region, and with time at the same well. It has been my experience that methane levels can change from < 10 mg/L to over 15 mg/L in the same well in the matter of a few days and concentrations may vary from < 2 mg/L to over 7 mg/L in just under a 100 feet. This was one reason, in 2009, I had proposed lowering the recommended action level in Pennsylvania to 7 mg/L. The level of methane in water is control by many factors that include barometric pressure, rainfall amounts, ice cover on soil, groundwater levels, water well operation, depth of pump setting, depth of well, and the geological setting. All of these factors can cause the headspace and dissolved methane to fluctuate and if the headspace is not properly vented, methane gas can accumulate. Private Wells need to be vented and vented properly.

Because of the interest in natural gas development, the baseline testing being done by the industry and fellow citizens is demonstrating very clearly the fact that PA Groundwater is not PURE. In fact, the groundwater contains measurable to explosive levels of methane gas, plus other trace elements, but of specific concern is that up to 50% of private wells may not meet a primary drinking water standard because of bacterial contamination, arsenic, barium, or lead. Primary drinking water standards are set because of specific health concerns. When speaking about this issue, I use the phrase the “Marcellus Shale Factor”. The development of this natural resource is just another reason we need to work together as a “Community” to “Get The Waters Tested”. We have problems now and the only way we can solve them in the future is to recognize the weakness and make a change.
Throughout my career, I have conducted extensive groundwater and private well testing in Pennsylvania and the world. We created the Water-Research.net web-portal as a free information resource for the community and we are continuing our work on the Citizens Groundwater and Surfacewater Database for NEPA. In addition to this effort, we are conducting a private well owner watershed survey and planning to offer free radon in water screening. With the help of our fellow citizens, this data warehouse will allow us to better understand our resources, our current issues, and track future change. This database is not a regulatory tool, but an informational tool that could be used to make decisions that ensures the health, safety, and welfare of our community and environment. With respect to the PADEP decision that the methane gas levels meet the requirements of the consent document for Cabot, it is my hope that the continued monitoring, that should be done, will confirm this conclusion and that as a community we could work together to move forward. We are a community of citizens, we may not all agree but we must work together – this is our home. It is critical that local stakeholders come together for form local task forces and create community-based resources to educate, assist, and inform the citizens so fact/ science and not fear rule the day. My hope is that the first order of business would be the development and implementation of private well construction standards and a program to fix and upgrade existing private wells, a program to test alternative practices to mitigate methane gas, and the development of a best-management practice manual for the Marcellus Shale in our region. It is critical we work together to ensure the health, safety, and economic welfare of our citizens and environment.

Original = Full draft of the article submit for consideration to the Scranton Times
The actual article that was approved.

Recent presentations related to Methane Gas Migration
Training Workshop Scheduled for November 4, 2011

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

Scarce Public Infrastructure Dollars To Replace Drilling-Affected Water Supplies In Dimock

"Home › Gas Industry › Scarce Public Infrastructure Dollars To Replace Drilling-Affected Water Supplies In Dimock

By Feed: PA Environment Digest in Gas Industry

Thu, 11/04/2010 - 15:41

The PA Infrastructure Investment Authority will vote on November 9 on whether to fund a $11.7 million drinking water project to replace water supplies affected by Marcellus Shale drilling in Dimock, Susquehanna County.

The proposed financing package would give an $11.5 million grant and a $172,000 loan to Pennsylvania American Water to install 5.4 miles of transmission line and 7 miles of distribution line to provide the option of public water to 18 homes with wells affected by drilling. The grant would be one of the largest ever given by PennVEST for a single project.

In an open letter to residents of Dimock in October, Department of Environmental Protection Secretary John Hanger said, "No one in Dimock or Susquehanna County will pay for it and local taxes will not be increased as the result of it. Residents along Route 29 will have the option to tap into the line if they so choose. No one will be forced to hook up to the new public water supply."

Secretary Hanger also said in a letter to Senators Mary Jo White (R-Venango) and Don White (R-Indiana), "All homeowners who choose to accept the public water system will receive the same monthly water bill as other Pennsylvania American Water Company customers." PennVEST estimates the average annual water bill on the system to be $724.

In that same letter, Secretary Hanger said the Commonwealth will "take all actions necessary and appropriate" seek to recover the cost of the project from Cabot Oil & Gas Corporation which DEP holds responsible for drinking water well contamination in the area.

Residents in Dimock this week protested the construction of the water line in a meeting with Secretary Hanger saying other less expensive options like drilling new wells, well reconstruction or adding filtration systems would solve the problem.

Opponents of the proposed water line are bombarding legislators and members of the Board of PennVEST with emails and petitions asking that funding not be approved. Senators Ray Musto (D-Luzerne), Don White (R-Indiana) and Reps. Bud George (D-Clearfield) and Dick Hess (R-Blair) serve on the Board.

The PennVEST Board meeting will be held in Room 60 East Wing of the Capitol Building starting at 10:30. It had been scheduled for its usual location at the Governor's Residence."
(Not my work - but my comments at the bottom)

NewsClips:

DEP Secretary Meets With Affected Families In Dimock
http://thetimes-tribune.com/news/dep-secretary-meets-with-affected-families-in-dimock-1.1059168

From this article- Items tested for in the water supplies included methane, iron, manganese, barium and aluminum- The problem is what are the levels - all of these parameters can be present and detectable and some are naturally present at elevated levels, i.e, iron/manganese and some times methane.  How about some numbers - what was the before?  what is the after?.
DEP Chief Confronted, Bombarded With Questions In Dimock
http://pahomepage.com/fulltext/?nxd_id=160656
The problem can not be fixed until all are fixed and groundwater remediated.
Link: DEP: Dimock Residents Will Be Provided Permanent Replacement Water Supply
http://www.paenvironmentdigest.com/newsletter/default.asp?NewsletterArticleID=16959
This article suggests the only real problem is methane - if this is the case - a water line probably is not needed, but this could be addressed through individual treatment systems or a small community system.