Related to natural gas development, the most frustrating part of this experience, for me, has been the lack of a fact-based review of the data. That is what you will find here - a fact based review with NO SPIN either way. I try not to make any judgments. The main goal of this evaluation is to understand the nature of the regional water quality and to provide a fact based review of the data. The results are compared to the EPA and Pennsylvania Drinking Water Standards. If no standard was available, we searched for a standard that has been established by another state or the World Health Organization.
First question is why? Because I do not have all the facts for each well for a number of reasons, which include inadequate or no baseline testing and lack of long-term information for each source. I was not on-site or part of the initial baseline testing or investigation, but I was invited on-site to witness the sampling that was conducted by the EPA. Therefore, the following is a review of this single sampling event.
The following is a summary of the water quality data that was generated by the EPA for a private water well identified as HW-2 in Dimock, Pennsylvania. The well was sampled by the EPA, DEP, and the local natural gas development company in January 2012 after the natural gas drilling wells had been drilled, developed, installed, and some under production. The primary objective was to determine the presence of any residual impacts at that specific time.
A fact based review - Well by Well of the Available Well Water Data for the Dimock Area that was generated by the EPA. I was not involved with the sampling, but I was on-site during the sampling and field evaluation of one home. I was invited by the homeowner. We are still in the process of reviewing the data. The main goal of this evaluation is to understand the nature of the regional water quality and to provide a fact based review of the data. The results compared the EPA and Pennsylvania Drinking Water Standards. If no standard was available, we searched for a standard that has been established by another state or the World Health Organization.
1. Without predrilling data, it is not possible to comment on the cause for any water quality problems. This has been a very frustrating issue for this area. In many cases, there was no to very little predrilling baseline testing conducted or the testing was inadequate and had "Zero" follow-up.
2. Where possible, I have noted situations where elevated levels of a water quality parameter exist in Pennsylvania.
3. If duplicate analysis provided, I attempted to use the highest reported value.
4. This evaluation was based on using the 2011 EPA Health Advisory (Source). For a more recent version of the EPA Health Advisory Click Here.
5. This is not about cause and effect; it is about a review of the data.
With the exception of the following parameters, the remaining values were reported as NOT Detected (U).
Total Coliform – Two samples - (82 colonies per 100 ml and 1 colonies per 100 ml) – since the EPA collected this sample at the end of the purging process – this suggests the well is vulnerable to near surface influence and the presence of total coliform would suggest the water is not potable. This is a very common problem in NEPA and about 30 to 50% of private wells have total coliform bacteria. The problem could be private well construction, type of well cap, or improper well siting. The primary recommendation would be to inspect the well, shock disinfect the well, and retest.
If this was a regulated water source it would be classified as not-potable, and disinfection would be required. As stated, this is a common problem with private wells in PA and the significant variation in the two testing results could suggest induced contamination by the field samplers. Action - Retesting Recommended
Ethylene glycol – the reported value is < 10 mg/L – there is no standard set by EPA or PA, 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)
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 – 3.9 mg/L (OK) – drinking water standard is < 250 mg/L – this does not suggest any specific impact.
Sulfate – 8.9 mg/L (OK) – drinking water standard is < 250 mg/L – this does not suggest any specific impact.
Arsenic – 0.004 mg/L (Total) and 0.0026 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 - 0.275 mg/L (Total) and 0.263 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 – 0.050 mg/L (Total) and 0.0588 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)
Calcium- 31.7 mg/L (Total) and 32.1 mg/L (D) – no specific drinking water standard, drinking water standard is available. (OK)
Copper – 0.0035 mg/L (Total) and 0.0025 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 – 1.62 mg/L (Total) and 0.140 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 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. Because of the high bacterial issue, it is also possible that iron bacteria may be present causing discolored and smelly water. The water probably has a reddish or brown appearance. Elevated level of iron is a common water quality problem in Northeastern Pennsylvania.
Action is recommended, because of an aesthetic issue.
Lead – 0.0019 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 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 Northeastern Pennsylvania. Action Needed may be a warning sign of corrosion.
Magnesium- 5.73 mg/L (Total) and 5.75 mg/L (D) – no specific drinking water standard, drinking water standard is available. (OK)
Manganese– 0.112 mg/L (Total) and 0.105 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 (microbiologically induced corrosion).
Sodium – 15.9 mg/L (Total) and 16.2 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 definitely taste salty. (Source- Dr. Brian Redmond, Professional Geologist). (OK)
Strontium – 0.661 mg/L (Total) and 0.677 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 – 0.004 mg/L (Total) and 0.0039 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 – < 0.002 mg/L (Total) and < 0.002 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 – 0.57 mg/L – No specific drinking water standard. (OK)
Methane – 18 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.
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 31 to 36. Since a ratio of methane to ethane of over 1000typically 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 modifyingthe 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 – 95 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)
Acenaphthylene – the reported level was 0.00001 mg/L. Acenaphthylene is a polycyclic aromatic hydrocarbon – PAHs are created when products like coal, oil, gas, and garbage are burned but the burning process is not complete. Acenaphthylene is a component of crude oil, coal tar and a product of combustion which may be produced and released to the environment during natural fires. Very little information is available on the document that was released and the report indicates that one sample had a detected at 0.00001 mg/L and the other sample was non-detected. There is no EPA or PADEP drinking water standard and the primary recommendation would be to retest the water. During retesting, it is critical to check for airborne sources of contamination during sampling.
Note - PAHs have been detected in surface waters of the United States. In an assessment ofSTORET data covering the period 1980-82, Staples et al. (1985) reported median concentrations in ambient water of less than 0.010 mg/L for 15 PAHs (acenaphthene, acenaphthylene, anthracene, benz[a]anthracene, benzo[b]fluoranthene, benzo[k]fluoranthene, benzo[g,h,i]perylene, benzo[a]pyrene, chrysene, fluoranthene, fluorene, indeno[1,2,3-c,d]pyrene, naphthalene, phenanthrene, and pyrene).
It appears that Arizona and Missouri recommended a limit of < 0.003 ug/L or <0.000003 mg/L.Retesting is recommend. During retesting, it is critical to check for airborne sources of contamination during sampling and it would be advisable to attempt to use a method with a lowerdetection limit. At this point, I am not sure if a certified method can detect acenaphthylene to the recommended level of 0.000003 mg/L – still researching.
Anthracene the reported level was 0.00023 mg/L (0.23 ug/L). This is an unregulated synthetic organic compound and polycyclic aromatic hydrocarbon. PAHs are created when products like coal, oil, gas, and garbage are burned but the burning process is not complete. There is no EPA or PADEP drinking water standard and the primary recommendation would be to retest the water.
Retesting recommended. During retesting, it is critical to check for airborne sources of contamination during sampling. The EPA reports a trigger value of 1.3 mg/L, but I can not find this reference. I did find a reference to a DWEL of 2.0 mg/L. It appears that the health-based screening requirement in California is 2.0 mg/L and a lifetime exposure limit is 10 mg/L- based on this information (OK).
Benzo(a)pyrene – the reported level was 0.00020 mg/L (0.00016 to 0.0002 mg/L).The EPA and PADEP have a primary drinking water standard of 0.0002 mg/L. The value is at the maximum contaminant level for a regulated water source. The primary recommendation would be to continue to monitor this source and make sure to monitor the source following a recharge event.
4-Bromopheyl-Phenyl Ether – the reported level was 0.00018 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. (OK)
Butyl benzyl phthalate – the reported level was 0.00035 mg/L – “Benzyl butyl phthalate, 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 benzyl phthalate is an industrial solvent and additive used in adhesives, vinyl flooring, sealants, car-care products and some personal care products. (OK)
Carbazole (Diphenylenimine) was reported at a level of 0.29 ug/L or 0.00029 mg/L. Carbazole is released to the atmosphere in emissions from waste incineration, tobacco smoke, aluminum manufacturing, and rubber, petroleum, coal, and wood combustion. If released to the atmosphere, vapor-phase carbazole is rapidly degraded by photochemically produced hydroxyl radicals (estimated half-life of 3 hrs.). In the particulate phase, the rate of degradation depends upon the adsorbing substrate. The EPA does not have a regulated drinking water limit, but it appears Florida has set a standard of 0.0075 mg/L. (OK)
4-chlorophenyl phenyl ether was reported at a level of 0.10 ug/L or 0.0001 mg/L. The preliminary research suggests that this chemical has a relatively low solubility and would have a tendency to bind to soil and sediment. In general, it is considered to be insoluble or have a low solubility in water. The U.S. EPA STORET Data Base, 1,333 samples, 1.1% positive, median concentration less than 10 ug/L or 0.010 mg/L. Because of the affinity to have only slight mobility in soil and water and because the well is vulnerable to near surface activity, it may be advisable to check the area around the well for evidence of surface contamination.
Florida appears to have established a standard of 0.010 ug/L. Based on the available standard, the level seems appropriate, but it would be advisable to monitor the quality of the water and inspect the area for signs of surface contamination. (OK)
Dibenzofuran (Dixons) was reported at a level of 0.04 ug/L or 0.00004 mg/L. Dibenzofuran is used as an insecticide, to make other chemicals, and is a by-product of combustion. It is made from coal tar and has been found in coke dust, grate ash, fly ash, and flame soot. In addition, it can be found in tobacco and as a combustion product. Dibenzofuran may be released from the incomplete combustion of coal biomass, refuse, diesel fuel and residual oil, as well as from tobacco smoke.
Based on the available information, the primary recommendation would be to conduct amore detailed site-specific evaluation and conduct confirmation testing. Since this well appears to be susceptible to near surface impacts, it may be possible to eliminate exposure by improving control at the wellhead to reduce vulnerability to contamination. No clear standard, but follow-up testing and on-site evaluation is recommended.
Note - The aerobic decomposition in an aerobic and anaerobic environment is < 28 days to over 112 days.
Comment: the presence of the partially combusted material and the bacterial contamination is making me believe there is a local source of contamination, i.e., old burn pit, burn barrels, etc. This is not a judgment, but it makes me very interested in seeing this site and the condition of the well and surrounding area.
Fluoranthene (Benzo(j, k)fluorene) was reported at a level of 0.27 ug/L or 0.00027 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.
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 months to 2 yrs).” 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.
Benzo(k)fluoranthene was reported at 0.32 ug/L or 0.00032 mg/L and the reported EPA trigger level is 0.029 mg/L. Florida has a health advisory at 0.0005 mg/L. (OK)
Benzo(b)fluoranthene was reported at 0.15 ug/L or 0.00015 mg/L and the reported EPA trigger level is 0.0056 mg/L. Florida has a health advisory at 0.0005 mg/L. (OK)
Fluorene was reported at 0.10 ug/L or 0.0001 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)
“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
Hexachlorobenzene (HCB) - was reported at 0.22 ug/L or 0.00022 mg/L and the reported PADEP/ EPA has a MCL of 0.001 mg/L. (OK) Florida also has a standard of 0.001 mg/L. (OK)
Ortho Nitroaniline (2-Nitroaniline)- the reported value was 0.00007 mg/L and the EPA indicates a trigger level of 0.15 mg/L. The NY regulations suggest a limit of 0.005 mg/L is the principle organic standard. (OK)
3-Nitroaniline -the reported value was 0.00012 mg/L and the EPA indicates that there is no trigger level. The NY regulations suggest a limit of 0.005 mg/L is the principle organic standard. (OK)
4- Nitrobenzenamine - the reported value was 0.00014 mg/L and the EPA indicates that there is a trigger level at 0.061 mg/L. The NY regulations suggest a limit of 0.005 mg/L is the principle organic standard. (OK)
4-Nitrophenol - the reported value was 0.00017 mg/L and the EPA indicates that there is no trigger level. The NY regulations suggest a limit of 0.001 mg/L is the standard for the total amount of phenolic compounds. (OK)
n-Nitrosodimethylamine (NDMA) - the reported value was < 0.005 mg/Land the EPA indicates that there is a 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 alkylamine 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.
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.
n-Nitrosodiphenylamine - the reported value was 0.00017 mg/L and the EPA indicates that there is a trigger level at 1.0 mg/L.
It dissolves in water, but it binds to soil and does not move quickly through soil. It breaks down in air, water, and soil within several weeks. For drinking water, the EPA has suggested trigger limits that range from 0.070 to 0.70 mg/L. Looks Ok – but may want to monitor.
Pentachlorophenol – the reported value was < 0.005 mg/L, but the EPA/PADEPMCL is < 0.001 mg/L. The NY regulations suggest a limit of 0.001 mg/L is the standard for the total amount of phenolic compounds. The EPA has a DWEL of 0.2 mg/L.
Looks OK, but retesting using a method with a lower detection limit may be advisable.
benzo(ghi)perylene – the reported value was < 0.0021 mg/L, but there is no MCL or trigger limit. Like most PAHs, benzo(g,h,i)perylene is used to make dyes, plastics, pesticides, explosives and drugs. 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 0.210mg/L for benzo(ghi)perylene. (OK)
phenanthrene– the reported value was < 0.0023 mg/L, but the there is noMCL or trigger limit. Florida has a health advisory level of 0.210 mg/L for phenanthrene. (OK) (Source)
dimethyl phthalate – the reported value was 0.00015 mg/L and the reported trigger limit is 1.4 mg/L. Florida has a health advisory level of 70 mg/L for dimethyl phthalate. (OK)
di-n-octyl phthalate (DNOP)- the reported value was 0.00028 mg/L and no trigger limit is reported. Exposure to di-n-octylphthalate occurs mainly from eating food or drinking water that is stored in plastic containers. There does not appear to be an action limit, but it would be advisable to monitor and conduct a site-specific survey. “This type of plastic can be used for medical tubing and blood storage bags, wire and cables, carpet back coating, floor tile, and adhesives. It is also used in cosmetics and pesticides.”
Pryene - the reported value was 0.00026 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)
indeno(1,2,3-cd)-pryene- the reported value was 0.00021 mg/L and the reported trigger limit is 0.003 mg/L. It is a polycyclic aromatic hydrocarbon (PAH). (Source for standard not available). (OK)
This sample seems to have as series of detects for polycyclic aromatic hydrocarbons (PAHs), plus is positive for bacterial contamination.
“Polycyclic aromatic hydrocarbons (PAHs) are a group of over 100 different chemicals that are formed during the incomplete burning of coal, oil and gas, garbage, or other organic substances like tobacco or charbroiled meat. PAHs are usually found as a mixture containing two or more of these compounds, such as soot. “ (Source)
Again – I have not been to the site, but I am wondering if the well is vulnerable to bacterial contamination is it also vulnerable to air-borne or local contamination related to the burning of materials. I have recommended the following:
a. An evaluation of the well – including a shock disinfection.
b. Local wellhead survey to attempt to identify local sources of potential contamination.
c. Recommended retesting for a number of parameters to either monitor or to use a different method with a lower detection limit. This should include monitoring following a recharge event.
d. Methane above the action limit – recommend venting and other modifications to the well and regular monitoring. The gas appears to have a thermogenic origin, but additional analysis is recommended.
e. Retesting for glycol using a more sensitive method.
f. Iron and manganese exceeds secondary drinking water limits that were set for aesthetic reasons.
g. Recommend testing the well water for forever chemicals (PFOA and PFOS).
This is not about cause and effect- it is an honest review of the data. Period!
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