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-4 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 are 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)
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)
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 definitely taste 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.
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)
Fluoranthene (Benzo(j, k)fluorene) was reported at a level of < 5 ug/L or0.005 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 0.5ug/L or 0.0005 mg/L for benzo(k)fluorene. Might be advisable to retest using a lowerdetection 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.
Nitrate+Nitrite- N – 0.64 mg/L, this is well below the EPA / PADEP drinking water limit of10mg N/L for nitrate-N and would also be below the limit of 1.0 mg N/L for nitrite-N. (OK)
1. The available data does not identify 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. At a minimum, I would recommend retesting for ethylene glycol and other glycol compounds using a method that is more sensitive or conducting some type of standard additions analysis.
3. Methane/ethane ratio - 68. 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 microbial" (Mr. Bob Pirkle, President of Microseeps, Inc.), but between 25 and 2500 this is where isotopic analysis and gas composition analysis is critical.
4. Consider testing the well for the forever chemicals (PFOA and PFOS).
5. Again – this is not about cause and effect- it is an honest review of the data.
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