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-47 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)
Heterotrophic Bacteria – not reported. The drinking water limit is < 500 colonies per 100 ml (OK).
Total Coliform < 1 colony per 100 ml (OK)
Aluminum – < 0.030 ****mg/L (Total) - drinking water standard ranges from 0.05 to 0.2 mg/L. This parameter is regulated as a secondary drinking water standard, because of aesthetic reasons. The treated water level of aluminum is < 0.030 mg/L. (OK)
Anionic Surfactants – 0.014 mg/L – the secondary drinking water standard for foaming agents is 0.5 mg/L. (OK)
Arsenic – 0.0907 to 0.0942 mg/L – drinking water standard is < 0.010 mg/L – the level is above the primary drinking water standard. 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.Treatment of arsenic reduction is advisable- the existing treatment system does not appear to reduce the level of arsenic to below 0.010 mg/L. The post-treatment level appears to be 0.090to 0.091 mg/L. (Action is Wise)
Barium – 0.485 mg/L – the primary drinking water standard for barium is 2.0 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. After treatment, the concentration is < 0.010 mg/L. (OK)
Bromide – < 0.5 mg/L - In freshwater, bromide is typically less than 0.05 mg/L. Therefore, it would be advisable to retest using a method with a lower detection limit.
Boron –0.140 mg/L (Total) – 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.
Calcium- 23.70 mg/L (Total)– no specific drinking water standard drinking water standard is available. After treatment, the level of Calcium is 22.10 mg/L.(OK)
Chloride –2.78 mg/L (OK) – drinking water standard is < 250 mg/L – this does not suggest any specific impact.
Chromium- < 0.002 mg/L (D) and the EPA/ PADEP primary drinking water standard is < 0.100 mg/L (OK).
Copper – 0.0101 mg/L (Untreated) - the secondary drinking water standard is 1.0 mg/L and the primary drinking water standard is 1.3 mg/L. (OK) At the tap the level was < 0.002 mg/L.
Ethane –< 0.0012 mg/L – No specific drinking water standard (OK)
Ethene - < 0.0011 mg/L – No specific drinking water standard (OK)
Fluoride – 0.184 mg/L – drinking water standard is < 2 mg/L- PADEP drinking water standard is2 mg/L.
Iron – 4.55 mg/L (Total) – 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. After treatment, the level is < 0.10 mg/L. (OK- with treatment)
Lead – < 0.001 mg/L ****(Total) - 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. (OK)
Lithium – < 0.200 mg/L (Total) – no specific drinking water standard drinking water standard is available, but EPA has recommend a level be below 0.7 mg/L (OK)
Methane – 7.9 to 10 mg/L – No specific drinking water standard. The well water is above the new action limit of 7 mg/L. Action is needed – this may include passive to active venting, monitoring, and possibly treatment.
Magnesium-3.95 mg/L– no specific drinking water standard drinking water standard is available. (OK) The treated water level of magnesium was 5.57 mg/L. After treatment, the level is < 0.50 mg/L.
Manganese– 0.947 mg/L (Total) – 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. After treatment the level is < 0.001 mg/L. (OK-with treatment)
Nickel – 0.001 mg/L – no specific drinking water standard drinking water standard is available, but the EPA has suggest a MCL of 0.1 mg/L. (OK) With treatment, the level is < 0.001 mg/L.
Potassium – < 2.0 mg/L (Total– no specific drinking water standard drinking water standard is available (OK)
Sodium –53.6 mg/L – 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). After treatment, the level was higher at 93.9 mg/L. (OK- but they may want to consider a K-based salt)
Sulfate –2.64 mg/L (OK) – drinking water standard is < 250 mg/L – this does not suggest any specific impact.
Strontium – 0.757 mg/L – 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) After treatment, the level is < 0.200 mg/L.
Total Dissolved Solids – 187 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. After treatment, the level was higher 231 mg/L (OK).
Total Suspended Solids - < 10 mg/L – no standard, but would recommend retesting to obtain a lower detection limit.
Uranium –< 0.001 mg/L (Total) – 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 – Zinc is regulated as a secondary drinking water standard by the PADEP in Pennsylvania and the action limit is 5.0 mg/L. After treatment, the level of zinc was < 0.002mg/L. (OK)
Nitrate+Nitrite- N – < 0.05 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 fornitrite-N. (OK)
Acetone - the reported value was < 0.002 mg/L. PADEP has a Medium SpecificConcentration (MSC) for aquifers with a TDS of < 2500 mg/L of 33.0 mg/L and Massachusetts appears to have a drinking water standard of 6.3 mg/L. (OK)
T. Phosphate – 0.287 mg/L – after treatment 0.329 mg/L – this seems high for the region, but is more likely related to agricultural development or the use of septic systems. No drinking water standard (OK)
Ethylene glycol – the reported value is < 10 mg/L – there is not 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)
Butyl benzyl phthalate – 0.00007 mg/L (J) value – the EPA Trigger value is 1.40 mg/L – A J value is an estimated value, below the detection limit for the method. Butyl Benzylphthalate is an industrial solvent and additive used in adhesives, vinyl flooring, sealants, car-care products, and some personal care products. It is slightly soluble in water, but it appears to be more of an air-borne contaminant. There does not appear to be any guidance on allowable levels in drinking water (World Health Organization).
Benzylbutylphthalate, also called n-butyl benzyl phthalate (BBP) or benzyl butyl phthalate, is a phthalate, an ester of phthalic acid, benzyl alcohol and n-butanol.” The health based screening level appears to be 0.100 mg/L and the EPA Human Health Equivalent is 1.4 mg/L. (OK)
1. Methane above the action limit -Action is needed and isotopic analysis advisable.
2. At a minimum, I would recommend retesting for ethylene glycol other and glycol-type compounds using a method that is more sensitive or conducting some type of standard additions analysis.
3. Installing or updating the treatment system to handle arsenic and considering the use of a potassium based salt as an alternative the sodium-based salt that appears to being used.
4. Recommend testing the well water for forever chemicals (PFOA and PFOS).
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