Impartial Fact-Based Judgment

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-14 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.

Dimock Pennsylvania Water Contamination EPA Testing Water On File (May 2012)

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.

Comments on HW-14 Data

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.

Well – HW-14 (1/2012)

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

Anionic Surfactants – 0.03 mg/L – the secondary drinking water standard for foaming agents is 0.5 mg/L. (OK)

Ethane – 0.0029 mg/L – No specific drinking water standard (OK)

Methane – 3.8 mg/L – No specific drinking water standard. (OK).

Methane/Ethane Ratio:131 (biogenic)

Note - Methane at the sink, possibly after treatment – 0.049 mg/L.

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 ls critical.

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 Minnesota 14.0 mg/L (14,000 ppb

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.

Chloride – 17.70 mg/L (OK) – drinking water standard is < 250 mg/L – this does not suggest any specific impact.

Sulfate – 14.40 mg/L (OK) – drinking water standard is < 250 mg/L – this does not suggest any specific impact.

Arsenic – < 0.001mg/L (Total) and < 0.001 mg/L (D) – drinking water standard is < 0.010 mg/L – OK

Barium - 0.0893 mg/L (Total) and 0.0857mg/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- 29.9 mg/L (Total) and 29.7 mg/L (D) – no specific drinking water standard, drinking water standard is available. (OK)

Copper – 0.0021 mg/L (Total) and < 0.002 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)

Note - the copper appears to be higher at the kitchen sink – this could suggest some type of chemical / biological corrosion within the distribution system.

Lead – 0.001 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. The level of lead after the treatment system and distribution system is 0.0015 mg/L.

Note - the lead is higher at the kitchen sink – this could suggest some type of chemical / biological corrosion within the distribution system.

Magnesium - 5.27 mg/L (Total) and 5.28 mg/L (D) – no specific drinking water standard, drinking water standard is available. (OK)

Manganese – 0.0083 mg/L (Total) and 0.0078 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 0.0016 mg/L (D) – no specific drinking water standard, drinking water standard is available, but the EPA suggest a MCL of 0.1 mg/L. (OK)

Sodium – 9.42 mg/L (Total) and 9.26 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)

Zinc – 0.0036 mg/L (Total) and 0.005 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)

Note - After treatment the Zinc content is 0.0268 mg/L – this would suggest some form of chemical or biological corrosion within the distribution system.

Total Dissolved Solids – < 10 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. (Question – this value seems inaccurate or a typo – This should be redone.)

Nitrate + Nitrite – 1.48 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 ok, but it may be advisable to test for nitrite-N. (OK)

Findings and Recommendations

1. No major problems

2. Heterotrophic bacteria data is not provided.

3. Methane/Ethane Ratio could suggest the source of the methane is biogenic.

4.Total Dissolved Solids results seem inaccurate or there is a typo in the draft report.

5. Higher levels for select metals suggest there could be some corrosion within the distribution system, but the levels do not exceed a primary or secondary drinking water standard.

6. Nitrate-Nitrite at 1.48 mg/L – it may be advisable to check the level of nitrite in the water.

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

8. Recommend testing the well water for forever chemicals (PFOA and PFOS).