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-20 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-20 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 exists 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-20 (1/30/2012)

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

Heterotrophic Bacteria – 67 colonies per 100 ml ( I do not understand the J value). The drinking water limit is < 500 colonies per 100 ml (OK). The presence of these bacteria in the water may suggest an issue related to improper well construction or placement or the need for well maintanence.

Total Coliform < 1 colony per 100 ml or Absent (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 – < 0.01 mg/L – the secondary drinking water standard for foaming agents is 0.5 mg/L. (OK)

Arsenic – < 0.002 mg/L – drinking water standard is < 0.010 mg/L – this does not suggest any specific impact and arsenic is a common problem in Northeast Pennsylvania – about 6 % of private wells have arsenic above 0.010 mg/L. The treated water level of arsenic was < 0.002 mg/L and treated and filtered < 0.002 mg/L. (OK)

Barium – 0.0328 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 0.0329 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. (OK) We would suggest retesting in the future using a method with a lower detection limit.

Boron – < 0.050mg/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 - 22.40 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 –3.41 mg/L (OK) – drinking water standard is < 250 mg/L – this does not suggest any specific impact. After treatment, the reported value was 3.1 mg/L (OK).

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

Copper – 0.0045 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 0.0039 mg/L.

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

Fluoride – 0.109 mg/L – drinking water standard is < 2 mg/L- PADEP drinking water standard is 2 mg/L. After treatment, the reported value was 0.124 mg/L (OK).

Iron – < 0.100 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. (OK)

Lead – 0.0024 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 – < 0.0095 mg/L – No specific drinking water standard. The well water is below the new action limit of 7 mg/L. After treatment, the level of methane is < 0.0095 mg/L. (OK)

Magnesium-5.71 mg/L– no specific drinking water standard, drinking water standard is available. (OK) The treated water level of magnesium was 5.57 mg/L.

Manganese– 0.0026 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 0.0023 mg/L. (OK)

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)

Potassium – < 2.0 mg/L (Total) - no specific drinking water standard, drinking water standard is available (OK)

Sodium – 6.21 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 definitely taste salty. (Source- Dr. Brian Redmond, Professional Geologist). After treatment, the level was 6.04 mg/L. (OK)

Sulfate – 5.73 mg/L (OK) – drinking water standard is < 250 mg/L – this does not suggest any specific impact.

Strontium – < 0.200 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 – 48 mg/L (Value appears low) – 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 109 mg/L (OK- Retesting Recommended).

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– 0.0127 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 0.0158 mg/L. (OK)

Nitrate+Nitrite- N – 0.42 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)

Acetone - the reported value was < 0.002 mg/L. PADEP has a Medium Specific Concentration (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)

Bromoform – < 0.0005 mg/L – the total trihalomethane group has a limit of 0.08 mg/L, but bromoform should be less than 0.004 mg/L. (OK)

Methyl ethyl ketone – < 0.002 mg/L in the treated water and untreated water. (OK)

Methyl ethyl ketone is a colorless volatile liquid that is soluble in water. The odor threshold for methyl ethyl ketone is 5.4 parts per million (ppm), with an acetone-like odor reported. Methyl ethyl ketone is also referred to as 2-butanone. The EPA and PADEP has not set a drinking water standard, but it appears that Massachusetts has set a level of 4 mg/L.

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)

Findings and Recommendations

1. No major problems.
2. Ethylene glycol - the testing was not sensitive enough - recommended retesting using a more sensitive method, i.e., a low level of detection or using a different method.
3. Resample for the total dissolved solids sample and conduct first flush testing of the raw water for copper, lead, and zinc; and
4. Recommend testing the well water for "forever chemicals" (PFOA and PFOS).