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-24 in Dimock, Pennsylvania. The well was sampled by the EPA, DEP, and the local natural gas development company in 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-24 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-24 (2012)

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

Anionic Surfactants – < 0.01 mg/L – the secondary drinking water standard for foaming agents is0.5 mg/L. (OK)

Barium – 0.139 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. (OK)

Boron – 0.251  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. Therefore, this does not appear to suggestany form of impact. (OK)

Calcium- 1.31 mg/L (Total)– no specific drinking water standard drinking water standard is available. (OK) – the value seems low.

Chloride – 6.63 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 – < 0.002 mg/L (OK)- the secondary drinking water standard is 1.0 mg/L and the primary drinking water standard is 1.3 mg/L. (OK)

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

Fluoride – 0.359 mg/L (OK) – drinking water standard is < 2 mg/L- PADEP drinking water standard is 2 mg/L.

Lithium – 0.204 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 – 0.740 mg/L – No specific drinking water standard. (OK).  The well water is not above the new action limit of 7 mg/L.

Magnesium- < 0.500 mg/L (D)– no specific drinking water standard drinking water standard is available. (OK)

Manganese– 0.0038 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. (OK)

Nickel – < 0.001 mg/L (D) – no specific drinking water standard drinking water standard is available, but the EPA has suggest a MCL of 0.1 mg/L. (OK)

Sodium –88.0 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 taste definitely salty. (Source- Dr. Brian Redmond, Professional Geologist). (OK)

Sulfate – 1.46 mg/L (OK) – drinking water standard is < 250 mg/L – this does not suggest any specific impact.

Total Dissolved Solids – 189 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.

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 (Total) – Zinc is regulated as a secondary drinking water standard by the PADEP in Pennsylvania and the action limit is 5.0 mg/L. (OK)

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)

Findings and Recommendations

At a minimum, I would recommend retesting for ethylene glycol other other glycol compounds using a method that is more sensitive or conducting some type of standard additions analysis.

Findings and Recommendations No major problems

1. No major problem, but the presence of boron, lithium, and higher sodium without a spike in an anion, suggests that there may be a source of sodic and alkaline water. It would be interesting to see the actual laboratory results that include total hardness, alkalinity, and pH.

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

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