Marcellus Trade Group Lays Out Pre-Drill Water Testing Practices
The State Journal
29 August 2012
By Pam Kasey
Pre-drill water quality testing is the subject of the third in the
Marcellus Shale Coalition's series of "recommended practices"
documents aimed at providing guidance on a range of subjects.
"Recommended Practices: Pre-Drill Water Supply Surveys," issued
Aug. 28 by the Pennsylvania-based natural gas trade group, lays
out simple guidelines for oil and gas operators and may serve as a
useful reference for water supply owners as well.
Groundwater chemistry is known to vary across regions, said MSC
President Kathryn Klaber in a media release — an observation she
applied to Pennsylvania but is true anywhere.
"This Recommended Practice builds upon what's required by law and
lays out in great detail steps operators can take to help ensure
homeowners have a clear understanding of their water quality
before natural gas-related activities begin," Klaber said. "These
tests, paid for by the natural gas producer, are shared with the
well owners and state regulators, serving a critical public health
function in many cases."
The 11-page document, which MSC said was developed by technical
experts from its member companies, explains that the purpose
of a pre-drill survey is to establish baseline water quality
conditions for the protection of both the operator and the water
user or owner.
The document recommends the following steps:
A pre-drill survey should be
conducted on all identified water supplies within a given area
of the wellpad surface location as required by the state
Water supply sources such as wells,
springs and ponds should be evaluated prior to earth disturbance
for site construction or prior to spud. Consideration should
also be given to sampling water supply sources that are not
currently in use.
With the assistance of the water supply
owner, locate the water supplies and sampling locations. Use
GPS, preferably NAD83 datum, to determine and record the
latitude and longitude of each water supply.
The samples should be collected in
accordance with all appropriate sample collection, preservation,
handling and defensible chain-of-custody procedures such as
those outlined by the United States Environmental Protection
Agency, or USEPA.
Water samples should be analyzed by a
state regulatory agency–certified laboratory using USEPA SW-846
methods or drinking water methods where drinking water methods
exist. For parameters that have a Maximum Contaminant Level, the
laboratory should be instructed to provide a laboratory
reporting limit no greater than the published MCL.
Operators should inform the water supply
owners or residents that any and all data collected will be
provided to the owner/occupant and, if required, to the state
regulatory agency and, as such, the information could be
disclosed as public information upon inquiry to the agency.
The document offers a list of 30 water quality parameters that
"should be considered." That list is essentially the same as the
list gas producer EQT supplied to The State Journal in 2011 as the
parameters it tests.
The MSC also said it is developing a pre-drill water quality
database that will serve as an important environmental and public
health tool to help address water quality challenges that have
persisted in rural communities for decades.