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 regulatory agency.
    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.