The Marcellus Shale Coalition (MSC) released a Recommended Practice (RP) for pre-drill water supply surveys. This is the third in a series of recommended practices, all aimed at reinforcing the MSC’s Guiding Principles to “continuously improve our practices and seek transparency in our operations” while furthering a fact-based dialogue that encourages responsible American natural gas development.
Pennsylvania regulations require natural gas producers to sample and test – with the owner’s consent – all water supplies within 2,500 feet of a proposed Marcellus Shale natural gas well. These pre-drill tests, which are conducted by certified laboratories, provide a baseline analysis of water chemistry prior to site preparation and development activities. Many natural gas producers test well beyond the 2,500 feet requirement, and were doing so prior to Pennsylvania enacting these new regulations.
According to the Center for Rural Pennsylvania, nearly 40 percent of Pennsylvania’s water wells do not meet at least one safe drinking water standard and another 20 percent of wells contain pre-existing methane. More information about that analysis is available here. The pre-drill water survey RP document, along with an overview, is available here.
“For years, well before shale gas production began in the Commonwealth, straightforward science has informed us that Pennsylvania’s groundwater chemistry drastically varies across regions,” said MSC president Kathryn Klaber. “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. 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.”
Developed by technical experts from a host of MSC member companies, this RP recommends the following steps:
- A pre-drill survey should be conducted on all identified water supplies within a given area of the well pad surface location as required by the State Regulatory Agency (SRA).
- 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 supply(ies) and sampling location(s). Use GPS (preferably NAD83 datum) to determine and record the latitude and longitude of each water supply.
The samples shall be collected, in accordance with all appropriate sample collection, preservation, handling, and defensible chain-of-custody procedures. Appropriate sample collection procedures can be found on the United States Environmental Protection Agency (USEPA) website (www.epa.gov).
- Water samples shall be analyzed by an SRA certified laboratory using USEPA SW-846 methods or drinking water methods (where drinking water methods exist). For parameters that have a Maximum Contaminant Level (MCL), the laboratory should be instructed to provide a laboratory reporting limit no greater than the published MCL.
- Operators should inform the water supply owners and/or residents that any and all information/data collected will be provided to the owner/occupant and to the SRA (if required by state regulations) and, as such, the information could be disclosed as public information upon inquiry to the SRA.
Continued Klaber: “Additionally, the MSC is developing a robust pre-drill water quality database. When complete, this first of a kind library will serve as an important environmental and public health tool to help address water quality challenges that have persisted in rural communities for decades.”