In response to requests from Plumbing Manufacturers Intl. (PMI) and its members, as well as from other supporters of the U.S....
What to expect and how to protect drinking water
Gas well drilling has been growing in activity over the past 10 years across the U.S.—specifically gas drilling within shale—due to the technological advancements in hydraulic fracturing and horizontal drilling, which has made it more economically feasible to produce. Hydraulic fracturing, often referred to as fracking, is a process that creates fractures within the rock formations to allow more fluids to flow to the well.
This process uses a fracking fluid, which can be made up of a variety of things, including water, gels, foams, air and an often proprietary blend of chemicals. Additionally, a proppant material is used, typically made of grains of sand, ceramic or other particulate used in conjunction with the fracking fluid to move it through the fractures and prevent them from closing when the injection is stopped.
There has been significant media attention given to this industry due to exploding wells and recent groundwater contamination findings near gas drilling sites. Additionally, there have been federal and state regulations surrounding gas drilling activities in some states. Two identical bills were introduced in 2009 known as the Fracturing Responsibility and Awareness of Chemicals (FRAC) Act. The regulators’ intent is to amend the Safe Drinking Water Act, giving the U.S. Environmental Protection Agency (EPA) the authority to regulate hydraulic fracturing that occurs in states that have not taken primacy in the Underground Injection Control regulations.
More importantly, this bill also requires energy companies to disclose which chemicals are being used in the fracking fluid, which could be a source of contamination. The policy only calls for the chemical constituents, since many of the firms that are using these fracking fluids do not want to disclose this information as they claim it as a trade secret.
However, the FRAC Act does require that firms disclose the chemical identity to a physician or state agency if a medical emergency requires it. There have been cases which suggest that hydraulic fracturing may be the cause of water contamination in areas around the drilling locations. Because the 2005 Energy Policy Act exempts hydraulic fracturing from federal water laws, there is no data that links the contamination to this process. The FRAC Act is designed to protect those who live in close proximity to fracturing locations.
Test the Waters
Gas drilling companies typically perform some type of pre-drilling analysis on water supplies that are located within 1,000 ft of the gas well site. Because there is no standard list or regulation directing this testing, the gas companies decide which parameters they will test.
Homeowners having their water tested by the gas company and those located more than 1,000 ft from the well perimeter should consider having a water analysis done independently of the gas company’s testing to ensure unbiased third-party results. They need to make sure to use a laboratory that is certified in the state in which the well is located and is certified for all of the tests being requested. Because these results could have potential legal ramifications, it is important to have the samples collected by a trained third-party collector.
The collection of samples involves a chain of custody. The chain of custody is defined as chronological documentation which shows the seizure, custody, control, transfer, analysis and disposition of evidence—in this case, the water sample. Most laboratories already use forms called chain of custodies, especially if they are performing work to meet regulatory requirements. The chain of custody form accompanies the sample and is dated and signed by everyone who handles the samples to ensure they are not tampered with.
Establish a Baseline
While it is important for homeowners with private wells to test their water, it becomes even more important in areas of gas drilling because these activities may impact drinking water quality. It is important to establish a baseline of water quality so the homeowner can prove legally that the contamination (if any) is a result of drilling activities. Having historical data from previous tests would be helpful in supporting a claim should gas drilling affect water quality. There has been much activity in the state of Pennsylvania with regards to testing the groundwater due to the large Marcellus Shale formations. Because there are many contaminants that could be present in groundwater, it can be confusing for homeowners to determine the correct level of testing needed to protect their drinking water. A professional laboratory will be able to make appropriate recommendations based upon specific needs.
Testing can range in cost from $50 to more than $1,000, depending on how extensive the test is. The minimum testing should include total dissolved solids, pH, brium, chloride and methane. Other parameters to consider include: total suspended solids, turbidity, iron, manganese, total organic carbon, hardness, sodium, strontium, detergents, lead, arsenic, alkalinity, coliform bacteria, sulfate, nitrate, oil, grease and volatile organic chemicals. Many laboratories offer a variety of testing packages geared toward these recommendations to assist homeowners in choosing the package to best protect their water source.
Gas well drilling will continue to grow as we look for ways to fulfill our energy needs using domestic resources. As drilling grows, so will the need to protect private wells and othegroundwater supplies. While it may be apparent to some that these water supplies are at risk, regulations always take time.
The EPA currently is launching a new study on hydraulic fracturing which should uncover any potential contamination. The EPA also released a study in 2004 that stated hydraulic fracturing would not affect groundwater; however, this study did not include any water testing data.
Until the EPA can conduct this new study and conclusively determine the effect this drilling is having on groundwater, there is no regulation in place, so it will remain on the shoulders of homeowners to protect their water quality. Homeowners will need to set the baseline for their water quality to protect themselves in the future, while waiting for regulators to figure out the next step today.
SIDEBAR:Considerations When Testing to Establish a Water Quality Baseline
From Brian Oram, professional geologist and laboratory manager for the Center for Environmental Quality at Wilkes University.