The Baseline Water Testing Process It is NOT Just About Getting a Sample
The Baseline Water Testing Process It is NOT Just About Getting a Sample
By Brian Oram, Professional Geologist
Carbon County Groundwater Guardians
Published in March ONG Marketplace
We have had the opportunity to witness a wide range of practices that have been called baseline testing. We have seen a team of 4 professionals working for the EPA in Dimock, Pennsylvania, take 4 to 5 hours to collect one water sample and we’ve seen a single sampler with virtually no training take 15 minutes to purge and sample a private well with no field measurements or even gloves. The potentially negative impacts of this wide variation in sampling techniques and experience is compounded by the lack of field documentation and a quest for that “single” list of parameters. This approach will make for great future lawsuits and media stories, but does little to generate the reliable data required by professionals, scientists, regulatory agencies, and the public.
The key elements to effective baseline testing should include:
a. A selection of parameters and indicators that meets the regional environmental conditions and addresses the historic and proposed activities and practices in the region and not just a simple list provided or recommended by a regulatory agency;
b. chain-of-custody practices with internal and external quality control (QC) and quality assurance (QA) that start and end with the certified laboratory working with a trained third-party professional;
c. field documentation, including notes, field measurements, and photos, that includes a summary of the existing condition of the private water distribution system;
d. field sampling done by third-party samplers that are either licensed professionals or specifically trained in the standard operating procedures of the certified testing laboratory, plus these individuals must have a working understanding of common water treatment systems; and
e. prior to releasing the data, the certified laboratory must validate and review the data, plus work with the third-party professional to confirm or check the reliability and validity of the results.
As part of our outreach efforts, we have been able to review baseline testing conducted by multiple entities. Here is just one example for your consideration.
The sample was collected by a non-professional, third party sampler, tested by a certified testing laboratory, and then given by a natural gas company to a private well owner. The sample was collected only a few weeks before drilling started. The well owner was given a report with the raw data, spike and recovery analysis, surrogate testing results, field data sheet, and a full listing of the methods and the laboratory certifications. When the homeowner, a royalty owner, asked if there was any problems, we provided them a list.
1. The field conductivity was reported at 250 uS/cm, but the certified laboratory data had reported a total dissolved solids of 1500 mg/L;
2. The cation and anion mass balance was out of balance by over 25 %;
3. Total metal values less than dissolved metal values; and
4. The well had arsenic at over 10 times the primary drinking water standard, but this was never flagged as a problem for the private well owner.
This data is not scientifically valid and does not make sense. It may be certified, but it is wrong and there is no time to collect another pre-drill sample.
As professionals, we have the obligation to attempt to get it right and to properly inform citizens when a problem is identified. It is critical that we implement a process to screen the water quality data before it is distributed to the community. To build trust, the data must be provided to the private well owner in a format they can understand.
Baseline testing can be a valuable tool for the environmental professional, gas drilling industry, and community. With proper planning, baseline testing can used to determine where additional documentation or monitoring is needed and to determine the location of systems or wells vulnerable to influence.
In our opinion, baseline testing is not just part of an environmental audit, but in many ways, it is an opportunity for the company and consultant to build trust in the community. At the same time, the company is attempting to mitigate risk by documenting pre-existing conditions, the data collected during this baseline assessment should be used to make critical decisions related to the use of best management practices and build trust in the community through education and outreach.
Baseline testing is a community issue. We ALL live downstream and we need to solve problems as a community. This is a great opportunity to make a positive difference in your host community. Options for informational well water testing.
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