DEP Releases File – 243 Cases Where Natural Gas Development Impact Private Wells Pennsylvania
This story was released on August 28, 2014 by the Associated Press. The link to the story is “Online list IDs water wells harmed by drilling” (Looks like article was removed- 9/28/2014). First- I am not a fan of the title, but the list does provide insights into the number of private wells that the PADEP has concluded were directly influenced by oil and gas development in Pennsylvania during the period from 2008 to 2014- Regional_Determination_Letters . Also, this story was pre-dated by a very good story in the Sunday Times in May 19, 2013.
May 2013 Story
As of May 2013, the PADEP had determined that 161 private wells had been adversely impacted by oil and natural gas development in PA over the period from 2008 to 2o12. But during this period, over 1000 cases or problems with private wells were evaluated. A quote from the article
“Inspectors declared the vast majority of complaints – 77 percent of 969 records – unfounded, lacking enough evidence to tie them definitively to drilling or caused by a different source than oil and gas exploration, like legacy pollution, natural conditions or mining. One in six investigations across the roughly five-year period – 17 percent of the records – found that oil and gas activity disrupted water supplies either temporarily or seriously enough to require companies to replace the spoiled source.”
Question Number 1 – what caused or is causing 77% of the problem? – Is this NOT important? Answer – NO one seems to be asking.
Question Number 2 – How many were temporary?
Statement 1: The 2013 and 2014 article proves what we have been saying since 2009. Oil and gas development has the potential to adversely impact private wells. The cause is most likely related or associated with drilling, methane migration associated with cementing / casing issues, spills, pipeline construction (shallow excavation) and the use of impoundments to store waste. We have been saying this since 2009 and so has the PADEP. Also, we recommended baseline testing parameters based on the pathways that were cited and suspected.
Statement 2: The common problems appear to be methane, Lower Explosion Limit, iron, manganese, aluminum, arsenic, and turbidity. We included these parameters in our baseline testing list, plus saline water indicates such as bromide and lithium well before PADEP, PSU, and others.
Statement 3: No credible source has ever said Oil and Gas Development could not adversely impact a private well. What has been said – there is not evidence that that hydraulic fracturing portion of the development has caused a problem. There has been many historic cases related to loss of circulation during drilling, mud migration, spills, surface disturbance, methane gas migration because of cement issues, spills, and releases from impoundments.
August 2014 Story
Statement 1: After looking at the 2014 article and the individual determination letters from PADEP for the Eastern Portion of Pennsylvania (excluding the first 19 because this is the Dimock Data- We Did a Well by Well Evaluation of the Dimock)- we found the following:
Eastern Data Set –
Stated Cause
Drilling – 84
Impoundment Leak – 1
Spill/ Surface Containment Issue – 1
LEL – > 10% LEL in wellhead – 4
Presumption – The Operator was presumed to be at fault – 20 %
Temporary Problem that resolved – 26 % (but still a problem for a period of up to a year)
Methane at any level – 78 cases
Methane > 28 mg/L – 24 cases
Methane > 10 mg/L – 68 cases
Methane < 10 mg/L – 6 cases
Methane < 5 mg/L – 2 cases
Iron – 30 cases – 28 %
Manganese – 41 cases – 38 %
Aluminum – 15 cases – 14%
Barium – 3 cases – 2.8 %
Total Dissolved Solids -TDS – 4 cases – 3.7 %
Chloride – 2 cases – < 2 %
Zinc – 1 case – < 1 %
From a review of the letters of determination, it appears that the PADEP made the determination in less than 2 months. I believe there is a regulatory requirement to make a determination in 45 days or less.
Other Interesting Notes
1. In one well the methane ranged from 0.29 to 148 mg/L
2. Two cases wellhead LEL was the determining factor and in one case the methane level in water was less than 2 mg/L – probably a venting issue.
3. Two springs were impacted.
4. Barium – two cases had pre-drill problems.
5. Only 1 case where organics were the issue – associated with a fire suppression activity because of loss of control at the wellhead. Suppressant was used at the surface.
What this tells us:
1. Most of the problems appear to be related to iron and manganese – these makes it difficult because it is a common and intermittent water quality problem in the region.
2. Methane is another factor – but it is critical to document both methane and all other gas issues and LEL levels.
3. Other parameters of importance include aluminum (we recommend in 2009) and barium, chloride, total dissolved solids, and zinc.
4. The process seems to work, but it would be great to have access to the raw data.
Again – trying to provide a fact based review of the information and use wisely. The main questions:
1. How many other wells reported a problem?
2. How many of these wells had a problem unrelated to oil and gas development? What was the cause?
3. How many private wells were impacted by other permitted activities or road salting efforts over the period from 2008 to 2014?
Final Question – If we do not create private well construction standards and fix the poorly constructed private wells – Will we really Ever Control this Potential Pathway for Groundwater Contamination.
Action You can Take!
1. Get your Well Water Baseline Testing Completed.
2. Have the data reviewed.
3. Release the Data -Data Only to the Citizens Database
4. Learn the Facts and Monitor Your Well Water Quality – Work as a Community!
5. Support the Keystone Clean Water Team – Facebook, Twitter, and maybe a Donation?
Volunteer
We seek new people at all skill levels for a variety of programs. One thing that everyone can do is attend meetings to share ideas on improving KCWT/CCGG, enabling us to better understand and address the concerns of well owners. We need individuals to provide copies of our brochure and information at local events, consider hosting a presentation, and sharing our facebook and twitter posts.
Everything we do began with an idea.
We realize your time is precious and the world is hectic. KCWT/ CCGG’s volunteers do only what they’re comfortable with. It can be a little or a lot.
For more information, please go to KCWT/CCGG’s About Page or contact us.
Clean Water Act Comments are Needed
by Peters Consultants, Inc. 100 Robbins Ave Berwick, PA 18603
The new rule, which was proposed by the Environmental Protection Agency and the U.S. Army Corps of Engineers, would codify their interpretation of the Clean Water Act after a 2006 Supreme Court ruling. In addition to navigable waterways, the rule provides EPA protection for certain wetlands and “seasonal and rain-dependent” streams.
The proposal would lead to stricter pollution controls on some of these areas and aims to resolve a long-running legal battle over how to apply the Clean Water Act to the nation’s intermittent and ephemeral streams and wetlands.
However, this rule could be a major intrusion for municipalities and landowners and a means to expand jurisdiction thereby regulating more property. Many of the new “definitions” are likely to cause more confusion instead of less. And, if enacted in its current form, the new rule could encompass lands that are wet and, in many cases, without beds and banks, as well as associated lowlands and transitional zones between open waters and upland areas.
Under these new definitions, almost any body of water, regardless of how small, could possibly be regulated. That means more projects and activities would be subject to permitting requirements, resulting in possible delays and significant additional costs.
The U.S. Environmental Protection Agency (EPA) announced that it would be extending the comment period for a regulatory proposal to expand the jurisdiction of the Clean Water Act. The 90-day comment period, which was set to end on July 21, was extended by an additional 91 days to October 20, following an outcry by a number of groups. The complexity of the proposed rule necessitated a lengthier comment period.
During the public comment period, municipalities, businesses, and citizens have the opportunity to express their concerns about the potential impact of the new proposed rule. So if you want to be heard and potentially sway the final wording of this proposed wide-sweeping rule, speak now. Comments must be received by October 20, 2014
If you are interested in participating in the EPA’s public comment period, contact your congressional representative or send an email to:
or mail comments to:
Water Docket, Environmental Protection Agency
Mail Code 2822T
1200 Pennsylvania Ave NW
Washington, DC 20460
Attention Docket ID No. EPA-HQ-OW-2011-0880
Peters Consultants, Inc –
Peters Consultants, Inc. is a full service consulting engineering/design firm located in Berwick and Bloomsburg Pennsylvania, and has provided professional consulting services in the engineering, environmental and land surveying disciplines to municipal, authorities, commercial, industrial and private clients since 1975. We are a leading provider of engineering services in northeastern Pennsylvania by using sound and practical engineering judgment and skills when evaluating potential projects.
More Reading on Proposed Clean Water Act
Iowa State University – Proposed Regulations WOULD Greatly Expand Clean Water Act
Washington Post – EPA Proposes Greater Protections (Now the Opposite)egal Review – Non-Jurisdictional Waters in the EPA’s Draft “waters of the US” Rule; Clean Water Act- “So here’s where the water really turns to mud on these non-jurisdictional waters. Can you and nine other people of normal but different intelligence and experience, exercising normal discernment, look at the same property and come to the exact same conclusion about which parts of the property are jurisdictional? And remember, the fine for being wrong could be a cool $75,000 per day. If not, then maybe there are some changes you could suggest to the EPA in the form of written comments to this rule.”
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