This story was updated on January 4, 2012.
What if a predrill water well test conducted during the biggest boom for natural gas became meaningless?
At least one predrill test in Pennsylvania has been deemed insufficient by natural gas giant Chesapeake Energy, calling into question the validity of predrill testing and the protection it can offer both water supply owners and gas operators in the state.
Predrill water tests create background or ‘baseline’ data — a ‘signature’ of what’s in water and are used to determine the impact on a water supply from natural gas drilling.
The Pennsylvania Oil and Gas Act of 1984 (OGA), that governs oil and gas operations, says that natural gas companies have five ways to disprove pollution of a water supply within 1,000 feet of a gas well — one of which is through predrill testing.
The Act specifies that “a predrilling or prealteration survey” must be conducted by “an independent certified laboratory.” Provisions to the OGA in Pennsylvania Code add that predrill tests must be submitted to the state Department of Environmental Protection (DEP) within ten business days, or else the test “may not be used to preserve the operator’s defenses.”
According to these regulations, one(1) properly conducted predrill test is sufficient to establish pre-existing conditions of a private water supply.
Chesapeake: Predrill Test Fails to Show Pre-existing Conditions
After a wellhead blew out at one of Chesapeake’s Marcellus Shale natural gas wells in Leroy Township, Pa. about 10,000 gallons of toxic hydraulic fracturing fluid mixed with rainwater spewed into nearby waterways and onto the ground in April 2011. Chesapeake did routine follow-up testing that included re-testing nearby private water wells the company had conducted predrill tests on before drilling.
The investigation revealed a problem with one water well, labeled RW04, located 1,200 feet from the failed Marcellus natural gas well. Initial post-blowout tests revealed methane levels 10 times higher than in the predrill test. Levels of barium, calcium, chloride, magnesium, manganese, potassium, and sodium increased about 10-fold as well.
Despite the significant change in water quality, Chesapeake concluded, citing post-blowout tests and “historical information” from the water well owner himself, that what was found in the water well after natural gas operations and the blowout was part of a pre-existing condition, characters of the well the predrill test missed.
The company concluded that the predrill water test it conducted of the resident’s well failed to reveal the resident’s true water quality prior to operations.
Chesapeake’s conclusion that the predrill test did not reveal pre-existing conditions was based in part upon the homeowner’s own “historical information,” a verbal description about the water tasting salty at times of high use since the water well was drilled in 1998.
The homeowner, Mr. Ira Haire, told Public Herald over the phone that he did not wish to discuss his water well with anyone, adding “Nobody wants any drilled wells around here, but I like it.”
The Value in a Predrill Test
Supposing that Chesapeake is right, and that a predrill water test may not truly reveal pre-existing conditions, it would call into question the validity of predrill tests and their ability to establish baseline data. It would also beg the question, “How should a predrill test be established in the state to protect residents?”
Public Herald posed this question to Bob Haag, a hydrogeologist who has worked under contract for NASA. Haag replied, “In order to make predrill testing meaningful, a resident would have to conduct the same amount of [predrill] work that was done post-blowout on RW04 [the well in question].” This indicated to Bob that all predrill testing at this point in the state could then be meaningless, and that if Chesapeake is right, there was no other way to detect these problems in residential wells found during the post-blowout tests.
“Groundwater conditions fluctuate widely by quarter, and if you want to prove that somethings clean than you’re going to have to show four quarters of data to say anything about the clarity of a particular contaminated well,” Haag said, pointing out that this would cost tens of thousands of dollars per well, but follows protocol in problem areas.
Chesapeake spent $4 million in less than six months on the post-blowout testing, wherein it found that at least one predrill test was unreliable. The company said the problem came from a previously unknown layer of salt in the bedrock, creating an unbalanced profile of compounds in the water — a stratified well. To come to this conclusion they had to lower cameras into the well, and repeat testing for months. From this, they found contaminants in the well water above safe drinking water standards, and installed a $25,000 reverse osmosis water treatment system.
During an interview with Public Herald the company made no mention of how this would change their protocol for future predrill testing. PH is awaiting comment from Chesapeake about predrill testing procedures in light of RW04.
Expensive Predrill Tests May Be Inconclusive
The general “water wisdom” in areas of deep shale oil and gas drilling, including the Marcellus Shale region of Pennsylvania, is to get a predrill test of your private water well before drilling starts nearby or on your property.
Judy Bear, owner and operator of Coudersport Well Drilling in Coudersport, Pa. has been conducting predrill tests for oil and gas parameters since the Marcellus drilling exploded in 2008. When Public Herald asked Bear whether she’d ever had a predrill test fail to show what’s in water, she replied, “No, I have not, and it surprises me that they’re actually questioning their own test person. Then are you saying you have the potential that every pretest is not correct? How then can you be assured that a predrill [test] is valid? People spend a lot of money on these tests.”
The typical water test that includes oil and gas parameters costs about $400 to $1,000, a cost incurred by natural gas drillers when a private water well is within 1,000 feet of a gas well. Some companies, like Chesapeake and Triana Energy, extend testing of private water supplies to 2,500 feet.
This wisdom is supposed to be legally binding, so if oil or natural gas drilling contaminates the groundwater aquifer, possibly impacting your water well, the gas company that’s drilling can be held liable for damages and associated costs, such as additional testing, water treatment systems, and cleanup.
If the company does not agree to help, you’ll then have to hire a lawyer and sue for damages — or live with it. In order to hold up in court, according to some lawyers and testing technicians, your predrill water test must be done within a year of drilling or hydraulic fracturing.
While Pennsylvania DEP suggests that private water well owners test every three years, Penn State University recently suggested once every year, and now recommends testing for bromide. Penn State’s most recent revision of its Water Facts: Testing Drinking Water Supplies Near Gas Drilling Activities removed four pages of information found in a previous version about the potential of drilling causing groundwater contamination. The newer version only eludes to the possibility but does not discuss it directly. (See bottom of article for Penn State’s recommendations, current costs, and the DEP’s suggestions.)
The Death of a Water Well
If natural gas operations contaminate your water supply and the responsible company pays for a treatment system, the groundwater aquifer will most likely remain contaminated, making it impossible to drill any more residential water wells without the intrusion of a water treatment system. Even with treatment, water still may not be up to drinking water standards.
In Dimock, Pa. a battle over groundwater contamination between Cabot Oil & Gas, DEP, and about a dozen Dimock families continues after DEP allowed Cabot to stop clean water deliveries to families who have not accepted a settlement between Cabot and DEP to mitigate the problem with methane-separation water treatment systems and settlement money.
The families contend that the pollution has not been permanently restored, as promised in individual homeowner leases and required in state regulations for the industry. (Read our full report, Drinking Dimock: A Glass Full of Gas Water.)
No Private Water Well Standards in PA
Pennsylvania is one of the few states without private water well standards, making it hard to know what’s in people’s water and how long it’s been there. According to Penn State University’s 2009 Guide to Private Water Systems, nearly three million Pennsylvanians rely on private water wells.
The Center for Rural Pennsylvania released a study in 2009 of 701 private water wells in the state in order to better understand private well contamination. The study determined “[r]egulations are warranted to increase mandatory testing of private water wells at the completion of new well construction and before finalization of any real estate transaction.”
The study also states that 20,000 new residential water wells are drilled every year.
The natural gas industry has used its own baseline data of residential water supplies to determine that many contaminants are already found in groundwater of Pennsylvania, though they have not released this data, claiming the data could diminish property value (read ProPublica report).
Kathryn Klaber, President of Marcellus Shale Coalition, credits the industry with raising awareness about the “pre-existing conditions” of Pennsylvania’s groundwater. In an interview with Public Herald in September regarding concerns about natural gas extraction impacts to groundwater, Klaber referred to the lack of private water well regulations in the state.
Other industry advocates have consistently pointed to pre-existing problems in drinking water supplies from private wells, citing a long, accurate record of predrill tests by gas drilling companies.
When Predrill Tests Pay
Pennsylvania residents continue to see a pristine drinking water source become cloudy, dirty, bubbly, salty, and even corrosive immediately following drilling and hydraulic fracturing activities at nearby wells.
DEP does not list a total number of contamination cases from natural gas drilling on its website and did not respond to questions for this report. Public Herald is aware of at least 200 reports of water contamination since 2008 linked to drilling through pre- and postdrill water testing in the state’s north central region alone. (The DEP has not responded to phone calls or emails sent weekly for upward of 3 months. Public Herald has instead relied on file reviews and open record requests.)
Water at the home of Jim and Tammi Harkins in Potter County, Pa. turned brown two days after hydraulic fracturing of a Penn Virginia Corporation horizontal gas well on a neighbor’s property, about 800 feet from their water well. Penn Virginia and DEP used the Harkins’ predrill water test to determine cause and Penn Virginia paid for filtration systems on the Harkins’ water supply.
Penn Virginia’s predrill test did not include a test for methane, a main component of natural gas, or b-tex compounds (benzene, toluene, ethylbenzene, and xylene), a category of Volatile Organic Compounds that are found in natural gas. Benzene being a known carcinogen.
Neither the DEP or Penn State include b-tex compounds in their pre-drill testing recommendations for private water wells, but do list them in the tier 3 options. B-tex compounds are known sister chemicals to the migrating methane from a thermogenic source, such as Marcellus Shale.
ATSDR, a branch of the Center for Disease Control, which conducted post-blowout tests on Chesapeake’s failed Marcellus well, wrote the following about predrill tests in an email to Public Herald:
“Good, quality private well water samples collected using appropriate sampling methods provide the basis for making good public health recommendations. Although conclusions can be made using a single pre-drill sample, having available additional high-quality samples for a private well over time will lead to more robust conclusions about the quality of the groundwater in the well.”
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Pennsylvania Water Facts for Predrill Tests
ATSDR Pre- and Post-Blowout Test Results on RW04
This article concludes Public Herald’s investigation into natural gas drilling for 2011. We will continue only by the help of your leadership and support for 2012. Please consider becoming a Lifetime Member of PH to ensure we are online working for you in the coming year. You can do so by visiting our kickstarter project to become a backer, our membership page, or by mail to 2350 Cleveland Rd; Sandusky, OH 44870. We are a licensed nonprofit in the state of Pennsylvania. Thank you for helping to challenge the suppression of moral truths by way of investigative journalism. Joshua Pribanic, Editor-in-Chief