MSC Releases Recommended Practice for Pre-Drill Water
Today, 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.
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.
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
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.”
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.
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.”
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