In the grand scheme, if drilling occurs in your area or nearby, or if a drill pad is located adjacent to your subdivision or property, then your water well, your aquifer, or your surface water could be potentially impacted. Your goal is to ensure that your water is safe to drink now and in the future. Its only good business to protect ones self from catastrophes should they occur.
What protections do I have from the State in regards to my water quality?
The answer below is provided from the Colorado Oil and Gas Conservation Commission website FAQ Page.
“With respect to water quality the COGCC coordinates its monitoring and enforcement with the CDPHE Water Quality Control Commission (WQCC) which sets water quality standards and classifications statewide. The COGCC is responsible (and accountable to the CDPHE-WQCC) for implementing those standards and classifications with respect to ground water. The COGCC requires that operators design and construct wells and facilities to protect ground water from contamination during oil and gas operations. If oil and gas operations entail discharges to surface waters the operator must obtain a permit prior to discharging from the CDPHE-WQCC. As an additional safeguard, the COGCC has several rules aimed at preventing unpermitted discharges to surface waters.”
The following COGCC regulations address concerns raised about hydraulic fracturing:
- Rule 205 requires operators to inventory chemicals, including fracturing fluids,and to provide this information upon request to the COGCC and certain healthcare professionals.
- Rule 205A became effective April 1, 2012. The Rule requires disclosures to FracFocus within 60 days of the conclusion of a hydraulic fracturing treatment, and in no case more than 120 days following the commencement of a hydraulic fracturing treatment.
- Rule 317 requires cement bond logs to confirm that aquifers are protected;
- Rule 317B imposes mandatory setbacks and enhanced environmental precautions on oil and gas development occurring near public drinking watersources;
- Rule 341 requires well pressures to be monitored during hydraulic fracturing;
- Rule 608 mandates additional pressure testing and water well sampling for coalbed methane wells; and
- Rules 903 , 904 , and 906 impose enhanced requirements for pit permitting,lining, monitoring, and secondary containment to ensure that pit fluids, including hydraulic fracturing flowback, do not leak.
We did spend some time going through the rules looking for the specifics on water testing and unfortunately did not find clearly written requirements as to the number and areal extent of the numbers of wells and the locations around the drilling location in which baseline testing must occur before drilling can begin. However we did find what types of chemical testing is required in the event of spills or complaints and will reference those technical specifics below.
With the lack of specific documentation that tells us how state requires where, when, and how many baseline samples must be collected before a drilling program can commence, one can only surmise that it is left up to the oil company to determine the scope and integrity of their water baseline study. One would logically assume it would be of the minimum extent to protect against their liabilities should an accident occur, be it a surface spill or a failed well casing, to contaminate ground and/or surface waters.
NEW: As of October 16, 2012, the COGCC has begun a series of hearings to create Statewide Water Sampling and Monitoring Rules that will address water quality issues and concerns. Please visit the COGCC site to learn more about these hearings and how you can pariticpate.
It would seem that the burden of monitoring the quality of your ground water is up to the individual. What should you do to monitor the effects on your water aquifers?
This answer is actually pretty easy, although its implementation, is somewhat tedious, and probably involves some cost. In order to protect the quality of your water, especially that derived from water wells, from both subsurface and surface contamination, it is necessary to perform a baseline water quality sampling study BEFORE any drilling starts. It would be highly recommended for this study to be completed prior to any drilling activity in your immediate area.
How should the sampling be conducted?
Since the results of the sampling survey are protective in nature, and the results could potentially be used in court IF a suspected contamination problem occurred, then it is only reasonable to conclude that a study would have to be conducted in such a manner so as to be defensible as un-biased. This is typically done by a third party that can perform the proper chain of custody protocols for collecting the water samples. In fact, we suggest that you DO NOT do this on your own for your own protection. For the few dollars it takes to hire a professional, it only makes sense to have this done correctly so as the results can stand up in a court of law. Remember, this is your insurance in case of the extremely unlikely event that your water becomes contaminated. However, lets face it, if well water is your only source of water, this is your most important resource. We would advise against skimping on your water sampling efforts to save a buck or two. What is at stake is your largest asset, your property value.
Some of the things an Environmental consultant can do:
- Compile your water rights records
- Assess your water well for depth based on state records
- Pump your well to totally clear the hydrostatic water column (i.e. empty the standing water)
- Take a fresh sample from the recharge water from your aquifer
- Follow the proper State chain of custody protocols in collection and delivery to laboratories to ensure that the water sample is properly handled and logged so that the tests that will be conducted will be considered valid.
We cannot stress strongly enough that THIS step is crucial in obtaining a good, valid, and defensible sample that can be used in court of law should you suspect your water becoming contaminated as a result of oil drilling. Protocols must be observed, or you have nothing.
Assuming you have hired an Environmental Consultant or similar third party firm to conduct your water sampling, they will have a suggested suite of extensive tests they will conduct to test for either fracking fluid contamination, and/or contamination of your aquifer from the fluids/gas present in the oil bearing formation as a result of oil drilling. Please remember, if you have a suspected problem you will need to “prove” that oil drilling is the reason for your contamination, so the testing should focus on any signs that oil drilling caused your problem, be it fracking fluid constituents, or migratory components from the oil producing formation. That’s what you want, irrefutable evidence. The following is a list of chemical constituents required by the COGCC to be tested for in the event there is a filed complaint with merit.
**** DISCLAIMER INFORMATION BELOW TO BE USED FOR EDUCATIONAL **** **** PURPOSES ONLY! ****
The chemicals listed below are suggested by the COGCC for testing after a spill or accident, however it not suggested that this is a comprehensive suite of tests to ensure your the quality of your well water nor are they suggested to be the only chemical testing necessary to ensure your protection in the event your water supply is compromised and you feel the need to litigate.
We highly recommend you hire a qualified professional to determine when and what, to test your well water for to ensure the integrity of the test program and its intended use(s).
- Methane – First of all, the main culprit identified in many contaminated wells is methane, your consultant will test for methane and measure your baseline before oil drilling. Methane comes out of solution in the water and is the one of the most migratory constituents associated with oil and gas drilling. Believe it or not, your well may indeed contain some naturally occurring methane gas. This gas is biogenic and occurs naturally from coal or other near surface organic deposits in your aquifer as a result of microbial activity. If this gas occurs naturally it will be logged in your water baseline. If by chance your aquifer is contaminated by drilling then your could see methane gas, but it will be thermogenic in origin as a result of the thermal maturation of organic material. Biogenic gas is very dry (i.e., it consists almost entirely of methane). In contrast, thermogenic gas can be dry, or can contain significant concentrations of “wet gas” components (ethane, propane, butanes) and condensate (C5+ hydrocarbons) Bottom Line, it is possible to analyze methane for thermogenic or biogenic origins, (i.e. source of contamination) Thermogenic gas components (methane, ethane, propane) generated at a given thermal maturity contain, on average, isotopically heavier carbon than do the corresponding gas components generated at a lower thermal maturity. Relationships between gas isotopic compositions and source maturity have been calibrated, allowing the vitrinite reflectance equivalent (VRe) of the gas source to be estimated from the gas geochemistry (Faber, 1987; Berner and Faber, 1988; Berner, 1989)
BTEX -Benzene, Toluene, Ethyl Benzene and Xylene Benzene, Toluene, Ethyl Benzene and Xylene (BTEX) are the volatile components commonly associated with petroleum products. Organic compounds can be a major pollution problem in groundwater. Their presence in water can create a hazard to public health and the environment. One of the most common sources for BTEX-contamination of soil and groundwater are spills commonly involves the release of petroleum products such as gasoline, diesel fuel and lubricating and heating oil from leaking oil tanks. Diesel fuel has also been commonly used as a slickening agent in the hydrofracking during horizontal drilling, so anytime there is a leak from an oil well either in the subsurface or at the surface, diesel fuel and other fracking fluid constituents may be accidentally released.
- Salinity – All natural drinking water – or “sweet water” aquifers have low levels of salinity, meaning not saline. Since the formations containing oil consist of thermally mature rock that was once part of ancient oceans, these formations have naturally occurring brine water within the pore spaces of the rock grains. When drilled, these formations can typically produce “formation water” which is laced with ocean salts such as sodium chloride, magnesium chloride, calcium chloride and other common seawater salts. If your aquifer were to be contaminated as a result of drilling, it would be expected to see your salinity levels rise above baseline as a result of “formation water contamination”.
- pH – In chemistry, pH is a measure of the acidity or basicity of an aqueous solution. Pure water is said to be neutral, with a pH close to 7.0 at 25 °C (77 °F). Solutions with a pH less than 7 are said to be acidic and solutions with a pH greater than 7 are basic or alkaline. The pH of ground water controls which cations, anions, gases and solids dissolve into ground water (i.e., go into solution) and which exit from groundwater (i.e., precipitate or volatilize).
- Alkalinity – “Alkalinity is the acid neutralizing capacity of solutes in a water sample, reported in milliequivalents per liter. Alkalinity consists of the sum of titratable carbonate and noncarbonate chemical species in a filtered water sample.” – Rounds, 2006
- Specific conductance – Specific Conductance (SC) is a measure of how well water can conduct an electrical current. Conductivity increases with increasing amount and mobility of ions. These ions, which come from the breakdown of compounds, conduct electricity because they are negatively or positively charged when dissolved in water. Therefore, SC is an indirect measure of the presence of dissolved solids such as chloride, nitrate, sulfate, phosphate, sodium, magnesium, calcium, and iron, and can be used as an indicator of water pollution. Note: contamination indicated by these salts can originate with soil fertilization operations due to farming. These chemicals may also be indicative of contamination from saline formation water from oil bearing formations containing brine.
- Major cations/anions (chloride, fluoride, sulfate, sodium); The most common constituents dissloved in oil and gas brines are the major cations sodium, calicium, magnesium, potassium and the major cations chloride, sulfate and bicarbonate. Testing for these constituents helps establish if there is any contamination from an oil bearing brine formation.
- Total dissolved solids -Dissolved solids” refer to any minerals, salts, metals, cations or anions dissolved in water. This includes anything present in water other than the pure water (H20) molecule and suspended solids. In general, the total dissolved solids concentration is the sum of the cations (positively charged) and anions (negatively charged) ions in the water. Parts per Million (ppm) is the weight-to-weight ratio of any ion to water. The EPA Secondary Regulations advise a maximum contamination level (MCL) of 500mg/liter (500 parts per million (ppm)) for TDS. Numerous water supplies exceed this level. When TDS levels exceed 1000mg/L it is generally considered unfit for human consumption.
- GRO/DRO – Diesel Range Organics/Gasoline Range Organics. Occasionally some horizontal wells will be fracked with diesel fuel that is used as a slickening agent to make the crude oil flow more easily from the formation. Detection of this component in groundwater could provide evidence of contamination from fracking fluids.
- TPH – Total Petroleum Hydrocarbons. (TPH) is a term used for any mixture of hydrocarbons that are found in crude oil. There are several hundred of these compounds, but not all occur in any one sample. Crude oil is used to make petroleum products which can contaminate the environment. Because there are so many different chemicals in crude oil and in other petroleum products, it is not practical to measure each one separately. However, it is useful to measure the total amount of TPH at a site. Chemicals that occur in TPH include hexane, benzene, toluene, xylenes, naphthalene, and fluorene, other constituents of gasoline, of jet fuels, of mineral oils, and of other petroleum products
- PAH’s (including benzo(a)pyrene) Polycyclic aromatic hydrocarbons (PAHs), also known as poly-aromatic hydrocarbons or polynuclear aromatic hydrocarbons, are potent atmospheric pollutants that consist of fused aromaticrings and do not contain heteroatoms or carry substituents.Naphthalene is the simplest example of a PAH. PAHs occur in oil, coal, and tar deposits, and are produced as byproducts of fuel burning (whether fossil fuel or biomass). As a pollutant, they are of concern because some compounds have been identified as carcinogenic, mutagenic, and teratogenic. PAHs are also found in cooked foods. Studies have shown that high levels of PAHs are found, for example, in meat cooked at high temperatures such as grilling or barbecuing, and in smoked fish.
- Metals (arsenic, barium, calcium, chromium, iron, magnesium, selenium). Testing for these metals may be indicate contamination between the oil bearing shale formation and surface water acquifers if a the ratio of heavy elements can be found to be similar to that found in a contaminated acquifer where these metals did not exist before.The heavy metals source of origin comes during the depostion of shale. Some shales and especially ‘Black shales’ are dark, as a result of being especially rich in unoxidizedcarbon. Common in some Paleozoic and Mesozoicstrata, black shales were deposited in anoxic, reducing environments, such as in stagnant water columns. Some black shales contain abundant heavy metals such as molybdenum, uranium, vanadium, and zinc. The enriched values are of controversial origin, having been alternatively attributed to input from hydrothermal fluids during or after sedimentation or to slow accumulation from sea water over long periods of sedimentation.
All the chemical tests listed above together constitute a comprehensive analysis with each test validating the other to determine IF a well water contamination event is indeed the result of oil drilling and fracking. One test for a specific chemical is in itself not diagnostic of a contamination source. This activity should be approached with good science, as facts will win the day. Again, it is highly suggested that a professional be used to BASELINE your water well BEFORE drilling operations begin.