Pre-Drill or Baseline Water Quality Testing for Oil and Gas Operations

Several states and other groups have recently put forward guidelines for sampling private water wells where oil and gas operations are occurring as public service information (e.g., Penn State Agricultural Extension; Oklahoma State Agricultural Extension; NGWA/GWPC; Louisiana Department of Health and Hospitals). Several states have recently promulgated regulations that address pre-drill sampling of drinking water supplies/wells (CO, OH, ND, PA, WV, WY, IL). While these are steps in the right direction, there continues to be variation in what is covered under these rules and guides as well as gaps. While leading the field technical portion of the USEPA Hydraulic Fracturing Study in 2010 and 2011, the single most glaring deficiency in all state programs for oil and gas operations was the absence of any rules or guides for baseline water sampling. When complaints were lodged with state agencies, there was almost never any pre-drill data to compare to post-drill suspected impacts. The best available data was typically historical regional water quality collected by the USGS, some of which could be decades old. Because of the natural variability of subsurface systems, this data was usually insufficient to allow for comparisons between pre- and post-drill water quality data. This presentation will provide an overview of state rules on this topic and emphasize the importance of proper sampling methods.