BASELINE WATER QUALITY PROGRAMS FOR OIL & GAS OPERATIONS - WHAT'S NEXT?

Several states in the U.S. have recently made baseline water quality testing of domestic wells mandatory in their oil and gas regulations and guidance (CO, WY, IL, OH). Other groups have also put forward guidelines for sampling private water wells where oil and gas operations are occurring as pubic service information (e.g. Penn State Agricultural Extension; Oklahoma State Agricultural Extension; NGWA/GWPC; Louisiana Department of Health and Hospitals). While these are steps in the right direction, there continues to be many states that have not adopted this approach. While leading the field technical portion of the USEPA Hydraulic Fracturing Study in 2010 and 2011, the single most glaring deficiency I encountered 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, and the states and operators often dismissed such comparisons due to aquifer heterogeneity and spatial and temporal variability. Baseline water quality programs are needed for all locations where oil and gas production is carried out. It is essential to have a baseline monitoring program that requires a specific ground water sampling protocol that is clearly documented and carried out by trained personnel. Over the years, EPA and the USGS have discovered this and therefore have established very specific and documented protocols. Historically much emphasis has been placed on Quality Assurance programs for the analysis of samples; however, we need to require the same level of Quality Assurance for the sampling methods we use. As more and more states implement baseline programs, we see substantial variability in the requirements imposed. Are these variations based on sound science and is sampling of nearby water sources sufficient for the establishment of a scientifically defensible baseline water quality program for oil and gas operations?