PRE-DRILL WATER PRE-DRILL WATER SOURCE SAMPLINGSOURCE SAMPLING

Moody and Associates, Moody and Associates, Inc.Inc.

Image taken Ohio Department of Natural Resources Geologic Survey

Image taken Ohio Department of Natural Resources Geologic Survey

Vertical Vs Horizontal Drilling

Vertical well exposed to about 50 ft of formation

Horizontal well can extend laterally through 2,000-6,000 ft of formation

Numerous vertical wells needed in an area to equal production of one horizontal wellSource: Penn State University

Advantages of Horizontal Drilling

Greater wellbore exposure

Smaller surface “footprint”

Access to resources under existing infrastructure, buildings or environmentally sensitive areas (wetlands).

Source: Geology.com

Purposes of Frac Fluid Purposes of Frac Fluid AdditivesAdditives

Friction ReducersFriction Reducers – Allows the hydraulic fracturing fluid to flow into and out of the production casing and tubing easily. – Allows the hydraulic fracturing fluid to flow into and out of the production casing and tubing easily.

   Scale InhibitorsScale Inhibitors – Formation brine creates scales on tubular steel products. Scale inhibitors prevent mineral scale on the interior surfaces of frac pipe, production tubing and well casing. – Formation brine creates scales on tubular steel products. Scale inhibitors prevent mineral scale on the interior surfaces of frac pipe, production tubing and well casing.

SurfactantsSurfactants – Keeps solid particles suspended in liquids. Surfactants can be thought of as soap. They reduce surface tension in liquids and bind polar molecules in water. Surfactants are used to increase recovery of flow back fluids. – Keeps solid particles suspended in liquids. Surfactants can be thought of as soap. They reduce surface tension in liquids and bind polar molecules in water. Surfactants are used to increase recovery of flow back fluids.

BiocidesBiocides – Inhibits or prevents the growth of bacterial, algae, fungi and other microscopic organisms. Bacteria can consume hydrocarbons or can form a slime or black residue in a gas well that can plug or damage the formation. – Inhibits or prevents the growth of bacterial, algae, fungi and other microscopic organisms. Bacteria can consume hydrocarbons or can form a slime or black residue in a gas well that can plug or damage the formation.

ProppantsProppants – Typically inert material such as sand or ceramic beads used to hold fractures open against formation pressure. – Typically inert material such as sand or ceramic beads used to hold fractures open against formation pressure.

Typical additives Typical additives for hydraulic for hydraulic fracturing fluid.fracturing fluid.

Note that there is Note that there is no such thing as a no such thing as a “bottle” of frac “bottle” of frac fluid. The fluid. The ingredients are ingredients are mixed on the well mixed on the well pad and injected pad and injected into the stream.into the stream.

To do well in the oil and gas industry, you To do well in the oil and gas industry, you must understand the regulations of the must understand the regulations of the

state that you are working in. Today I will state that you are working in. Today I will briefly touch on the regulations of:briefly touch on the regulations of:

PennsylvaniaPennsylvaniaNew YorkNew York

PennsylvaniaPennsylvaniaLegislative AuthorityLegislative Authority

Oil & Gas Act of December 19, 1984 (updated Oil & Gas Act of December 19, 1984 (updated February 2012 with the passage of HB 1950, andFebruary 2012 with the passage of HB 1950, and subsequent signing into law by the PA Governor as subsequent signing into law by the PA Governor as Act 13)Act 13)

Act 13 presumes that an unconventional well operator is Act 13 presumes that an unconventional well operator is responsible for the pollution of a water supply that is located responsible for the pollution of a water supply that is located within 2500 feet of the oil or gas well, where the pollution within 2500 feet of the oil or gas well, where the pollution occurred within 12 months after the completion or alteration occurred within 12 months after the completion or alteration of the unconventional well.of the unconventional well.

Unless -Unless -

(1)(1) The pollution existed prior to the drilling or alteration activity as determined by The pollution existed prior to the drilling or alteration activity as determined by aa predrilling survey. predrilling survey.

(2) The landowner or water purveyor refused to allow the operator access to conduct a predrilling or prealteration survey.

(3) The water supply is not within 2,500 feet of the well.

(4) The pollution occurred more than 12 months after completion of the drilling or alteration activities.

(5) The pollution occurred as the result of some cause other than the drilling or alteration activity.

Any operator electing to preserve its defense under items (1) or (2) above shall retain the services of an independent certified laboratory to conduct the predrilling or prealteration survey of water supplies. A copy of the results of any such survey shall be submitted to the PADEP and the landowner in a manner prescribed by the PADEP.

PADEP REGULATIONSPADEP REGULATIONS

Current regulations adopted by the PADEP were promulgated Current regulations adopted by the PADEP were promulgated from the Oil & Gas Act of 1984 and have yet to be updated to from the Oil & Gas Act of 1984 and have yet to be updated to reflect the provisions of Act 13.reflect the provisions of Act 13.

Pennsylvania Code Title 25 – Environmental ProtectionPennsylvania Code Title 25 – Environmental Protection

Chapter 78 – Oil and Gas WellsChapter 78 – Oil and Gas Wells

Commonly referred to as “Chapter 78”.Commonly referred to as “Chapter 78”.

CHAPTER 78 cont’dCHAPTER 78 cont’d §§ 78.52 Predrilling or prealteration survey

A well operator who wishes to preserve its defense under section 208(d)(1) that the A well operator who wishes to preserve its defense under section 208(d)(1) that the

pollution of a water supply existed prior to the drilling or alteration of the well shall pollution of a water supply existed prior to the drilling or alteration of the well shall

conduct a predrilling or prealteration survey in accordance with this section.conduct a predrilling or prealteration survey in accordance with this section.

The survey shall be conducted by an independent certified laboratory. A person The survey shall be conducted by an independent certified laboratory. A person

independent of the well owner or well operator, other than an employee of the certified independent of the well owner or well operator, other than an employee of the certified

laboratory, may collect the sample and document the condition of the water supply, if the laboratory, may collect the sample and document the condition of the water supply, if the

certified laboratory affirms that the sampling and documentation is performed in certified laboratory affirms that the sampling and documentation is performed in

accordance with the laboratory’s approved sample collection, preservation and handling accordance with the laboratory’s approved sample collection, preservation and handling

procedure and chain of custody. procedure and chain of custody.

An operator electing to preserve its defenses under section 208(d)(1) of the act shall An operator electing to preserve its defenses under section 208(d)(1) of the act shall

provide a copy of the results to the PADEP and the landowner within 10 business days of provide a copy of the results to the PADEP and the landowner within 10 business days of

receipt of the results.receipt of the results.

CHAIN of CUSTODY WATER TESTINGCHAIN of CUSTODY WATER TESTING

Water tests done to document pre or post drilling water quality should be Water tests done to document pre or post drilling water quality should be

collected by professionals and delivered to a PA accredited laboratory. collected by professionals and delivered to a PA accredited laboratory.

This type of sampling is referred to as “chain of custody” or “third party” This type of sampling is referred to as “chain of custody” or “third party”

water testing.water testing.

This assures that individuals who handle the sample are documented on the This assures that individuals who handle the sample are documented on the

COC and that only unbiased professionals, using proper sampling COC and that only unbiased professionals, using proper sampling

protocols, have access to the samples.protocols, have access to the samples.

A complete list of water testing laboratories that are accredited by the A complete list of water testing laboratories that are accredited by the

PADEP can be found on the PADEP website.PADEP can be found on the PADEP website.

WHAT IS NOT INCLUDED IN EITHERTHE OIL & GAS ACT OR CHAPTER 78

Post-drill Sampling Post-drill sampling is neither specified nor required in the Act or

Chapter 78. Post-drill sampling is generally performed by the gas operator

following a complaint by the landowner.

Analyte Lists Prior to Marcellus drilling, operators generally created an analyte list that were

either indicators of gas well drilling or the “recipe” of the operator. PADEP recommended predrill list Marcellus Shale Coalition recommended predrill list

PADEP RECOMMENDED OIL & GAS PRE-DRILL PARAMETERS

Alkalinity Chloride Conductivity Hardness Oil & grease pH Sulfate TDS TSS Total coliform & E.coli

Barium Calcium Iron Magnesium Manganese Potassium Sodium Strontium Methane Ethane

If a homeowner elects to sample for less than the recommended list, PADEP says that pH, TDS, iron, manganese, sodium, methane and ethane should be sampled for.

PADEP recommends that the sampling be conducted within one year prior to the start of gas well drilling.

PADEP recommends that a third party (laboratory or consultant) collect and transport the sample for testing.

MARCELLUS SHALE COALITION PRE-DRILL CONSTITUENTS

Alkalinity Oil & grease pH Specific conductance TDS TSS Sulfate Hardness MBAS Nitrate as N Turbidity Propane Ethylene Glycol Methane Ethane BTEX

Arsenic Barium Cadmium Calcium Chromium Lead Iron Magnesium Manganese Mercury Potassium Selenium Silver Sodium Total coliform/E.coli/fecal coliform

ISSUES

No standardized analytical method for methane. The different methods with widely varying detection limits used by laboratories accounts for the wide range of the number of wells with reported methane during pre-drill sampling.

No specific analyte list as a regulatory standard.

Chapter 78 does not stipulate the time of sample collection.

Chapter 78 does not define “predrill”.

NEW YORKNEW YORKLEGISLATIVE AUTHORITYLEGISLATIVE AUTHORITY

There is a moratorium on development of the Marcellus Shale in NYS.There is a moratorium on development of the Marcellus Shale in NYS.

Currently, there is no legislative or regulatory framework in NYS that Currently, there is no legislative or regulatory framework in NYS that guides pre-drill or pre-alteration water sampling for conventional gas well guides pre-drill or pre-alteration water sampling for conventional gas well drilling.drilling.

The only guidance for pre-drill sampling issued to date is the draft The only guidance for pre-drill sampling issued to date is the draft Supplemental Generic Environmental Impact Statement (“dSGEIS”).Supplemental Generic Environmental Impact Statement (“dSGEIS”). The dSGEIS only applies to the Marcellus Shale and other unconventional gas The dSGEIS only applies to the Marcellus Shale and other unconventional gas

well drilling that uses high volume hydraulic fracturing.well drilling that uses high volume hydraulic fracturing.

dSGEISdSGEIS

The final Generic Environmental Impact Statement was The final Generic Environmental Impact Statement was released by the NYSDEC in 1992. There were no provisions released by the NYSDEC in 1992. There were no provisions for pre-drill water source sampling.for pre-drill water source sampling.

In response to the high volume hydraulic fracturing proposed In response to the high volume hydraulic fracturing proposed for the Marcellus Shale that was distinct from the other types for the Marcellus Shale that was distinct from the other types of well completions allowed in NYS under the 1992 GEIS, the of well completions allowed in NYS under the 1992 GEIS, the dSGEIS was issued in 2009 for public comment.dSGEIS was issued in 2009 for public comment.

The NYSDEC incorporated public comments into the dSGEIS The NYSDEC incorporated public comments into the dSGEIS and released the final draft SGEIS on July 1, 2011. and released the final draft SGEIS on July 1, 2011. 

dSGEIS cont’d

Another formal public comment period was completed in the Fall/Winter of 2011/2012.

Following the finalization of the SGEIS, the NYSDEC will begin processing high volume hydraulic fracturing drilling permits, and where appropriate, issue well permits in accordance to the GEIS and SGEIS.

In 2010, Governor Patterson issued an executive order stating that no permits would be issued for high volume hydraulic fracturing until the SGEIS is finalized.

PROPOSED SGEIS WATER WELL SAMPLINGPROPOSED SGEIS WATER WELL SAMPLING

Private water wells within 1000 feet of the well pad, subject to the property Private water wells within 1000 feet of the well pad, subject to the property

owner’s permission, are to be pre-drill sampled.owner’s permission, are to be pre-drill sampled.

If no water wells are available within 1000 feet of the well pad (due to lack of If no water wells are available within 1000 feet of the well pad (due to lack of

sources or lack of landowner permission), the sampling radius moves to within sources or lack of landowner permission), the sampling radius moves to within

2000 feet of the well pad.2000 feet of the well pad.

PROPOSED SGEIS WATER WELL SAMPLINGPROPOSED SGEIS WATER WELL SAMPLING

The results of each test must be provided to the property owner within 30 days of The results of each test must be provided to the property owner within 30 days of

receipt of the analytical results by the operator.receipt of the analytical results by the operator.

The data shall be available to the NYSDEC and local health department upon The data shall be available to the NYSDEC and local health department upon

request for complaint investigation purposes.request for complaint investigation purposes.

PROPOSED SGEIS WATER WELL SAMPLINGPROPOSED SGEIS WATER WELL SAMPLING

Initial sampling is to occur prior to site disturbance at the first Initial sampling is to occur prior to site disturbance at the first well on the pad, and prior to drilling commencement at well on the pad, and prior to drilling commencement at additional wells on multi-well pads. additional wells on multi-well pads.

Sampling is to occur three months after reaching total Sampling is to occur three months after reaching total measured depth (“TMD”) at any well on the pad if there is a measured depth (“TMD”) at any well on the pad if there is a hiatus of longer than three months between reaching TMD and hiatus of longer than three months between reaching TMD and any other milestone on the well pad that would require any other milestone on the well pad that would require sampling.sampling.

Sampling is to occur three, six and 12 months after hydraulic Sampling is to occur three, six and 12 months after hydraulic fracturing operations of each well on the pad.fracturing operations of each well on the pad.

dSGEIS PROPOSED WATER SOURCE dSGEIS PROPOSED WATER SOURCE SAMPLING SCHEDULING cont’dSAMPLING SCHEDULING cont’d

For multi-well pads where drilling and hydraulic fracturing activity is For multi-well pads where drilling and hydraulic fracturing activity is continuous, to the extent that water source sampling according to the continuous, to the extent that water source sampling according to the schedule laid out in the previous slide would result in sampling to occur schedule laid out in the previous slide would result in sampling to occur more often than three every months, the NYSDEC proposes that:more often than three every months, the NYSDEC proposes that:

Sampling would occur at three month intervals until six months after Sampling would occur at three month intervals until six months after the last well on the pad is hydraulically fractured.the last well on the pad is hydraulically fractured.

Final round of sampling 12 months after the last well on the pad is Final round of sampling 12 months after the last well on the pad is hydraulically fractured.hydraulically fractured.

More frequent sampling, or sampling beyond 12 months after the More frequent sampling, or sampling beyond 12 months after the conclusion of hydraulic fracture activities may be warranted in response to conclusion of hydraulic fracture activities may be warranted in response to landowner complaints or landowner complaints or for other reasonable cause.for other reasonable cause.

PROPOSED SGEIS WATER WELL SAMPLING PROPOSED SGEIS WATER WELL SAMPLING PARAMETERSPARAMETERS

Barium (or other drilling mud component)Barium (or other drilling mud component)

ChlorideChloride

ConductivityConductivity

Gross alpha/betaGross alpha/beta

IronIron

ManganeseManganese

Dissolved methane/ethaneDissolved methane/ethane

pHpH

SodiumSodium

TDSTDS

SWLSWL

VOCs (specifically BTEX)VOCs (specifically BTEX)

NYSDOH recommends that the following parameters be tested for to aid with NYSDOH recommends that the following parameters be tested for to aid with

determining whether gas drilling may have had an impact on the quality or quantity of determining whether gas drilling may have had an impact on the quality or quantity of

a well:a well:

In the event that a potential impact is determined, additional In the event that a potential impact is determined, additional investigation, such as isotopic analysis of methane or site-investigation, such as isotopic analysis of methane or site-specific chemical analysis, may be necessary.specific chemical analysis, may be necessary.

Water samples shall be collected by a “qualified professional”.Water samples shall be collected by a “qualified professional”.

ISSUES

No standardized analytical method for methane. The different methods with widely varying detection limits used by laboratories accounts for the wide range of the number of wells with reported methane during pre-drill sampling in Pennsylvania.

The SGEIS refers to testing of private water wells, and does not discuss springs, ponds or other surface water bodies that could be sources of drinking water or other legitimate beneficial use.

In fact, the NYSDOH discourages the use of springs as drinking water sources and suggests that they should only be used as a last resort with proper protective measures.

QUALITY ASSURANCEQUALITY ASSURANCE

Oil & gas operators are looking Oil & gas operators are looking for analytical data that is for analytical data that is scientifically and legally scientifically and legally

defensible.defensible.

Quality Assurance begins with the standard operating procedure for field sampling.

Where are you going to collect the sample from? How will you determine an appropriate purge volume and purge rate (is the water

representative of the aquifer)? What field parameters should you measure? Do you have a calibration and calibration documentation program? What information should you collect from the property owner during the field

interview? Are sample custody, preservation and method hold time requirements being met?Are sample custody, preservation and method hold time requirements being met?

Document field activities – document, document, document! Especially when a Document field activities – document, document, document! Especially when a

deviation of the SOP is used (why?) or when an issue is identified at the time of deviation of the SOP is used (why?) or when an issue is identified at the time of

sampling that could be an existing source of contamination of the well.sampling that could be an existing source of contamination of the well.

Possible components of a Quality Control ProgramPossible components of a Quality Control Program

Trips blanks for every sample cooler that contains VOC Trips blanks for every sample cooler that contains VOC samples.samples.

Blind duplicate sampling – 1 in every “x” samples Blind duplicate sampling – 1 in every “x” samples collected.collected.

Duplicate sample sent to another lab – 1 in every “x” Duplicate sample sent to another lab – 1 in every “x” samples collected.samples collected.

MS/MSD sampling – 1 in every “x” samples collected.MS/MSD sampling – 1 in every “x” samples collected. Field blanksField blanks Equipment blanksEquipment blanks

Quality Assurance continues in the laboratory.

Laboratory reports should include both MDLs and MRLsLaboratory reports should include both MDLs and MRLs Are the conditions of the QAPP being followed?Are the conditions of the QAPP being followed? Can your laboratory provide full data validation?Can your laboratory provide full data validation?

QUESTIONS?QUESTIONS?

Timothy M. Eriksen, P.G.

Moody and Associates, Inc.

685 Broad Street Extension

Suite 1

Waverly, NY 14892

(607) 565-8800

teriksen@moody-s.com