American petroleum institute best practices for groundwater quality and testing
Landowners can use the oil and gas industry’s existing best practices to protect their groundwater when negotiating an oil and gas lease.
The people of Michigan are very fortunate to have an abundance of clean water, both surface and groundwater. One of the controversies surrounding hydraulic fracturing (which is one step in the process of developing a deep natural gas well for production) is potential contamination of groundwater. When it comes to protecting groundwater, the American Petroleum Institute (API) has established industry best practices for setting baseline water quality and testing (API-HF1) when hydraulic fracturing will be used.
If a mineral rights owner is aware the industry has established its own best practices, adding water protection stipulations to the lease should not be as difficult. According to the API, water’s taste, smell or color is not necessarily an indicator of water quality. Many of the most hazardous contaminants are undetectable to the senses. The only way to detect most pollutants is by testing. It is extremely important to follow proper water sampling and analysis protocols in order to obtain valid results from sampling. The National Ground Water Association maintains a list of groundwater professionals you can review to help you find someone in your area to assist you. You may also contact your county health department for assistance or the Department of Environmental Quality Laboratory Services. Proper sampling and analysis protocols may include:
- Using appropriate containers and seals
- Purging of the well prior to sample capture
- Collection at points before water treatment equipment
- Following sample container filling procedures
- Following storage and holding time requirements
- Utilizing appropriate analysis methods
- Following appropriate quality control/ quality assurance protocols
If protection of the groundwater is a concern for you, it is important to have a pre-oil and gas operational sampling and analysis of the groundwater for constituents that may provide a reasonable baseline for post fracturing analysis.
According to the API, the following is a list of constituents that should be considered for analysis prior to oil and gas operations:
- Major cations and anions
- Specific Conductance
- Total Dissolved Solids
- Benzene, Toluene, Ethyl benzene, Xylene (BTEX)/ Diesel Range Organics (DRO)/ Gasoline Range Organics (GRO)
- Total Petroleum Hydrocarbons or Oil & Grease (HEM)
- Dissolved Methane
Once hydraulic fracturing has taken place and a record of the actual chemicals used is available, the API advises a sampling and analysis on the groundwater for the chemicals shown on the record that match those listed above. To minimize costs for the landowner, they state that an alternative analysis could be conducted for at least Total Dissolved Solids (TDS) and Dissolved Methane. An increase in the concentration of either of these constituents could indicate that further, more complete sampling and analysis should be conducted. Landowners may want to make water quality testing part of their lease agreement and make arrangements to share in the costs of these water quality tests.
It is extremely important to follow these protocols in case deterioration of water quality occurs. Failure to use these provides an open door for a litigator to reject the analysis out of hand.