Water Quality Impacts

Water Quality Impacts

Water Quality Impacts

Water quantity and quality have obvious importance for public health in terms of having
reliable sources of water for public and private drinking-water supplies at all times.
Surface waters provide additional indirect public health benefits related to fish resources
(both recreation and for food), recreational use (swimming and boating) and flood
control in the case of wetland areas. Maintaining adequate surface water quantity and
quality helps promote these health benefits. Under the federal Safe Drinking Water Act
(SDWA), the US Environmental Protection Agency (US EPA) established the public
water system supervision program. In New York State, the DOH has the primary
responsibility for implementing and enforcing the drinking water regulations of the
SDWA for all public water systems.19 This also includes oversight and implementation of
US EPA’s Surface Water Treatment Rule.
With the promulgation of the Surface Water Treatment Rule in the late 1980s, all
drinking water taken from surface water sources must be filtered to reduce the risk of
waterborne disease. However a waiver, or Filtration Avoidance Determination (FAD),
may be granted to a water supplier if it is able to demonstrate ongoing compliance with
strict water quality criteria and if it has a plan for the long-term control and management
of its watershed.

In New York State, both the City of Syracuse and the City of New York have been
issued a FAD. The FAD for the Syracuse public water supply system encompasses
Skaneateles Lake and its 59 square mile watershed and for New York City, the FAD
encompasses the Catskill and Delaware (Cat/Del) water supplies and its 1600 square
mile watershed in the Catskills.

While watershed management is important for any surface water supply, it is critical and
required for an unfiltered FAD system. Therefore, both the NYC Cat/Del and
Skaneateles Lake watersheds are unique natural and hydrological sources of
importance within the State. The importance of these resources is highlighted, in
particular, by the 1997 NYC Watershed Memorandum of Agreement (MOA). The MOA
is a landmark agreement that recognizes both the importance of preserving high-quality
drinking water and the economic health and vitality of communities located within the
watershed. It is a legally binding 145 page contract, with 1500 pages of attachments,
between NYC, the State, US EPA, nearly 80 local governments in the watershed and
environmental groups.
The literature investigating water-related impacts of HVHF activity is relatively extensive
compared to literature on other environmental impacts, although most studies do not
directly assess the potential for human exposure or public health impacts from water
contamination. Osborne et al. (2011) first highlighted the potential for sub-surface
methane migration from HVHF activity to affect drinking water wells in Pennsylvania,
and subsequent reports from the same group of researchers have continued to
investigate this potential source of groundwater contamination. The following
summarizes a few of the most recent water-quality investigations of HVHF that could be
most germane to understanding the potential for HVHF to contribute to human exposure
through drinking water.
Some recent publications have shed light on the potential for and causes of occasional
water pollution incidents around oil and gas wells (for example, see: Satterfield, 2011;
Sharma, 2014; Warner, 2014; Zhang, 2014). Darrah et al. (2014) identified groundwater
contamination clusters that they determined were due to gas leakage from intermediatedepth
strata through failures of annulus cement, faulty production casings, and

underground gas well failure. Vengosh et al. (2014) identified published data revealing
evidence for stray gas contamination, surface water impacts, and the accumulation of
radium isotopes in some disposal and spill sites. Some preliminary data suggest
inadequate HVHF wastewater treatment could contribute to formation of disinfection
byproducts in treated surface waters (e.g., Chang, 2001; Parker, 2014). These and
other reports indicate that there remain data gaps and uncertainties regarding the
effectiveness of some common mitigation measures related to both well construction
and wastewater management, at least as these have been implemented in other states.
An investigation was reported by Kassotis et al. (2014) using in vitro (i.e., cell culture)
assays to assess the estrogen- and androgen-receptor activity of HVHF chemical
additives and environmental water samples. Twelve chemicals were chosen that were
considered to be known or suspected endocrine-disrupting chemicals and were
chemical additives used in natural gas operations in Colorado.20 Groundwater and
surface water samples were collected in Garfield County Colorado from areas
considered “drilling dense” near locations where natural gas “incidents” had occurred.
Reference groundwater and surface samples were collected in areas of Garfield County
considered “drilling sparse” and from the nearby Colorado River and a non-drilling
reference location in Missouri. Assay results showed the twelve chosen chemicals
showed varying degrees of anti-estrogenic and anti-androgenic activity compared to
positive control activities (17β -estradiol and testosterone, respectively). Groundwater
and surface water samples concentrated 4-times or 40-times from their levels in the
environment had varying degrees of estrogenic, anti-estrogenic or anti-androgenic
activity in the test assays, generally with higher activities seen from samples collected
from the drilling dense sites, although differences from reference samples were not
always statistically significant.

Kassotis et al. concluded that, based on in vitro assay results of the selected chemicals
and water samples from drilling dense vs. reference locations, natural gas drilling
operations may result in elevated endocrine disrupting activity in groundwater and
surface water. There are a number of study limitations that suggest a strong conclusion
attributing the observed assay responses to natural gas drilling is questionable. For
instance, there were no chemical analyses presented of the drilling-dense water
samples that would allow an evaluation of whether the observed assay results were due
to drilling-related chemicals present in the water or to other unrelated chemicals that
could have been present from other sources. Similarly, drilling-dense samples and
reference samples were not always matched for other potentially influential factors
aside from drilling proximity such as the type (drinking water vs. monitoring) and depth
of groundwater wells, stream ecology or land use differences adjacent to sampling
locations.
Drilling-dense sampling sites were described by Kassotis et al. as being associated with
“natural gas incidents” including equipment leaks, spills or natural gas upwelling.
However, these incidents took place at varying times from several months to several
years prior to sampling and could have involved very different mixtures of materials
(such as bulk chemical additives during a spill or formation brine from an equipment
leak). The investigators did not provide details concerning the specific nature of any
water contamination that might have resulted from these incidents or what
environmental remedial activities may have taken place prior to collecting water
samples. This information would have been helpful in evaluating the likelihood that
water contamination from the incidents had occurred and persisted in the sampled
water sources. This information is especially important because the study report
provided no analyte concentration data for the study water samples. The proximity of
water sample collection locations to drilling activity alone does not conclusively indicate

that natural gas drilling operations result in endocrine disrupting activity in the water.
Even if further detailed research supported drilling-related contaminants as the source
of increased endocrine disrupting activity in the in vitro assays used in this study, the
relevance of the study methods to actual human exposure and human physiological
responses are unknown. Therefore, these results do not allow any assessment of the
potential risk to human health posed by such contamination.
A critical review of water resource issues associated with HVHF (Vengosh, 2014) noted
that treatment and disposal of HVHF solid waste and wastewater is a significant
challenge. Gas wells can bring naturally occurring radioactive materials (NORM) to the
surface in the cuttings, flowback water and production brine. NORM consists of uranium
and thorium and their decay products. Some of those decay products, namely radium
and radon, can be a public health concern if exposure occurs at sufficiently-high levels.
Rocks and soil contain NORM at various levels, and certain types of rock tend to have
higher concentration of NORM.
NORM in flowback and production brine can plate out and concentrate on internal
surfaces of pipes and tanks (scale). NORM in pipe scale contains predominantly
radium. This can cause an external radiation exposure risk to workers who work with
this equipment.