Wyoming has begun a 45-day comment period on a proposed water well testing requirement before oil and gas activity begins nearby that could set the pattern for other producing states.
"It requires testing of water wells within a half mile radius of any proposed oil and gas well," explained Grant Black, supervisor of Wyoming's Oil & Gas Conservation Commission.
Operators would be required to submit a groundwater baseline sampling and monitoring plan with each drilling permit application for any oil and gas, dedicated injection, or monitoring well. Subsequent sampling and testing also would be required once the well was completed.
Initial sampling and testing would take place within a 12-month period before the first oil or gas well on a drilling pad was completed. Subsequent sampling and testing would be conducted 12-24 months after setting the production casing or liner. A second subsequent sampling would occur at least 2 years after the first.
The operator of an oil or gas well would notify OGCC's supervisor and the director of the state's Department of Environmental Quality if test results indicate thermogenic gas (or a mixture of thermogenic and biogenic gas); the methane concentration increases by more than 5 mg/l. between sampling periods; the detected methane concentration is at or above 10 mg/l.; or BTEX (benzene, toluene, ethylbenzene, and xylenes) compounds or TPH is detected in the water sample.
Wyoming Gov. Matt Mead (R) made this part of his energy initiative, Black told OGJ on July 19. "Many people recognize it's important to take a scientific approach to protecting groundwater," Black said, adding, "This is intended to be an information baseline so if something is detected once drilling is completed, the operator has scientific data to refer to."
Confidentiality issue
Pennsylvania and Colorado have similar rules, Black said. "Test results confidentiality was an issue. We decided to make all results transparent and available to the public," he said.
Two environmental groups applauded the proposed rules. "On the whole, this rule establishes a solid, scientifically valid framework for groundwater quality testing," said Jay Goldstein, senior energy policy manager at the Environmental Defense Fund.
Meanwhile, Amber Wilson, the Wyoming Outdoor Council's environmental quality coordinator, said, "It establishes a foundation that can be added to over time. This rule will go a long way toward providing the public with important information about the quality of the water resources we all share."
EDF plans to remain involved in the discussions, "especially on the newly introduced concept of 'master plans,'" said Goldstein. "We need to ensure these plans are not a way for each operator to invent their own sampling plans out of whole cloth" but establish and monitor well-by-well groundwater quality, Goldstein said.
