## Final Report Water Qua lity Literature Review and Field Monit oring of Active Shale Gas Wells Phase I
For “Assessing Environmental Impacts of Horizontal Gas Well Drilling Operations”

Prepared for: West Virginia Department of Environmental Protection Division of Air Quality 601 57 th 

### Street, SE Charleston, WV 25304

Prepared by: Paul Ziemkiewicz, Ph.D ., Director Jennifer Hause , M.S

.

Brady Gutta, B.S. Jason Fillhart , M.S

. , M.Ed. Ben Mack M.S

. Melissa O’Neal , B.S.

West Virginia Water Research Institute West Virginia University PO Box 6064 Morgantown, WV 26506

- 6064

Date: February 15 , 2013i | Page 

## Disclaimer The contents of these reports reflect the views of the authors who are responsible for the facts and the accuracy of the data presented. The contents DO NOT necessarily reflect the official views or policies of the State. These reports do not constitute a standard, specification, or regulation. Trade or manufacturers' names which may appear herein are cited only because they are considered essential to the obj ectives of these reports. The State of West Virginia does not endorse products or manufacturers. These reports were prepared for the West Virginia Department of Environmental Protection.ii | Page 

## Table of Contents
DISCLAIMER
................................ ................................ ................................ ................................ ............. I TABLE OF CONTENTS
................................ ................................ ................................ .......................... II LIST OF FIGURES
................................ ................................ ................................ ................................ . III LIST OF TABLES
................................ ................................ ................................ ................................ .... IV LIST OF ABBREV IATIONS
................................ ................................ ................................ ................... V EXECUTIVE SUMMARY
................................ ................................ ................................ ........................ 1 BACKGROUND AND OBJEC TIVES OF WATER AND W ASTE STREAM STUDY
..................... 8 LITERATURE REVIEW
................................ ................................ ................................ ........................ 11 I NTRODUCTION

................................ ................................ ................................ ................................ ........ 11 W ATER S OURCES FOR H ORIZONTAL S HALE G AS W ELL D EVELOPMENT IN THE M ARCELLUS

............... 15 Surface Water

................................ ................................ ................................ ................................ ...... 15 Groundwater

................................ ................................ ................................ ................................ ....... 16 Potable Water Supplies

................................ ................................ ................................ ....................... 16 Flowback Water Reuse

................................ ................................ ................................ ........................ 17 Other Sources

................................ ................................ ................................ ................................ ...... 17 W ATER AND W ASTE S TREAMS A SSOCIATED WITH H ORIZONTAL G AS W ELL D EVELOPMENT

.............. 18 Drilling Wastes

– Liquid and Solid Waste Streams

................................ ................................ ............ 21 Commonly Used Hydraulic Fracturing Fluids

................................ ................................ ................... 22 Characteristics of Flowback Waters

................................ ................................ ................................ ... 26 Radioactivity

................................ ................................ ................................ ................................ ... 26 E NVIRONMENTAL AND P UBLIC H EALTH C ONCERNS A SSOCIATED WITH W ATER AND W ASTE S TREAMS FROM THE D EVELOPMENT OF H ORIZONTAL S HALE G AS W ELLS

................................ ........................... 29 M ANAGEMENT OF W ATER AND W ASTE S TREAMS

................................ ................................ ................. 31 S UMMARY OF B EST A VAILABLE P RACTICES AND T ECHNOLOGIES FOR W ATER AND W ASTE S TREAMS 33 Storage Options and Practices

................................ ................................ ................................ ........... 34 Reuse or Recycle Options and Practices

................................ ................................ ............................ 35 Disposal Options and Practices

................................ ................................ ................................ .......... 38 P ROTECTION OF G ROUND AND S URFACE W ATERS DURING H ORIZONTAL S HALE G AS W ELL D EVELOPMENT S TAGES

................................ ................................ ................................ .......................... 42 WATER AND WASTE STRE AM MONITORING PLAN
................................ ................................ .. 45 B ACKGROUND

................................ ................................ ................................ ................................ ......... 45 R OLES AND R ESPONSIBILITIES

................................ ................................ ................................ ................ 45 S TUDY D ESIGN

................................ ................................ ................................ ................................ ........ 45 S AMPLING S ITES

................................ ................................ ................................ ................................ ..... 51 F IELD S AMPLING M ETHODS

................................ ................................ ................................ .................... 72 Groundwater Monitoring

................................ ................................ ................................ .................... 73 Water Storage for Well Development

................................ ................................ ................................ . 76 Moving Waste Stream

................................ ................................ ................................ ......................... 77iii | Page Waste Storage

................................ ................................ ................................ ................................ ..... 80 A NALYTICAL M ETHODS

................................ ................................ ................................ .......................... 80 D ATA M ANAGEMENT

................................ ................................ ................................ .............................. 83 DATA ANALYSIS, RESULTS AN D COMPARISON WITH WA TER QUALITY STANDARD S 85 D RILLING M UDS AND C UTTINGS C HARACTERIZATION AND P OLLUTANT I DENTI FICATION

................... 85 H YDRAULIC F RACTURING F LUIDS AND F LOWBACK C OMPARISON AND P OLLUTANT I DENTIFICATION 87 I MPOUNDMENT I NTEGRITY

................................ ................................ ................................ ..................... 89 I DENTIFICATION OF P OTENTIAL H EALTH C ONCERNS AND R ECOMMENDATIONS

................................ . 102 REFERENCES
................................ ................................ ................................ ................................ ........ 105 APPENDIX A: WVWRI P ROJECT STAFF
................................ ................................ ...................... 110 APPENDIX B: REI CON SULTANTS CHAIN
- OF
- CUSTODY FORM
................................ .......... 111 APPENDIX C: PACE AN ALYTICAL CHAIN OF CU STODY FORM
................................ .......... 112 APPENDIX D: INDIVID UAL SITE CHECKLISTS
................................ ................................ ......... 113 S ITE C HECKLIST

– C HESAPEAKE DNR A P AD

................................ ................................ ...................... 114 S ITE C HECKLIST

– L EMONS P AD

................................ ................................ ................................ ........... 116 S ITE C HECKLIST

– M AURY P AD

................................ ................................ ................................ ............ 118 S ITE C HECKLIST

– M ILLS W ETZEL P AD #2

................................ ................................ ........................... 120 S ITE C HECKLIST

– M ILLS W ETZEL P AD #3

................................ ................................ ........................... 122 S ITE C HECKLIST

– S AND H ILL L OCATION

................................ ................................ ............................ 124 S ITE C HECKLIST

– W EEKLEY P AD

................................ ................................ ................................ ........ 126 S ITE C HECKLIST

– W ACO /D ONNA P AD

................................ ................................ ................................ 128 APPENDIX E: FIELD S PREADSHEETS
................................ ................................ .......................... 130



## List of Figures F IGURE 1: C ENTRALIZED P ITS L OCATIONS

................................ ................................ ................................ 54 F IGURE 2: SHL

- 1 I MPOUNDMENT S AMPLING

................................ ................................ ............................ 55 F IGURE 3: SHL

- 1 I MPOUNDMENT S AMPLING

................................ ................................ ............................ 55 F IGURE 4: L EMONS P AD

– S HAKER T ABLE L IQUIDS

................................ ................................ .................. 56 F IGURE 5: L EMONS P AD

– S HAKER T ABLE S OLIDS

................................ ................................ .................... 57 F IGURE 6: L EMONS P AD

– V ERTICAL D RILLING F LUIDS

................................ ................................ ........... 57 F IGURE 7: M ILLS W ETZEL P AD #2 S HAKER T ABLE ( WHERE SAMPLES WERE P ULLED )

............................. 59 F IGURE 8: D ONNA P AD P IT S AMPLING OF H YDRAULIC F RACTURING (M AKEUP ) W ATER

........................ 60 F IGURE 9: S AMPLING H YDRAULIC F RACTURING F LUIDS AND W ATER M IXTURE BEFORE E NTERING W ELL

................................ ................................ ................................ ................................ ............................ 60 F IGURE 10: S AMPLING L OCATION OF H YDRAULIC F RACTURING F LUIDS

................................ .................. 61 F IGURE 11: F LOWBACK S AMPLING P OINT AT C ONDENSATE T ANKS , D ONNA P AD

................................ ... 63 F IGURE 12: C OMPOSITE F LOWBACK S TREAM S AMPLE AT D ONNA P AD S INGLE

- L INED P IT

..................... 63 F IGURE 13: W EEKLEY P AD S AMPLE A REA

– S AMPLE TAKEN FROM THE NOZZLE ( SEE ARROW )

............... 64iv | Page F IGURE 14: S AMPLE AREA AT THE S AND H ILL # 3 AND #4 ( AT LOWER RIGHT ) P ITS

................................ . 65 F IGURE 15: L OCATION OF C ONSOL /N OBLE C ENTRALIZED P ITS

................................ ................................ 67 F IGURE 16: C ONSOL /N OBLE C ENTRALIZED P IT SHL3

................................ ................................ .............. 68 F IGURE 17: C ONSOL /N OBLE C ENTRALIZED P ITS SHL2 AND SHL4

................................ .......................... 69 F IGURE 18: B OTTLES FOR T YPICAL G ROUNDWATER S AMPLE

................................ ................................ ... 70 F IGURE 19: C OLLECTION OF G ROUNDWATER S AMPLE FROM C ONSOL /N OBLE C ENTRALIZED P IT SHL2

. 71 F IGURE 20: L OW F LOW S AMPLING AT SHL3 G ROUNDWATER M ONITORING W ELL

................................ . 72 F IGURE 21: R ELATIONSHIP BETWEEN TPH AND B ENZENE

................................ ................................ ........ 99 F IGURE 22: R ELATIONSHIP OF C HLORIDE AND B ROMIDE IN S OURCE W ATERS

................................ ....... 100 F IGURE 23: B ARIUM /C HLORIDE (B A /C L ) R ELATIONSHIP IN I MPOUNDMENT W ATER AND G ROUNDWATER

................................ ................................ ................................ ................................ .......................... 101



## List of Tables T ABLE 1: C HEMICAL C HARACTERISTICS OF I NFLUENT AND F LOWBACK W ATERS

................................ ... 20 T ABLE 2: H YDRAULIC F RACTURING A DDITIVES

................................ ................................ ....................... 25 T ABLE 3: W ATER AND W ASTE S TREAM S AMPLING P LAN

................................ ................................ ......... 48 T ABLE 4: W ATER AND W ASTE S TREAM P ARAMETERS

................................ ................................ ............. 49 T ABLE 5: S AMPLING S ITE L OCATIONS

................................ ................................ ................................ ....... 51 T ABLE 6: G ROUNDWATER M ONITORING W ELLS AT C ONSOL /N OBLE C ENTRALIZED P ITS

....................... 66 T ABLE 7: REI C ONSULTANTS

– I NORGANIC AND O RGANIC D ATA C HECK

................................ ................ 82 T ABLE 8: P ACE A NALYTICAL

– R ADIOACTIVITY D ATA C HECK

................................ ................................ 83 T ABLE 9: A VERAGE C ONCENTRATIONS OF I NORGA NIC P ARAMETERS

................................ ...................... 92 T ABLE 10: A VERAGE C ONCENTRATIONS OF O RGANIC P ARAMETERS

................................ ....................... 93 T ABLE 11: F IELD R ADIATION R EADINGS FOR D RILL C UTTINGS AND D RILLING M UDS

............................ 94 T ABLE 12: R ADIOACTIVITY R ESULTS OF D RILLING M UDS AND F LOWBACK S OLIDS S AMPLES

................ 95 T ABLE 13: E XCEEDANCES OF D RINKING W ATER S TANDARDS

................................ ................................ .. 96 T ABLE 14: S UMMARY OF R ADIOACTIVE D ETERMINATIONS FROM F LOWBACK L IQUIDS S AMPLES

.......... 97 T ABLE 15: S UMMA RY OF R ADIOACTIVE D ETERMINATIONS FROM G ROUNDWATER M ONITORING W ELLS

................................ ................................ ................................ ................................ ............................ 98 T ABLE 16: G ROUNDWATER E XPOSURE TO S HALE G AS W ASTE S TREAMS

................................ .............. 102v | Page 

## List of Abbreviations Ag Silver
Alk Alkalinity
Al Aluminum
AMD Acid mine drainage
As Arsenic
ASTM American Society for Testing and Materials
Ba Barium
BOD Biochemical oxygen d emand
Br Bromide
BTEX Benzene, toluene, ethylbenzene and xylene
Btu British thermal unit
Ca Calcium
CFR Code of Federal Regulations
Cl Chloride
CO 3 2

- 

### Carbonate
COC Chain of custody
COD Chemical oxygen d emand
Cr Chromium
CSR Code of State R ules
CWA Clean Water Act
CWT Centralized waste treatment facility
DO Dissolved o xygen DRO Diesel range organics
E&P Exploration and productionvi | Page 

### EC Electro

- conductivity
EIA Department of Energy’s Energy Information Administration
EPA United States Environmental Protection Agency
FB Flowback
Fe Iron
FR Flame resistant
ft Feet
gpm Gallons per minute
GPS Global Positioning System
GW Groundwater
HCO 3 

### Bicarbonate
HF Hydraulic fracturing, fracking or frac
HFF Hydraulic fracturing fluids Hg Mercury
I Inorganic (parameters)
K Potassium
LPG Liquefied petroleum gas
MBAS Methylene blue active substances (surfactants)
MCL Maximum contaminant level
MCLG Maximum contaminant level goal Mg Magnesium

m g/L Milligrams per liter
Mn Manganese

m rem /h r M illirems per hour (rem = roentgen equivalent man)
MU Makeupvii | Page 

### Na Sodium
ND Not determined
Ni Nickel
NO 2 

### Nitrite
NO 3 

### Nitrate
NORM Naturally occurring radioactive material s NPDES National Pollutant Discharge Elimination System
OSHA Occupational Safety and Health Administration
Pb Lead pCi/g Picocuries per gram pCi/L P icocuries per liter, United States unit for volumetric concentration
PID Photo

- ionization detector
PO 4 

### Phosphate
POTW Publicly owned treatment works ppb Parts per billion
PPE Personal protective equipment
ppm Parts per million ppt Parts per trillion QA/QC Quality Assurance/Quality Control
R Radioactive (parameters)
RCRA Resource Conservation and Recovery Act
RO Reverse osmosis
S Sulfide
SDWA Safe Drinking Water Act
Se Seleniumviii | Page 

### SO 4 

### Sulfate
SOPs Standard Operating Procedures
Sr Strontium
SVOC Semi

- volatile organic compounds
TDS Total dissolved solids
TENORM Technically enhanced naturally occurring radioactive material
THM Trihalomethane
TOC Total organic carbon
TPH Total p etroleum h ydrocarbons
TSS Total suspended solids μg/L Micrograms per liter μmhos/cm Micromhos per centimeter (1 μmhos/cm = 1 μS/cm) μS/cm MicroSiemens per centimeter (1 μS/cm = 1 μmhos/cm)
USGS United States Geological Survey
VOC Volatile organic compound
WVDEP West Virginia Department of Environmental Protection
WVU West Virginia University
WVWRI West Virginia Water Research Institute
Zn Zinc1 | Page 

## Executive Summary This report summarizes the results of the phase I study “ Water Quality Literature Review and Field Monitoring of Active Shale Gas Wel ls.” In addition to the literature review, the p hase I
report consists of solid and liquid waste stream characterization and r ecommendations to reduce environmental exposure . It also contains initial results of groundwater monitoring at three centralized waste water impoundments. These impoundments wer e constructed with double polymer liners. Monitoring wells were installed at a second impoundment sit e in mid February 2013. The phase II report will include results of extended monitoring at the centralized and single impoundment sites.
Legislative Direction Although hydraulic fracturing is not a new technique, its rapid deve lopment in the Marcellus Shale Formation has caused concern regarding the pot ential risks to human health and the
environment

. On December 14, 2011 , t he West Virginia Legislature (Code of State Regulations §22

- 6A) enacted the Natural Gas Horizontal Well Control A ct. The act directs the West Virginia Department of Environmental Protection (WVDEP) to conduct several studies in order to collect information and report back its findings and recommendations. In summary the act requires a report that addresses the human health issues related to:

• Light and noise

• Air emissions

• Impoundment safety

• Water and waste streams The scope of the study begins with initial well development and ends with the initiation of gas product ion. In support of these legislative mandates, the WVDEP solicited a team of researchers2 | Page 

### from West Virginia University (WVU) to conduct these studies. L ed by the West Virginia Water Research Institute (WVWRI), the WVU researchers studied horizontal gas well development activity impacts on air and water quality, generated light and noise, and structural integrity and safety of the pits and impoundments retaining fluids from well development

. The studies included literature reviews followed by direct field monitoring. This report focuses on the
activities undertaken to conduct the wate r and solid waste stream study. Findings from the air emissions, light and noise study and the pits and impoundments safety study are contained in
separate reports. In 1988, the United States Environmental Protect ion Agency (EPA) issued a regulatory determination stating that control of exploration and production (E&P) wastes under the Resource Conservation and Recovery Act (RCRA) Subtitl e C regulations is not warranted. Hence, E&P wastes have remained exempt from Subtitle C regulations. The R CRA Subtitl e C exemption, however, did not preclude these wastes from control under state regulations, under the less stringent RCRA Subtitle D solid waste regulations, or under other federal regulations. In addition, althou gh they are relieved from regulation as hazardous wastes, the exemption does not mean these wastes could not present a hazard to human health and the environment if improperly managed. For the purposes of this report, waste streams will be indicated as “s olid or liquid
wastes” as defined by RCRA Subtitle D.
Hydraulic fracturing Hydraulic fracturing (injection of a water

- based fluid and sand mixture) technology, coupled with horizontal drilling, has facilitated exploitation of huge natural gas reserves in the Devonian

age Marcellus Shale Formation of the Appalachian Basin. The most widely used technique for stimulating Marcellus gas production involves hydraulic fracturing along a horizontal wellbore
to create a series of thin (generally less than 1 m illi m eter thick) fractures in the shale . The3 | Page 

### fractures are filled with a prop p ant such as sand to keep the m open and conduct gas to the
wellbore where it is conveyed to pipelines for transport and distribution.
The hydraulic fracturing process usually involves surface water withdrawal and disposal of waste
fluids. W hen the injection phase is over, 10 % to 40% of the injected fluid returns to the surface through the well casing . Th ese fluids are captured for later reuse or disposal and are referred to

as flowback . Flowback typically lasts for 4 to 6 weeks during which the water discharge rate
decreases from about 150 gallons per minute ( gpm ) to about 1 gpm. Flowback water is highly saline with varying amounts of organic contamination. It can be dispo sed of, either by injection into an approved underground injection well, or treated to remove contaminants so that the water meets the requirements for either surface release , or for use as makeup water for subsequent hydraulic fracturing operations

.

Th e Study An extensive literature review was conducted to characterize the water and waste streams associated with the development of horizontal shale gas well s including commonly used hydraulic fracturing fluids. Specific areas of review included: potential i ssues related to public
health and the environment, and safety aspects of hydraulic fracturing development ; surface and ground water contamination ; and well development practices to protect surface and groundwater sources during the well d evelopm ent . The literature review was used in developing an on
- site water and waste stream monitoring plan by defining sample parameters and procedures . The water and waste stream monitoring plan was updated as active horizontal well sites were monitored and study design and sampling methods were adjusted to field conditions.
The focus of the study was on s ampling and chemical analysis of drilling fluids, muds and cuttings along with hydraulic fracturing flui ds and flowback waters of working hydraulic4 | Page 

### fracturing sites in the Marcellus F ormation in West Virginia

. T he list of analytical parameters used in this study was developed through literature review and finalized in conjunction with the
staff of WVDEP. The list includes both primary and secondary drinking water contaminants.
Contaminan ts were evaluated based on exceedance of maximum contaminant levels as identified
under the Safe Drinking Water Act (SDWA)

. Permitting the construction of centralized pi ts for the storage of flowback water has recently begun in West Virginia

. Groundwater monitoring is required for centralized pits in West Virginia and thus groundwater monitoring wells were installed by the permit holder and samples collected prior to the use of the pits to store flowback water. As of the date of this study, only one permit had been issued for a cluster of three centralized pits. This site was selected for groundwater monitoring as well as waste storage monitoring. During well developme nt and hydraulic fracturing , these pits contained water for use in hydraulic fracturing fluid makeup. After hydraulic fracturin g, the impoundments were converted to flowback storage. Water in the impoundments was analyzed before and after conversion to flowback storage. Monitoring wells

were sampled to identify any groundwater contaminants before and after placement of flowback in the impoundments.

Site S ampling In order to meet the timeline specified by WVDEP, sampling reported in this part of the stu dy took place between June and December 2012. Multiple wells sites were sampled during that period in order to collect data from multiple sites during the various well development and completion stages. Active horizontally drilled and hydraulically fractured wells in northern West Virginia were sampled to determin e contaminant concentrations in :

• Hydraulic fracturing fluids5 | Page 

### • Flowback

• Drilling muds and cuttings

• Groundwater monitoring wells

WVDEP contacted natural gas developers and established access to Marcellus gas well sites for WVU researchers to collect water and waste stream samples. Liquid and solid samples were collected and analyzed for a wide range of inorganic, organic and radioactive constituents to

as certain and document the characteristics of the water and waste streams associated with the various stages of horizontal gas well development. While in the field, WVU researchers noted
current weather conditions and sampling time. They conducted a general radiation sweep of the
site and of the collected samples with a handheld radiation alert detector that displayed current
radiation level s in millirems per hour (mrem /hr) . They also scanned for off

- gases of volatile organic compounds ( VOCs) with a photo

- ionization detector (PID) as part of personal safety procedures

. Parameters such as pH, specific conductivity, total dissolved solids (TDS), dissolved oxygen , salinity and temperature of samples were measured in the field using a multi

parameter YSI56 unit. For each stage of horizontal gas well development, at least one sit e was identified for sampling.
To ensure complete site information was obtained and field monitoring and sampling activities remained consistent from site to site, a site checklist was developed. The checklist includes information relevant to the site location, stage of well development, samples collected and field observations. Samples were sent to certified labora tories. Samples were sent to REI Consultants for organic and inorganic compound determinations and to Pace Analytical for radioactiv ity analysis. It is important to note that all chemical determinations are for total as opposed to
dissolved concentration s
. It is also important to note tha t one of the organic parameters, TPH6 | Page 

### (diesel range) , is a measure of all hydrocarbons i n the range of C11 to C28. This range includes not only diesel fuel but the plant products: vegetable oil and guar gum. The l atter is a common additive in hydraulic fracturing fluids. Our analyses also included the organic compounds benzene, toluene, ethyl benzene and xylene. These, particularly benzene, are superior indicators of toxicity.
The nomenclature for hydraulic fracturing waste waters is not standardized across the industry. For the purposes of this study hydraulic fracturing fluids refer to the fluids injected with proppant in order to generate sufficient pressure to create fractures within the targeted formatio n.
T he term flowback refers to all fluids that return to the wellhead after hydraulic fracturing and prior to gas production . This includes hydraulic fracturing fluids , ga ses, gas liquids and water

. Produced water consists of fluids that return to the wellhead subsequent to gas production. In addition, reference to brines within this report refers to flowback waters with TDS values greater than 35,000 milligrams per liter ( mg/L )

. As the well is drilled, muds are used to cool the drill bit, control well pressures and lift rock cuttings to the surface. Cuttings and muds are separated at
the surface where muds are typically recycled. Spent drilling muds and cuttings are removed for disposal.
Findings Stud y objectives include : 1) C haracterize drilling muds and cuttings and identify pollutants , 2)

c ompare hydraulic fracturing fluids with flowback and identify hazardous pollutants , and 3)
i dentify if groundwater monitoring wells indicate d impoundment leakage

.

1. Characterize drilling muds and cuttings and identify pollutants

. Drilling muds were analyzed as liquids while drill cuttings were analyzed as solids. With the exception of arsenic, mercury, nitrate and selenium, the average concentrations of the primary and7 | Page 

### secondary drinking water parameters in drilling mud were in ex cess of all of the inorganic drinking water standards. They also exceeded the drinking water standards for benzene and surfactants (MBAS) and contained high concentrations of sodium, potassium and chloride. TPH (diesel range) was present in all drilling muds with
concentrati on s ranging from 23 mg/L to 315 mg/L. Background levels of radiation

r anged fr om 0.005 millirems per hour (mrem /hr) to 0.013 mrem /hr . Sample level s of radiation ranged from 0.009 mrem /hr to 0. 016 mrem /hr. The standard for contaminat ion is typically twice background. A review of the individual background levels of radiation
indicated that this criterion was not exceeded

. 2. Com pare hydraulic fracturing fluids with flowback and identify pollutants

. Two hydraulic fracturing fluids and thirteen flowbac k samples were analyzed. One hydraulic fracturing fluid sample contained benzene in measurable quantities while ten of the thirteen flowback samples contained benzene in concentrations in excess of the primary drinking water st andard of 5 μg/L . Both hydraulic fra c turing fluids and all of the drilling mud and flowback samples contained total petroleum hydrocarbons ( TPH ) in the diesel

range
. It is important to note this determination, also known as diesel range organics (DRO) , does not indicate that diesel is present. Rather, it indicates that hydrocarbons in the range of C1 1 to C28 are present. This c ould include diesel or common hydraulic fracturing fluid additives such as guar gum, an extract of the guar bean used to incre ase the viscosity of the hydraulic fracturing fluid to efficiently deliver the proppant into the
formation

. There was no correlation between concentrations of benzene and TPH (diesel range). All flowback samples contained high concentrations of inorganic ions including sodium, chloride, bromide and barium.8 | Page 

### 3. Impoundment leakage. There was no evidence of significant leakage of flowback from the impoundments. Nitrate and lead were detected in monitoring wells in excess of primary drinking water standards. The concentration of nitrite exceeded the maximum contaminant level ( MCL ) of 1 mg/L in three of five shallow monitoring wells by a maximum of 0.47 mg/L. However, w hile nitrate exceeded the primary MCL in samples taken after conversion of the impoundments to accept flowback, the single lead exceedance occurred prior to conversion. As is common in West Virginia wells, i ron, aluminum and manganese exceed ed the seconda ry drinking water standard in both shallow and deep wells both before and after conversion of the impoundments from holding freshwater to flowback. The impoundment wells did not, however, indicate elevated chloride, bromide or barium concentrations as wou ld be expected if flowback leakage occurred in significant quantities

. In addition, while flowback contains
measurable benzene and diesel range organics , neither was detected in the monitoring
wells. While the monitoring wells detected no contaminants it is not clear that the monitoring interval of 146 days was sufficient to capture any leakage from the impoundments. A longer sampling is suggested with, perhaps, aquifer permeability testing.



## Background and Objectives of Water and Waste Stream Study In West Virginia, around 3,000 wells have been identified as targeting the Marcellus or Utica
S hale F ormation s. These wells are reported to have the potential to recover more than 100
trilli on cubic feet of natural gas ( 1 )

. With current United States ann ual consumption rates, this quantity of natural gas could m eet the energy needs of the United States for several decades.9 | Page 

### As pressure for fossil fuel production grows, the proximity of communities to exploration and extraction operations increases along wi th the potential for human exposure to potential hazards and pollution. With recent increased activity tapping the gas reserves of the Devonian Shale, public concern over the potential impacts of horizontal drilling and hydraulic fracturing has also increased. Although hydraulic fracturing is not a new technique, the rate of which it has been used recently in the Marcellus Shale Formation has greatly escalated bringing with it elevated concerns of environmental impacts. Few studies have been published on the health effects of oil and gas exploration and extraction activities on nearby communities. The Natural Gas Horizontal Well Control Act enacted by the West Virginia Legislature at CSR §22

- 6A on December 14, 2011, directs the West Virginia Department of Environmental Protection (WVDEP) to conduct several studies in order t o collect information and report back its findings and recommendations. In par ticular, the following studies we re directed by the new legislation: §22
- 6A
- 12 (e) Well location restrictions. The secretary shall, by December 31, 2012, report to the Legislat ure on the noise, light, dust and volatile organic compounds generated by the drilling of horizontal wells as they relate to the well location restrictions regarding occupied dwelling structures pursuant to this section. Upon finding, if any, by the secre tary that the well location restrictions regarding occupied dwelling structures are inadequate or otherwise require alteration to address the items examined in the study required by this subsection, the secretary shall have the authority to propose for

pro mulgation legislative rules establishing guidelines and procedures regarding reasonable levels of noise, light, dust and volatile organic compounds relating to drilling horizontal wells, including reasonable means of mitigating such factors, if necessary.10 | Page 

### §22
- 6A
- 22 Air quality study and rulemaking. The secretary shall, by July 1, 2013, report to the Legislature on the need, if any, for further regulation of air pollution occurring from well sites, including the possible health impacts, the need for air qual ity inspections during drilling, the need for inspections of compressors, pits and impoundments, and any other potential air quality impacts that could be generated from this type of drilling activity that could harm human health or the environment. If he or she finds that specialized permit conditions are necessary, the secretary shall promulgate legislative rules establishing these new requirements. §22
- 6A
- 23 Impoundment and pit safety study; rulemaking. The secretary shall, by January 1, 2013, report to the Legislature on the safety of pits and impoundments utilized pursuant to section nine of this article including an evaluation of whether testing and special regulatory provision is needed for radioactivity or other toxins held in the pits and impoundments. Upon a finding that greater monitoring, safety and design requirements or other specialized permit conditions are necessary, the secretary shall propose for promulgation legislative rules establishing these new requirements. In support of th ese legislative mandates and at the request of WVDEP , a team of researchers from West Virginia University (WVU), led by the West Virginia Water Research Institute (WVWRI), examined the effects of gas drilling on surrounding air and ground water and
identifi ed potential environmental health and safety impacts of the large pits and impoundments used to retain liquids and solids associated with the development of shale gas well s . Research

teams conducted literature review s and developed and implemented environmental monitoring
studies to identify the effects of horizontal gas well development on air and water quality, generated light and noise, and structural integrity and safety of the pits and impoundments11 | Page 

### retaining fluids from well development

. T o fu lfill the obligations of the water and waste stream portion of the study titled , “Assessing Environmental Impacts of Horizontal Gas Well Drilling Operations,” t he objectives include :
1. Conduct a review of relevant literature on the use of hydraulic fracturi ng fluids and the water and waste streams created during the various stages of horizontal gas well development.
2. Based on the literature review, identify concerns with potential surface and groundwater contamination that may be caused by horizontal well de velopment and identify protective
measures for surface and groundwater during the well drilling process.
3. Develop and implement an on

- site monitoring plan of the various water and waste streams associated with horizontal gas well development to identify potential health
concerns or associated environmental risks.
4. Analyze the data collected during the monitoring portion of the study and compare results to primary and secondary drinking water quality standards.
5. Note any potential public health concerns or risks to the environment and include in the final report to the West Virginia Department of Environmental Protection (WVDEP).



## Literature Review
Introduction Fossil fuels

– coal, oil and natural gas

– supply more than 85% of the nation’s energy. Natural gas has a high British thermal unit (Btu) content, is an efficient and reliable energy source and is the cleanest burning of the fo ssil fuels ( 2 )

. R eliance on natural gas as an energy source will not
diminish in the foreseeable future. With recent increa sing demands on energy , easily accessible oil and gas reservoirs decreasing, and success tapping unconventional natural gas resources in12 | Page 

### the United States, natural gas from unconventional resources is anticipated to become an ever

increasing portion of the country’s natural gas reserves
. Natural gas from unconventional

resources currently accounts for nearly half of the country’s total production ( 3 ). Development of the extensive natural gas reserves contained in the Marcellus Shale deposits promises to be an important op portunity for the United States because of its proximity to majo r markets in the
northeastern United S tates ( 4 and 5 )

. Shale gas is a natural gas from shale formations and consists of a combination of hydrocarbon gases but is largely ma de up of methane. Shale gas is found in rock formations beneath the surface of the earth and at times is present with oil deposits. Shale is a sedimentary rock made up mainly of clay

- sized particl es that tend to lay flat as sediments accumulate and beco m e compacted with additional sediment deposits over time . O rganic matter is trapped along with
these sediments. The sheet

- like clay mineral grains and layers of sediment result in a rock with limited horizontal permeability and extremely limited vertical p ermeability. These low permeable and often rich

- organic units are thought to be the source for much of the hydrocarbon gases produced in the basins (6 ). In other words, shale gas is created and stored within the shale bed. Low permeability means the gas trapped in the shale cannot move easily within the rock and must be stimulated to release the gas and allow it to fl ow up through the wellbore hole

. Extraction of gas from the Marcellus is considered to be unconventional by the Department of Energy’s Energy Information Administration (EIA) because the gas is found within a shale
formation rather than sandstone or limestone (7 )

. Major shale deposits under development in the
United States all have the common characteristics of low porosity and permeabil ity. Extraction from shale gas reservoirs like the Marcellus requires either vertical or horizontal drilling coupled13 | Page 

### with hydraulic fracturing to access and release the gas . Also required are strategies for sourcing makeup water and handling waste water

.

T he Marcellus Shale F ormation is thought to be among the largest natural gas reserves in the world. It covers an area of approximately 95,000 square miles overlaying much of the Appalachian Basin stretching from West Virginia in the south through New York in the north.
The Marcellus Shale is a Middle Devonian

- age shale , a member of the Hamilton Group; found more than a mile (5,000 to 9,000 feet) underground and ranging in thickness from 50 to 200 feet
surrounded with limestone below and a n additional shale layer above (5 )

. It is an organic rich rock, the remnants of an ancient river delta , laced with trapped gas, mostly methane. Driven by application o f existing technology to tap this natural gas reserve thousands of feet below the
earth ’s surface, development of th e Marcellus reservoir has transformed the energy industry sending United States natural gas prices to all

- time lows and the possibility of the country becoming energy

- in dependent within the foreseeable future to an all

- time high.
Advances in refining cost

- effective horizontal drilling and hydraulic fracturing practices have changed the ability to tap unconventional shale reservoirs and produce a sustainable product. However, rapid application of these technological advancements has increased concern about environmental impacts mainly because of the uncertai nt y that surrounds the techniques involved. It is important to understand the technologies and practices in use and what is needed to prevent

or m inimize potential effects of shale gas development on water resources

. Shale gas development has consisted of drilling and completing vertical and horizontal wells. Regardless of the type of well, casing and cement are installed to protect fresh and treat able water aquifers. The combination of horizontal drilling and hydraulic fracturing technologies14 | Page 

### provide several environmental and economic advantages over conventionally drilled vertical wells. Technological advances allow natural gas companies to use less surface area, drill fewer
wells to access the same rese rves, and generate less wastes (8)

. Therefore, t o optimize recovery of shale gas in the most economical way, operators are using more horizontal wells. Horizontal drilling exposes more of the fo rmation creating a huge advantage over the use of vertical wells. Multiple horizontal wells can be launched from one well pad targeting different zones. Six to eight horizontal wells drilled from only one well pad can access the same reservoir volume as
sixteen vertical wells and the use of these multi

- well pads reduces the ove rall environmental impact (3 ). Reducing the size of the shale operations’ footprint is at the top of the list for companies seeking to become more environmentally friendly. Indust ry is designing their well pads to better meet their needs and reduce the impact on the surrounding environment. The use of multiple wells w ith multiple stages of fractures on a single pad is one way. Some companies are also moving away from freshwater f or hydraulic fracturing of wells and using liquid petroleum gases or gels

. Hydraulic fracturing, p umping of a mixture of water, sand and additives under high pressure into a shale formation allowing the natural gas to flow out of the shale , is the other component that makes recovery of shale gas viable. The casing and cement that is installed during the drilling process provides protection for groundwater sources d uring the hydraulic fracturing process. Plus, several hundred to several th ousand feet separate the top of the fracture zone of the Marcellus and the bottom of the deepest freshwater aquifer layer making it improbable for hydraulic fracturing fluids to reach groundwater used as a source of drinking water.
Sustainable development of shale gas in the Marcellus requires the management of large volumes of water necessary for the drilling and hydraulic fracturing process to unleash the gas15 | Page 

### from the formation. Challenges associated with the development of shale gas involve the

manageme nt of water

– transportation, storage and disposal of the water and waste streams created during all stages of well development

- in a manner that does not present a threat to
human health and the surrounding environment.



### Water Sources for Horizontal Shale Gas Well Development in the Marcellus Explor ation of the Marcellus Shale may pose water resource and water supply challenges to the gas industry operating in the Appalachian Basin (4 ). Water used for drilling and hydraulic fracturing normally comes from surface waters, groundwater, muni cip al potable water suppl ies, or reuse of flowback waters, or from some other water source.

Surface Water 

### Currently, the preferred source of hydraulic fracturing water is surface water which may be transported to the site by pipeline or truck ( 9)

. On average, for each horizontal well drilled in the Marcellus, three to five million gallons of water are needed to drill and hydraulically fracture
the well. Only about 10 % to 40% of this water is recovered and it typica lly contains high
concentrations of total dissolved solids (TDS). The remaining water stays in the formation. Due to the amount of water loss, large amounts of new make up water are required to develop each new gas well. Depending on the number of horizontal wells that may be drilled and hydraulically fractured in any given basin, water demand may become a critical issue particularly during the latter half of the year when stream levels are lowest

. The Ohio River Basin is located
within southwester n New York, western Pennsylvania, and much of West Virginia. It comprises all the major rivers and streams that make up the Ohio River. The Marcellus Shale region underlies approximately 10% of the Ohio River Basin (10 ). The Ohio River Basin and its maj or
tributaries

– the Monongahela and Allegheny Rivers, may be seen as less challenged from a water resource perspective when compared to the other river basins within the Marcellus Shale16 | Page 

### area. However, recent evaluations conducted by the West Virginia Wate r Use Survey and Pennsylvania State Water Plan highlight the Ohio River watershed may face some significant water resource challenges (4 ) . With many streams and aquifers affected by acid mine drainage, supplies of potable water are often limited (4 ). When comparing shale gas development water use with other activities and practices such as agriculture, power generation, recreation and municipal consumption, shale gas water use accounts for a very small portion of overall general
bas in use, usually less tha n 1% (3 ).
Besides quantity issues, concerns about the ecological impacts to aquatic resources from water withdrawals have been raised throughout the Marcellus Shale region (11 ).

Groundwater 

### Groundwater in West Virginia is generally of good quality with 42% of the state’s population relying on groundwater as the source of their domestic water supply; but, a recent comprehensive study by the United States Geological Survey (USGS) raises concerns based on iron, manganese and radon levels found in water samp les taken from 300 wells around the state

. Developing a groundwater well near an active Marcellus Shale development area would have to be able to provide sufficient yield and not have any impact on nearby drinking water s upply wells or surface waters ( 9 ). To ensure this does not happen, a hydrological study of the area would need
to be conducted prior to drilling the groundwater well

.
Potable Water Supplies 

### Municipal water suppliers are another option to provide a source for freshwater to drilling and hydraulic fracturing operations. To the extent that capacity exists to provide water for rate

paying customers as well as shale gas operators, the municipality may agree to provide water for hydraulic fracturing

.17 | Page Flowback Water Reuse 

### Recy cling of flowback and produced water reduce s the dem and on freshwater supplies and the volume of water that requires treatment or disposal

. It is unknown if reus ing untreated flowback
waters for hydraulically fracturing new wells would impede gas production. Therefore, most shale gas operators treat flowback waters to some degree. Many technical solutions exist to treat
flowback waters. These technologies are discussed under the Best Available Practices section
of th is report.

Other Sources 

### Another option may be to use treated acid mine drainage (AMD). AMD is water that has been contaminated by contact with pyrite in strip

- mine operations, refuse piles or abandoned deep
mines that results in the format ion of sulfuric acid and iron ( 9)

. Treatment typically involves
neutralization and removal of metals such as iron. Common in many areas underlain by the Marcellus Shale, treated AMD may be a plausible substi tution for surface water. Scaling by divalent and trivalent ions is an issue when considering the use of AMD . Some suggest
treatment to reduce total hardness to 2,500 mg/L (12 )

. A study in 2009 conducted by ProChem Tech International, Inc. found that treated AMD was a suitable su bstitute for freshwater for the hydraulic fracturing process of a shale gas well. It required a simpler treatment process compared to treatment of return flowback water and allowed an alternative use for AMD other than treatment and surface discharge. Us ing their unique chemical process with no addition of calcium hydroxide and inclined plate clarifiers to remove iron below 20 mg/L and keep calcium well below 350 mg/L, treated AMD was used in a succe ssful operation in Pennsylvania (12 )

. The use of AMD wa ter in Marcellus Shale development may provide a win

- win solution for coal and natural gas industries along with the regulatory agencies that are tasked to oversee activities18 | Page 

### of both industries by providing a use for the AMD instead of treatment and monito ring required for discharge

. 

### Water and Waste Streams Associated with Horizontal Gas Well Development Several members of the Marcellus s hale industry volunteered to participate in a study to develop an information base on the nature and composition of influent water and flowback waters associated with completions of Marcellus shale g as wells (13 )

. Nineteen well sites were identified throughout Pennsyl vania and West Virginia where hydraulic fracturing would take place. Samples were taken of the: supply water prior to blending of additi ves, influent wa ter following blending with additives but before the addition of sand, flowback samples at varying
time lapses after hydraulic fracturing, and water from each producing well 90 days after completion.

Results show influent water usually contains moderate to low concentrations of salts

. R efer to
Table 1 (13) . The concentration of TDS in flowback increased with time while the flow rate decreased with time. Samples showing moderate TDS values in the influent water indicate implementation of water reuse practices meaning those companies use flowback water in part to make up hydraulic fracturing flui d for subsequent fracturing . Oil and grease, and total organic carbon (TOC) concentrations in these samples indicate blending of flowback water with
freshwater . General characteristics of the flowback and produced water are consistent with
literature val ues. Typically the dissolved solids in flowback and produced water s from Marcellus wells consist of sodium, chloride, calcium and to a lesser extent , strontium, barium and bromide. Heavy metals of toxicological concern that are often associated with urban industrial activity were at very low levels compared to what is typically reported in sludge from municipal wastewater facilities. Among the volatile organic constituents tested, nearly 96% were found at19 | Page 

### non
- detectable levels and 0.5% w as above 1 mg/L

. Constituents in produced waters that exceeded 100 parts per billion (ppb) included components commonly present in produced water s from natural gas operations: benzene, toluene, ethylbenzene and xylene (BTEX); naphthalene; several methylated benzene compoun ds and an alkylated toluene; however, few determinations of these compounds exceede d 2 parts per million (ppm; 13)

. Nearly all halogenated organic compounds were at non

- detect levels strongly suggesting additives blended with mak e up waters
do not contain concentrations of organic chemicals of concern. The results of this shale gas

water c haracterization effort indicate that PCBs, pesticides, and a large fraction of volatile organic compounds ( VOCs ) and semi

- volatile organic compounds ( SVOCs ) should be

con sidered unnecessary for the sampling and analysis o f flowback waters in the future (13 )

.20 | Page 

### Table 1 : Chemical Characteristics of Influent and Flowback Waters

Parameter Units Influent Water Before

Additives Influent Water After

Additives Flowback Water 5 Day s Out Flowback Water 14 Days Out pH No units 6.7

– 7.4 5.2

– 8.9 5.8

– 7.2 4.9

– 6.8 Acidity mg/L <5

– 5.5 <5

– 1 , 230 <5

– 447 <5

– 473 Total Alkalinity mg/L 6.2

– 88.8 5

– 308 48.8

– 327 26.1

– 121 Hardness as CaCO3 mg/L 18

– 1 , 080 26

– 9 , 500 5 , 100

– 55,000 630

– 95,000 TSS mg/L <2

– 24 4

– 5 , 290 10.8

– 3 , 220 17

– 1 , 150 Turbidity NTU 1.3

– 33.7 2.7

– 715 2.3

– 1 , 540 10.5

– 1 , 090
Chloride mg/L 4.1

– 3 , 000 18

– 10,700 26,400

– 148,000 1 , 670

– 181,000 Total Dissolved Solids mg/L 35

– 5 , 510 221

– 27,800 38,500

– 238,000 3 , 010

– 261,000 Specific Conductance μ mhos/cm 55

– 10,100 177

– 34,600 79,500

– 470,000 6 , 800

– 710,000 Total Kjeldahl Nitrogen mg/L <3

– 56.4 2.3

– 400 38

– 204 5.6

– 261 Ammonia Nitrogen mg/L 0.017

– 20.8 0.28

– 441 29.4

– 199 3.7

– 359 Nitrate
- Nitrite mg/L <0.1

– 3.0 0.1

– 3.1 <0.1

– 1.2 <0.1

– 0.92 Nitrite as N mg/L <0.05

– 4.9 <0.05

– 5 1.2

– 29.3 <2.5

– 77.4 Biochemical Oxygen Demand mg/L <2.0

– 110 <2.0

– 2 , 220* 37.1

– 1 , 950 2.8

– 2 , 070 Chemical Oxygen Demand mg/L <10

– 924 35.3

– 47,400 195

– 17,700 228

– 21,900 Total Organic Carbon mg/L 1.8

– 202 5.6

– 1 , 260 3.7

– 388 1.2

– 509 Dissolved Organic Carbon mg/L 1.4

– 222 5

– 1 , 270 30.7

– 501 5

– 695 Oil and Grease mg/L Not detected 4.6

– 255 4.6

– 655 <4.6

– 103 Cyanide, Total μ g/L <10

– 625 3.5

– 954 <10

– 72.1 <10 Amenable Cyanide mg/L <0.01

– 0.27 <0.01

– 0.87 <0.01

– 0.032 <0.01 Bromide mg/L <0.2

– 31.9 <0.2

– 107 185

– 1 , 190 15.8

– 1 , 600 Fluoride mg/L <0.05

– 1.2 <0.05

– 58.3 < 0.05

– 17.3 <0.05

- <50 Total Sulfide mg/L 1.6

– 5.6 <3

– 8.8 <3

– 5.6 <3.0

– 3.2 Sulfate mg/L 3.8

– 139 2.9

– 2 , 920 2.4

– 106 <10

– 89.3 Total Phosphorus mg/L <0.1

– 0.14 <0.1

– 16 <0.01

– 2.5 <0.1

– 2.2 Total Recoverable Phenolics mg/L 0.01

– 0.031 < 0.01

– 0.77 <0.01

– 0.31 <0.01

– 0.31 Sulfite mg/L 6

– 21.6 <5

– 61.6 2.5

– 38 7.2

– 73.6 Methylene Blue Active Substances (MBAS) mg/L <0.05

– 0.962 <0.03

– 0.506 <0.012

– 1.52 <0.05

– 4.6 *BOD readings were reported as g/L not mg/L.21 | Page Drilling Wastes

– Liquid and Solid Waste Streams 

### Drilling a horizontal gas well begins the same way as other types of wells. A vertical well is drilled to a pre

- determined depth, followed by the horizon tal or lateral drilling into the targeted
shale formation. The drilli ng process itself generates cuttings and muds that must be managed
when removed from the bore hole. Cuttings are made up of rock fragments. Drilling muds are made up of a base fluid such as water, mineral oil, or a synthetic oil

- bas ed compound; weighting
agent; clay; and a stabilizing organic material such as lignite (15). Drilling muds can also pick up characteristics of the various formations as drilling proceeds.
Cuttings are often transported from the well to the surface by the base fluid that serve s to cool and lubricate the drill bit. This fluid, which is used only during the drilling phase of well development , is commonly referred to as “drilling muds” or “muds

. ” Bari te is sometime s added to the fluid for weight (14 )

. In the Marcellus, pressurized air is commonly used as the drilling “fluid” during the vertical drilling stage and a liquid waste or slurry for the horizontal drilling
stage. Drilling muds and cuttings are brought to the surface where the liquids and sol ids are separated via shale shaker tables that consist of large sieves (15 )

. Liquid wastes pass through the screen and are collected in an underlying basin. The solid drill cuttings are retained on the top of
the screen. Shaker tables can re cover up to 70 % to 80% of the liquid for reuse. Disposal options for cuttings include dewatering and haulage to a licens ed waste disposal site or burial on
- site with the permission of the landowner and approval from the governing regulatory body . Until recently, cuttings disposal pits were generally not lined

. Muds are typically reused and sent back down the well. Once drilling is completed, muds can be reused to drill another well or be properly disposed of in a landfill

.22 | Page Commonly Used Hydraulic Fracturing Fl uids 

### After a well is drilled and casing has been placed , the completion stage, or hydraulic fracturing, begins (16 )

. Hydraulic fracturing was first developed in the 1940s to stimulate production from
oil reservo irs with declining productivity (3 )

. In the production zone of the well, a perforation gun shoots holes through the casing and ce ment at pre

- determined locations (11 )

. Hydraulic fracturing takes place in stages where hydraulic fracturing fluids are pumped through the perforations, and plug s are set . The process is repeated until the length of the production zone
has been fractured

. Hydraulic fracturing takes place under high pressure (around 10,000 psi) to create microfractures in the rock formation to allow the gas to be extracted. The sand or other proppant holds the new fractures open allowing the gas to flow freely out of the formation and into a production well for compression, transmission, and sale.
Mixed with the water and sand is a chemical cocktail of other ingredients that include friction
reducers (slick water) , corrosion inhibitors, oxygen scavengers, scale inhibitors and biocides (disinfectants; 17 )

. The resulting mixture is referred to as hydrau lic fracturing fluid and is typically created on

- site . The water and sand typi cally make up 98 % to 99% of the hydraulic fracturing fluid with the rest consisting of the various chemical additives used to improve the
effectiveness of the fracture and subs equent release of natural gas. Nearly all f luids currently
used in Marcellus Shale hydraulic fracturing operations are water based or mix ed slickwater fracturing fluids (5 )

.

Some of the a dditives used in hydraulic fracturing fluids are used in many common hous ehold products and foods (8)

. However, hydraulic fracturing fluids have been f ound to contain hydrochloric or muriatic acid, petroleum distillate, ammonium bisulfate, fluorocarbons,23 | Page 

### naphthalene, butanol, and formaldehyde (18 )

. Many of these chemical s are either carcinogenic or can cause a wide range of health problems affecting eye s, skin, lungs and the nervous system.
In 2010, the United States House of Representatives Committee on Energy and Commerce conducted an investigation into the practice of hydraulic fracturing in the United States (19 )

. Fourteen leading oil and gas companies were asked to provide information on the types and volumes of hydraulic fracturing products used in their fluids between 2005 and 2009. The investigation yielded a total of 750 different chemicals and other component s used by these companies to create their hydraulic fracturing fluids. Components were found to range from harmless (table salt and citric acid), to unexpected (instant coffee and walnut hulls), to ext remely toxic (benzene and lead; 19 )

. Methanol was f ound to be the most widely used chemical by the companies surveyed. Methanol is considered a hazardous air pollutant and is on the candidate list for pote ntial regulation under the SDWA (19 )

. Other commonly used chemicals included isopropyl alcohol (sur factant), 2

- butoxyethanol (foaming agent or surfactant) and ethylene glycol (scale inhibitor) along with the silicon dioxide (sand proppant). The Committee’s investigation also found that the fourteen oil and gas companies surveyed used hydraulic f racturi ng products containing twenty

- nine chemicals that are known as or may be possible human carcinogen s regulated under the SDWA due to risks to human heal th, or listed as hazardous air pollutant s
under the Clean Air Act.
Each company has their own hydraulic fractur ing fluid recipe s and has typically kept them secret siting proprietary information (20 )

. The resistance of energy companies to publicly disclose the chemicals used to make up their hydraulic fracturing fluids has heightened the concern that these substances can harm the surrounding environment and negatively impact human health. This is especially true if there is a way the hydraulic fracturing fluids and thus chemicals can mix with24 | Page 

### nearby groundwater resources. Some companies post information a bout their fracturing fluids on their websites or general websites . An example is www.fracfocus.org which provides a general idea as to what additives are used for hydraulic fracturing in the Marcellus Shale. Adapted from the West Virginia Oil and Natural Gas Association , Energy in Depth , Geology.com, and the Society of Petroleum Engineers, common ingredients found in hydraulic fracturing fluids used in the Marcellus Shale region and the purpose each serves is summarized
in Table 2 ( 21, 22, 23 and 24 )

.25 | Page 

### Table 2 : Hydraulic Fracturing Additives Category Main Ingredient Purpose Other Uses
Water Water Expand fracture, deliver sand Landscaping, manufacturing Proppant Silica, Quartz Sand Hold fracture open Drinking water filtration, play sand, concrete
Gel Guar Gum or Hydroxyethyl C ellulose Thickens water and suspend s sand Cosmetics, baked goods, ice cream, toothpaste

Friction Reducer 1) Petroleum distillate 2) Polyacrylamide 3) Mineral oil 1) Slick water to minimize friction 2) Minimizes friction between pipe and fluids 1) Hair, makeup , skin products 2) Soil conditioner, water treatment 3) Makeup remover, laxatives Acid Hydrochloric or Muriatic A cid Dissolves minerals and initiates cracks in rock Swimming pool cleaner
Anti

- Bacterial Agent Glutaraldehyde Eliminates bacteria in the water Disinfectant, medical equipment sterilizer Scale Inhibitor Ethylene G lycol Prevents scale deposits Household cleansers, paints, caulk

Breaker 1) Ammonium Persulfate 2) Sodium Chloride Allows delayed breakdown of gel 1) Hair coloring, disinfectant, manufacturing of plastics 2) T able salt
Corrosion Inhibitor (Oxygen Scavenger) 1) n,n
- dimethyl formamide 2) Ammonium Bisulfite Prevents pipe corrosion 1) Pharmaceuticals, plastics 2) Cosmetics, food and beverages
Crosslinker Borate salts Maintains fluid viscosity as temperature increases Laundry detergents, hand soaps, cosmetics
Iron Control Citric acid Prevents metal oxides precipitation Food additive, beverages Clay Stabilizer Potassium Chloride Creates brine carrier fluid Table salt substitute, IV fluids pH Adjustment Agent Sodium or Potassium Carbonate Maintains effectiveness of other products Laundry detergents, soaps, water softeners
Surfactant Isopropanol Reduces surface tension an d i ncreases viscosity of frac turing fluid s Glass cleaner, deodorant, antiperspirant26 | Page Characteristics of Flowback Waters 

### Once the hydraulic fracturing process is completed and the wellbore pressure released, a portion of the fracturing fluids and water flows back up the wellbore to the well head

. Referred to as flowback, this water returns over the life of the well and is collected in tanks or lined pits

. The
Marcellus is considered a desiccated formation. It contains little if any water in most locations.
Flowback and produced water consist of organic, inorganic and radioactive compounds from the originally injected wa ter along with constituents acquired during contact with the formation. These may include the additives that were introduced during the hydraulic fracture job as well as characteristics of the formation such as salts, oils and greases, metals and organic compound s,
and may include naturally occurr ing radioactive materials (NORM ). The primary radionuclides of concern are isotopes of radium that originate from the dec a y of uranium and thorium naturally present in the subsurface

. Organic compounds are either separable with de

- oiling technologies (such as oils and greases) or they are soluble (such as phenol, mono

- carboxylic acids glycols) , requiring a m or e complicated removal process ( 9).

Radioactivity 

### All environmental media contain some level of radioactivity or naturally occurring radioactive materials ( NORM )

. There are three main groups of radioactive elements that exist in all soil and
rock on earth : uranium

- 238/radium

- 226 radionuclide series, the thorium

- 232 radionuclide series , and potassium

- 40 (25 )

. Typical , natural background concentrations of uranium, radium, and thorium present in soil and rock in the eastern United States range from 0.5 to 1 pCi/g each and 10 to 30 pCi/L for potassium

- 40 (2 5 )

. Certain commercial minerals, such as gypsum, zirco nium and titanium used in paint and zircon sand and carborundum used in sandblasting and ceramics have radioactivity le vels ranging from 5 to 50 pCi/L (26 )

.27 | Page 

### Certain materials used or generated in certain industry sectors have higher than background levels of NORM or technologically enhanced naturally occurring radioactive materials (TENORM; 27 )

. Exposure to naturally occurring radiation makes up the majority of an average person’s yearly radiation dose and is generally not considered of significance to health and safety (49). Certain industries handle signifi cant quantities of NORM, which can mainly be found in
their waste streams . A s potential hazards are identified, monitoring and regulation of s uch
materials and activities have increased. Industries known to have NORM issues include: coal, oil and gas, metal mining and smelting, phosphate fertilizer industry, building and recycling (49).

In shale gas development, NORM can be found in drill cuttings, flowback waters and natural gas (28 )

. NORM are more noticeable in areas where sediments or precipitates tend to accumulate such as equipment, pipes and storage tanks , and as a result, exposure m ay occur when repair work is performed (29 )

. Dense steel used in natural gas production blocks alpha and beta radiation and greatly reduces transmission of gamma radiation. Since distance reduces exposure, risks to the general public are possible when co ntaminated materials and components s uch as pipe and tankage are mis handled (29 ). According to the World Nuclear Association, NORM i n the oil and gas industry poses a problem to workers particularly during maintenance, waste transport and processing, and decommissioning (49). In particular, Lead

- 210 deposits and films

are only a concern when pipe internals become exposed (49). External exposure due to NORM
in the o il and gas industry is generally low enough not to require protective measures to ensure that workers stay beneath their annual dose limits and internal exposures can be minimized through hygiene practices (49).
Radioactivity in the Marcellus Shale var ie s across the formation. Over time, the radioactive isotopes decay with half

- lives from a few days to several hundred years. Levels of NORM in28 | Page 

### Marcellus Shale flowback tend to be relatively low with higher concentrations in the later
flowback waters and produced water

. Alpha particles and Radium

- 226 in some produced waters
in New York ha ve been found at concentrations exceeding drinking water m aximum
contaminant levels of 15 pCi/L and 5 pCi/L, respectively (26 )

. Exposure to radionuclides , even at low levels can raise serious health concerns. Radon gas , known to exist within the Marcellus has been shown to be a primary cause of lung cancer. The EPA has established drinking water guidelines for certain radionuclides: 5 pCi/L for radium, 30 pCi/L fo r uranium and 15 pCi/L for total alpha emitters. EPA has also set radium

- 226 levels in wastewater discharges at 60 pCi/L, disch arges to land surface at 5 pCi/g and 15 pCi/g to
subsurface soils.
The New York Department of Health analyzed three samples of flowback waters from Marcellus wells and found elevated levels of gross alpha, gross beta, and radium

- 226, which is
character istic of Devonian

- age shales (11 )

. The presence of high levels of radium

- 226 raised several issues: monitoring of NORM need to be evaluated for Marcellus gas wells; levels of
NORM in flowback waters need to be assessed to determine if additional treatment of the
flowback waters are needed prior to disposal; and caution should be exercised when considering spreading brine waters on roads to keep du st down or for deicing purposes (26 )

. Based on these findings, the New York Department of Health recommends continued sampling of flowback

water s and drilli ng muds and cuttings. They feel analysis of gross alpha activity, gross beta activity and some gamma spectroscopy analysis to be sufficient to assess if further
characterization of radioactive material is warranted. Although total gross alpha counting efficiency is uncertain in samples with high dissolved solids, it is an inexpensive screen ing tool,
and if counts exceed 15 pCi/L, additio nal analysis is warranted (26 )

. The WVDEP may want to29 | Page 

### consider following the lead of the New York Departmen t of Health for monitoring radioactivity
of water and waste streams returning up

- hole. If general analysis of total gross a lpha and beta counting present concern by yielding sample readings well above twice background radioactivity readings, further analy sis should be conducted to characterize radiation levels measured and determine if additional protective measures need to be implemented for workers and/or nearby populations

.


### Environmental and Public Health Concerns Associated with Water and Waste Streams from the Development of Horizontal Shale Gas Well s Public concerns about water quality from horizontal gas well development include: aquifer and drinking water well contamination; waste storage pit leak age ; spills of hydraulic fracturing
fluids ; handling of flowback streams ; water use and supply; drilling waste disposal; s tormwater runoff; and blowouts (31 )

. These concerns stem from two related activities: 1) well development and completion , and 2 ) management of w ater and waste streams (handling, storage and disposal)

. Casing and cement failure to properly bond the well annulus can result in upward migration of gas and fluids into shallow drinking water aquifers.
Identifying the cause of contamination of a nearby drinking water well can be difficult. Characterization of flowback and produced water chemistry and isotopic composition has been empl oyed to identify migration of hydraulic fracturing wastes into drinking water supplies . A study conducted by researchers from Duke University found methane gas in drinking water wells located within one kilometer of active drilling sites ( 32 ). However, there was no baseline data available to determine if methane was present in the drinking water wells prior to nearby drilli ng activities commencing. And, methane was detected in nearly all of the drinking water wells tested regardless of the proximity to drilling activities. The Duke study did highlight a known concern that faulty or leaky well casings at the top of a drilli ng site may allow methane to30 | Page 

### migrate t o nearby water supplies. I n Pennsylvania, where this study took pla ce, regulations do not exist requiring private drinking water wells to be properly drilled and cased, increasing the potential of contamination from an y nearby activity. A lack of baseline testing of water wells prior to well development and completion render s interpretati on of the results problematic.
Published studies and agency investigations indicate no direct connection between hydraulic
fracturi ng of shale formation s and groundwater contamination (33 )

. A 2011 study by the Center for Rural Pennsylvania analyzed water samples from private wells within 2,500 feet o f a Marcellus Shale gas well (34 ). Pre

- drill and post

- drill samples were taken to id entify any changes in water quality. Samples were analyzed for TDS, chloride, sodium, sulfate, barium, strontium and methane. Results indicated there were no statistically significant increases in pollutants prominent in drilling waste fluids and the con clusion was drawn that gas well drilling had not had a significant effect on water quality of nearby drinking water wells. Nonetheless, contamination incidents attributed to poor gas well construction , as was the case of the Duke University study of nearby drinking water wells in Pennsylvania , have raised concerns regarding the adequacy and/or enforcement of state well construction regulations for both gas production and drinking water supply

. Many who express concern about potential water problems do not differentiate between the actual fracturing process and associated stages of horizontal shale gas well development and production (35 )

. State regulators and industry representatives define hydraulic fracturing as the specific well stimulation opera tion. However, t he general public and media outlets often use the term “hydraulic fracturing” or “fracking” to broadly refer to a range of activities associated with unconventional gas development. Few published, peer

- reviewed scientific reports exist
do cumenting potential environmental impacts from hydraulic fracturing. Studies that do exist31 | Page 

### show that the risks depend more on the quality and integrity of the borehole casing and cement job rathe r than the hydraulic fracturing process (36 ). There is litt le agreement regarding the risks that hydraulic fracturing operations pose to underground sources of drinking water and , as a result, Congress has directed the E PA to study the matter further (33 )

. 

### Management of Water and Waste Streams Surface activities pose an additional concern for potential groundwater contamination. Leaking pits, accidental spills or careless disposal practices of drilling fluids at the production site will increase the risk of contaminating nearby water supply w el ls. Storage, treatment and disposal of flowback waters also create additional water quality issues. Leaks from flowback water and waste storage pits and s urface spills from transporting flowback water or fracking fluids can cause contamination of nearby s urface and groundwater . Many believe that above

- ground activity is a greater risk to drinking water resources than below

- ground activity and may have
contributed to the contamination of water supplies in Pavillion, Wyoming (37 )

. Lined pits that are used to store the flowback water may pose a threat to groundwater and surface water resources if these structures are not designed and constructed properly to retain the liquids until they are drained and the site closed and reclaimed. Common problems wit h these structures
include tears in liners that allow fluids to escape and enter nearby surface waters o r seep into nearby groundwater.

Surface water contamination from the hydraulic fracturing process may occur if hydraulic
fracture fl uid s pills at the wellhead site or if the trucks carrying this fluid leak as they trav el to
and from the wellhead . These spills may be from unused hydraulic fracturing fluid or return hydraulic fracturing fluid that comes back up the well during the flowb ack process. Spill prevention measures are necessary because surface spills may pose a greater risk to groundwater32 | Page 

### than the hydraulic fracturing process. Although operators try to ensure spills do not occur, it occasionally happens and must be reported t o the proper regulatory agencies. Spills are not a common occurrence because fluids lost to a spill must be replaced and remediation of
contaminated so ils increases operational costs (5 )

. One of the biggest issues with surface water contamination found during the literature review is
from the treatment of the flowback water at municipal wastewater plants. Flowback water is very high in chlorides, sodium and calcium. These chemicals create high TDS levels. Other
contaminants of concern found in f lowback waters include bromide, barium, and traces of radiation. Typical wastewater treatment plants are not equipped to remove enough of these contaminants to allow release or final disposal into receiving surface waters. The high
contaminant levels fou nd in flowback water require specialized treatment in order to protect surface waters receiving the treated wastewater. High bromide levels have been found to exist in
surface waters where publicly owned treatment work s (POTW) and centralized waste treatm ent ( CWT ) facilities receiving wastewaters from oil and gas development discharge their effluent. These are the same surface waters that downstream drinking water systems pull from to supply their customers with drinking water. Most POTWs and CWTs are not equipped to treat bromide and thus it passes through their system. Bromides are not necessarily dangerous by themselves; it is only when they mix with chlorine used by drinking wa ter systems that they become a threat to public health.
A typical Marcellus well pad site is around 3 to 5 acres in size. The area allows fo r the wellheads and a combination of pits, impoundments and tanks to hold drill cuttings, used drilling and hydrau lic fracturing fluids, freshwater and flowback waters. Access to the well pad add s to33 | Page 

### the overall amount of disturbed land. Appropriate practices need to be in place to control
stormwater runoff at the well pad as well as around the roads providing acces s to the site.
Blowouts are rare occurrences that happen when the fluid injected into the wellhead does not fracture the rock around the bottom of the well and the elevated pressure drives the fluid into

ot her open and permeable pathways (36 )

. Pathways can include the borehole, other oil and gas wells, artesian wells or abandoned wells in the vicinity that cannot handle high pressures. Old abandoned wells can also provide a potential pathway for contaminants to enter groundwater systems. Sta tes estimate that there are over 150,000 abandoned o il and gas wells in the United
States (35 )

. Blowout prevention equ ipment installed at the surface prevents pressurized fluids encountered during drilling from moving up the well through the space between the dri ll pipe and surface casing (38 ) . A blowout in West Virginia occurred because the drillers reportedly encountered an unexpected pocket of methane in an abandoned coal mine below the surface and a blowout preve nter had not yet been installed (38 )

. Fluids spilled onto the surface from blowouts can leach into surrounding soils and groundwater and need to be cleaned up and the
area remediated

. These types of incidents support the need to gather accurate and complete
information about the subsurface an d surrounding area prior to gas well development

. 

### Summary of Best Available Practices and Technologies for Water and Waste Streams Water management (storage, treatment and disposal) technologies available in the Marcellus Shale region cover treatment , recycle/reuse and disp osal by Class II injection well s of flowback and produced waters

. Industry is looking for alternative ways to manage these waste waters that minimize costs and impacts to the environment. Treatment is the most complex option availabl e to manage water and wastes from the development of horizontal shale gas wells. Treatment can

occur on
- site or off

- site and in conjunction with reuse options. All treatment method s produce34 | Page 

### some form of residual waste, liquid or sludge, and must be managed to avoid environmental
harm

. Depending upon the end use of the wastewater, various treatment options are available and discussed below in respective sections.

Storage Options and Practices 

### Large quantities of water in a short amount of time are required for hydraulic fracturing operations. Water restrictions commonly exist limit ing the amount of water that can be withdrawn and transported to well sites necessitating the need for some form of water storage.
The two methods often used to store water on

- site or near active hydraulic fracturing operations are containment units, t ypically referred to as tanks, and impoundments.

Tanks are available from many vendors. Rectangular tanks, with a V

- bottom or cylindrical bottom, with a 21,000 gal lon capacity tran sported b y a semi

- truck, are most commonly used. Because these tanks hold a small volume of water compared to the amount needed for the

average hydraulic fracturing job, hoses are used to connect several tanks together. To provide a 1,000,000 gallon storage capacity, 48 tanks are needed, requiring a considerable amount of space
and an extensive hosing network. Secondary containment const ructed around these units serves

to provide additional environmental protection from accidental leaks and spills. Se condary
containment units look similar to a tray

- like structure with raised sides to prevent fluids from leaching into soil or washing into nearby surface waters.
Impoundm ents can b e used in coordination with tanks or alone as a m eans to provide water
storage on
- site. Impoundments differ from pits in that they hold only freshwater. Pits are used
to hold flowback waters and other residual water and waste streams from horiz ontal gas well development.35 | Page Reuse or Recycle Options and Practices 

### A combination of water use restrictions and increased unconventional natural gas development will likely increase the demand f or non
- freshwater supplie s for future development operations. Care must be exercised when reusing fluids and flowback waters with little or no treatment.
Flowback waters with high levels of salts, barium and calcium , may cause scaling issues over
time. Bes ides salts, flowback w aters contain heavy metals and various organic and radioactive compounds that may limit reuse options without prior advanced treatment. Major treatment processes such as reverse osmosis and distillation are very costly but have been proven to reduce

const ituents present in flowback waters that can cause scaling, compatibility issues with hydraulic fracturing fluid additives and increase friction on subsequent hydraulic fracturing jobs. In Pennsylvania, industrial treatment followed by reuse is a common me thod for managing
wastewaters from the dev elopment of Marcellus gas wells (15 )

.

Because traditional off

- site disposal options are not often available in the Marcellus region, reuse

o ptions are being employed (39 )

. Recycle or reuse of flowback waters reduces the amount of wastewater generated and the amount of freshwater needed for hydraulic fracturing operations; but, this practice can create concentrated residual by

- products that will need to be dealt with. Pennsylvania allows the use of Mar cellus brines to roadways as long as the brines can meet

cer tain water quality requirements (39 )

. Brines are a product of flowback waters that have been treated at a CWT designed specifically to handle these wastes. Although this has been a common practi ce in the Marcellus region, environmental concerns have recently increased

re sulting in a closer look at contaminant concentrations of the brines and risks of these pollutants

was hing into nearby waterways (39 )

.36 | Page 

### Land application of hydraulic fracturing f luids is considered an acceptable form of disposal in

some states where hydraulic fracturing activities are ongoing ; however, little information exists on impacts these fluids have on vegetation. In 2008, hydraulic fracturing fluids from a gas well

were applied to a small section of a hardwood forest in West Virginia. During application, severe damage and mortality to the ground vegetation was observed (40 )

. Two years after application, nearly half of the trees were dead. Soil samples were taken prior to application and throughout the two year study period of the application area and adjacent area to evaluate the
effects of hydraulic fracturing fluids on soil chemistry. Sodium and chloride concentrations in
the soil were found to be increased 50

- fold after application of the hydraulic fracturing fluids (40 ) . T hese concentrations did decline over time, likely due to leaching. Researchers
recommend additional studies into the application rates of hydraulic fracturing fluids and effects on vegetation an d land resources.
Chemical composition of hydraulic fracturing fluids is designed to optim ize performance of the
frac turing job (17 )

. When reusing flo wback waters for additional hydraulic fracturing , it is imperative TDS concentrations are kept in check to not negatively affect the ability of the new hydraulic fracturing fluids. Many operators will blend the flowback waters, treated or untreated, with freshwater to achieve the right consistency, keeping TDS values minimal. If the flowback

waters are unt reated, blending will require more freshwater to dilute TDS values. Therefore, it is
beneficial to treat the flowback waters if freshwater sources are scarce.
Treatment of water and waste streams from horizontal gas well development can occur on or off site. Several companies have developed a wide variety of technologies to treat flowback waters
for reuse from gas wells at the site (on

- site). Some form of physical (filtration) or chemical (coagulations and flocculation) separation is needed to remove o il and grease and suspended37 | Page 

### matter. Bag or cartridge filtration systems are commonly used to remove suspended solids from flowback waters. They offer a compact footprint with a simple design but can be labor intensive. The next step for treatment conc entrates on reducing levels of hydrocarbons, organics and
metals. This treatment can be accomplished using a form of membrane system like reverse osmosis (RO), ion exchange, or electrodialysis. These membrane systems cannot be used as a
stand

- alone treatment system for Marcellus flowback waters . They require some level of
pretreatment. Often, some form of disinfection is introduced into the treatment schematic as
well

. Disinfection is often required in unconventional shale plays like the Marcellus prior to hydraulic fracturing and especially if recycled flowback waters m ake up part of the hydraulic fracturing fluids (41 ) . Ozone and ultraviolet light are two common forms of disinfection used to oxidize biological films and bacteria that may exist i n flowback waters. Similar to the membrane systems, disinfec tion systems cannot be used as stand

- alone treatment system s and also require pretreatment to be effective.
The issue of reducing TDS values has not been addressed by the treatment technologies

m entioned thus far. Since TDS values are extremely high in flowback waters of the Marcellus, any of these treatment options may have difficulty processing flowback waters with TDS values over 40,000 mg/L. Thermal distillation and evaporation may be the on ly option to treat flowback waters with TDS values greater than 40,000 mg/L on a regular basis. As of 2010, a handful of thermal distillation facilities were operating in the Mar cellus region, highlighting the need to develop and implement a dditional trea tment process es
. Wastewater treatment processes achieve a high water recovery rate by concentrating the solids and sludges. H owever, no practical and cost

- effective method exists to remove all NORM

. Chemical precipitation, ion exchange or activated carbon can remove metals and radium. The38 | Page 

### EPA recommends reverse osmosis treatment of water to remove most forms of radioactive particles when treating for drinking water consumption ( 42 )

. This may be pra ctical as an end of treatment process if NORM are still an issue in the discharge waters.
Energy requirements, need for pretreatment, and the system size needed for these technologies to process flowback waters must be considered when evaluating these technologies for on

- site application. Treatment and reuse of flowback waters will reduce the demand on freshwater sources and potentially decrease disposal costs by reducing the amount of wastewater that mu st be hauled away. The disadvantages of treating flowback waters on

- site still to be addressed include the fluctuations in quantity and quality of flowback waters. The treatment selection for one site may not be the best for the next given the variations from well to well and formation to formation making it difficult for a one

- size

- fits

- all treatment solution.

Disposal Options and Practices 

### With the excep tion of underground injection via a Class II well, most wastewater management strategies for handling water and waste streams from horizontal gas well development require some level of treatment. During the treatment of these water and waste streams, resi dual wastes are created that will have high concentrations of heavy metals, salts and other constituents limiting disposal options. Often these residual wastes are either sent to an acceptable landfill or
sent f or underground injection

. Current practice in the Marcellus Shale region is to transport

wastewater s to treatment facilities (POTWs or CWTs) or dispose through Class II injection
wells.
Direct discharge of wastewater from shale gas wells to surface waters is prohibited by federal
law. POTW can accept wastewaters from shale gas extraction activities as long as the treatment facility maintains compliance with all federal, state, and local requirements governing the39 | Page 

### introduction of such wastewaters into the POTW. In other words, POTW need to main tain compliance with their national pollutant discharge elimination system ( NPDES ) permit. When considering accepting wastewater from shale gas development, or any other industrial activity, the POTW operator needs to know the water quality and quantity c haracteristics of the

wastewater to determine if the POTW can process it without upsetting the treatment system or allowing pollutants to pass through and be discharged to the receiving water. Wastew ater treatment facilities, POTWs , may be unable to adequ ately treat the levels of TDS, metals and radioactivity that is sometimes present in flowback water and waste streams.

TDS concentrations in Marce llus s hale waste streams have been found to range from 300 milligrams per liter (mg/L) to well over 300,000 mg/L with chlorides typically constituting about 50% of the total makeup of TDS (7 and 13 )

. TDS is not significantly reduced or removed by

most treat ment processes utilized at POTWs and therefore pretreatment of the wastewater would be required. High concentrations of TDS require advanced wastewater treatment, such as distillation, and may cause scaling which requires frequent cleaning of equipment ( 9) . The
l iterature reveals some of the common constituents of TDS, at concentrations much less than
wha t is typically found in shale waste streams (including the Marcellus) , and may result in inhibition of activated sludge, nitrification, and anaerobic digestion proce sses commonly utilized
at POTWs (7 )

. High concentrations of chlorides have also been found to disrupt biological treatment processes and metals have also been found to preci pitate out during treatment creating issues with disposal options for b iosolids

. Bromide, which can be present in shale gas extraction wastewater streams , has the potential to pass through the POTW and be present in the final discharge stream as a disinfection byproduct that could lead to increased effluent toxicity ( 43 )

. Because of high levels40 | Page 

### of bromides and TDS found in many of the rivers and st reams in Pennsylvania to which POTWs and CWTs discharge, State regulators recently asked Marcellus Shale Formation operators to voluntarily stop disposing of the drilling wastes and flow back waters to these facilities ( 44 )

.
Radionuclides, referred to as NORM , have been found to exist at fairly high concentrations in

waste s treams from the Marcellus Shale Formation (7 )

. Flowback water has not been extensively monitored and studied for NORM

. Few studies are available to he lp understand the
issue of NORM in POTW and CWT effluent. Because there is a possibility wastewater from shale gas extraction activities may pass through a POTW, cause the POTW to violate its permit,
cause interference with the PO TW’s operation, or contaminate biosolids, acceptance of the waste
is not advisable unless its effects on the treatment system are well unde rstood and the wastewater
is reasonably expected not to cau se pass through or interference (7 )

. The same pollutants may be of concern to CWTs

. CWTs typically use the same tr eatment processes found a t POTW but may also include additional coagulation and precipitation techniques to help with TDS removal. Yet, m any CWTs may not effectively treat shale gas
extraction wastewaters and , therefore , appropriate limits and pretreatment requirements will need to be developed by the permitting and pretreatment control authorities. Additional limits may be required to address pollutants present in shale gas extraction wastewaters that were not
considere d in developing the original CWT effluent guideline . These limits will need to be incorporate d into the CWT’s NPDES permit. For such pollutants, permit writers will have to include technology

- based limits developed on a case

- by

- case, “best professional j udgment ” basis (7 )

. Very few CWTs exist within the Marcell us region , most of which exist in Penns y lvania.41 | Page 

### Chemicals used during drilling, as part of the hydraulic fracturing fluids, or other production

related activities need to be disclosed to the POTW o r CWT as well. The facility in turn must notify and receive approval from the appropriate State agency and the EPA prior to accepting any waste streams from shale gas extraction operations.

In 2011, a stream study was conducted in western Pennsylvania on the effects of discharges from POTWs and CWTs that accept wastewaters fr om Marcellus Shale gas sites ( 45 )

. Salinity stress to freshwater systems was found to be the most significant threat to the ecological welfare of the
streams. Accumulation of radi oactivity in the stream sediment represented a long

- term legacy of NORM in the environment. Based on these findings, researchers determined that gas

- produced
NORM ha ve yet to be quantified in freshwater sediments and suggested further studies to

measure N O RM levels in stream sediment.
Where injection wells are available, they are used as an option for disposal of flowback waters and may provide one of the safer means for final disposal

. Underground injection requires less treatment than other disposal m ethods, and when done with appropriate safeguards , creates the
least risk of contami nant release to the environment (39 )

. In the Marcellus region, there are a limited number of Class II injection wells scattered throughout Ohio, Pennsylvania and West Virginia. These injection wells can be near the well pad and operated by the producer , or off

- sit e and operated by a third

- party (17 )

. Injection wells access deep formations that have sufficient porosity and ability to accept the water. These form ations lay far below any groundwater aquifers.
In summary, Marcellus Shale gas operators employ all of the above mentioned options for storage, treatment, reuse and disposal of their flowback waters. If waters are not being reused,42 | Page 

### they are taken to a P OTW or CWT that will accept the wastewater or dispose of it via a private or commercial injection well.


### Protection of Ground and Surface Waters during Horizontal Shale Gas Well Development Stages In addition to treatment , there are various options available to shale gas developers in the Marcellus that can be utilized to protect water resources. These options range from the type of additives used to make up the hydraulic fracturing fluids, to how fluids are handled during the various stages of well development.
Horizontal shale gas wells are typically encased in alternating layers of concrete and steel down through aquifers. For wells to produce gas, it is vital there are no leaks of either gas or hydraulic fracturing fluids into aquifers or other strata. There are rare occasions that a well may fail during drilling or does not produce enough gas to be economical and may have to be abandoned. In this case, proper procedures must be followed to abandon the well.
Many shale gas development operators have abandoned the use of diesel in favor of more environmentally friendly fluids such as high paraffinic fluids, mineral oil and plant

- based oils that possess less toxicity a nd are reasonably biodegradable (11 )

. There is also the option to use
waterless fracturing agents such as liquefied petroleum gas (LPG) , GasFrac TM, or liquid carbon
dioxide DryFrac TM

. According to GasFrac TM , their system is a closed

- loop system that primarily

uses prop ane since it is a naturally

- occurring hydrocarbon and does n ot damag e the shale
formations ( 46 )

. If the topography is conducive and the distance not great , natural gas developers can also use conveyance pipes to carry the various water and fluids to well pads. Depending upon the location in the Marcellus, this may be an option to help reduce spill potential and truck traffic.43 | Page 

### Baseline monitoring studies o f groundwater are needed before any drilling activity begins. Cementing of wellbore casings need to be carried out to the surface. Down

- hole pressure testing and measurements and casing integrity tests are needed to ensure protection of shallow groundwate r resources.
One of the best ways a community’s water system source water can be protected is to have total ownership of the land, minerals, and gas and oil rights in the water shed area, or strict lan d

- use ordinances or regulations (4 7 )

. Since this kind of control is usually not possible, there are other measures nearby communities and drinking water system operator s can make to protect their source waters. Source water and wellhead protection plans can be updated to reflect past and present gas well dev elopment . Transportation routes to and from well pads should be mapped and plans developed to handle potential spills that may occur along the way.

Lab test results from routine drinking water and wastewater system analyses normally obtain ed
to meet SDW A and NPDES requirements , respectively, will help establish a baseline for any future anomalies and will be important to show changes in water quality if changes occur (4 7 )

. Drinking water system operator s need to keep an eye on their raw water and wastewa ter system operator s need to watch their influent waste streams for any significant changes. Changes in TDS, TSS, conductivity, pH, bromide, chloride, or methane levels may signify that external factors may be influencing their system. Monitoring source water for drinking water systems and influent for wastewater systems should incl ude VOCs , TDS, conductivity, total suspend ed solids ( TSS ) , chloride, bromide, dissolved methane, pH and radon. Systems on a limited budget should concentrate on chloride, brom ide, conductiv ity, TDS and pH (47 )

.44 | Page 

### With the boom in developing unconventional gas reservoirs through means of horizontal drilling
and hydraulic fracturin g operations, health and safety concerns from the public and private

sectors have increased. A new American Society for Testing and Materials ( ASTM ) committee was recently formed to develop standards that will promote best practices for field operations and protect downstream air, land and water resources

. Although in its initial stage of creation,
the committee plans to look at all stages of gas well development

– from initial site planning and investigation thro ugh well abandonment activities ( 48 )

. Lastly, critical evaluations of horizontal gas well development and their potential impacts on the
envir onment must be based on peer

- reviewed, scientific analyses of the data. Transparency will encourage acceptance of horizontal drilling and hydraulic fracturing activities. Open communication between industry, regulatory agencies and the general public is a must for successful development of natural gas resources that protects public health and the environment.45 | Page 

## Water a nd Waste Stream Monitoring Plan Background The intent of the Water and Waste Stream Monitoring Plan is to characterize and document potential surface and groundwater contamination that may be caused by any of the various stages
of horizontal gas well development

. 

### Roles and Responsibilities A list o f WVWRI staff directly involved in this study is included in Appendix A along with their
contact information.


### Study Design The intent of the field sampling described in this monitoring plan is to characterize and
document water and waste streams associated with the development of a horizontal gas well in the Marcellus play and to determine potential impacts from pits and impoundments on nearby groundwater resources. Marcellus gas wells at various stages of development have been selected for this project. WVWRI researchers worked with state agencies and industry representatives to identify the gas well sites and obtain access to the drilling fluids, muds and cuttings, and the hydraulic fracturing and flowback waters. WVWRI personnel also obtained informati on on the source water(s) that make up the hydraulic fracturing water, as well as copies of the hydraulic fracturing fluid composition breakdown. GPS coordinates were obtained and verified upon initial site visits for all gas well locations, sampling poin ts, water withdrawals, permissible discharges, and pits and impoundments.
Water samples were collected and analyzed from all applicable impoundments and pits at each site studied. In addition, three centralized waste pits in Marshall County were monitored per requirements of §22

- 6A

- 9 (mandated for study by §22

- 6A

- 23). Background samples were46 | Page 

### collected from each monitoring well prior to pit use and post

- pit acceptance of waste streams. The leak detection systems were monitored for the presence of leaked fluid. One monitoring well was placed up

- gradient of the pit and two were placed down

- gradie nt of the pit at each study location. Additional monitoring wells were installed down

- gradient of two of the study pits in a deeper aquifer to provide further characterization. Part of this study focuses on sampling and analyzing the chemical makeup of dri lling fluids, muds and cuttings along with hydraulic fracturing and flowback waters of Marcellus gas wells, paying specific attention to organic compounds, and determining which of these compounds are of concern for potential groundwater contamination. Wat er samples and samples of solids (cuttings, muds, etc.) from the drilling process were also an alyzed for radioactivity

.

An overview of the various stages of gas well development that were monitored, how often samples were collected during each stage, the t ype of sample

- liquid or solid, and the sampling
date is provided in Table 3

. A listing of parameters analyzed for each sample by a commercial laboratory facility is provided in Table 4 . Method detection limits (MDLs) and EPA method numbers for each para meter are also provided in Table 4 . Total count and exposure radiation were monitored for all liquids and solids from impoundments and pits, as well as all groundwater samples. Sampling results were compared to primary and secondary federal drinking water standards. Daily maximum values, values that exceed maximum contaminant levels, and average results for all parameters for each well development stage were determined from

sa mpling results.
Duplicate samples were randomly collected for approximately 10% of all samples taken. Field parameters such as pH, specific conductivity (μS/cm), total dissolved solids (mg/L), and temperature (oC) were measured in the field using a multi

- parameter YSI 556 unit. Duplicate47 | Page 

### samples were obtained prior to sample collect ion in the field. WVWRI researchers also noted visual observations of the surrounding environment and obtained photographs during sampling
visits. On any fie ld investigation, a minimum of two WVWRI staff were p resent. Each staff member

was required to car ry personal prote ctive equipment (PPE) and flame

- resistant (FR) clothing necessary for access to a well development or well development activity

- related site. Minimum PPE requirements included: hardhat, safety glasses, metatarsal boots, metacarpal gloves and FR clothing. In addition, WVWRI personnel were required to have on hand: full

- face respirators with combination P100 and organic vapor filters, first aid kits, a flotation device, a handheld
radiation alert detector displaying current radiation levels in millir ems per hour (mrem /hr) and a
6

- gas photo ionizer detector (PID). The radiation alert detector and PID were used to scan the working environment prior to any sampling or monitoring activity on

- site.48 | Page 

### Table 3 : Water and Waste Stream Sampling Plan**Stage Target** **Water/Waste Stream Sample** **Frequency Water/** **Waste Stream** **Sample Phase** **Water/Waste Stream Point of** **Collection # Water /** **Waste Samples** **per Site Water and Waste** **Stream Sampling Dates, 2012** **Air Monitoring Dates, 2012** **Pad Site for Water/Waste Stream** **Monitoring**Water Storage forWellDevelopmentFresh WaterImpoundmentFresh waterSite specific (# ofsamples pulleddetermined by size ofimpoundment)LiquidVarious locationsdependentuponimpoundmentsize, up to 8(1) 6/7(2) 8/28(1) N/A(2) WAMS only: moved on8/25 staying 6 days(1) Consol/Noble CentralizedImpoundment(2) Mills Wetzel Pad #3LiquidLiquid from shakertable, Composite (pit)3(1) 8/8, 8/15, 8/22, 10/2(2) 10/25SolidMuds from shakertable, Composite (pit)3(1) 8/8, 8/15, 8/22, 10/2(2) 10/25Drilling fluidOnceLiquidDetermined by siteoperator1(1) 8/8, attempted on 8/20,8/22, 8/24(2) Storm - completed drillingbefore samples could becollectedLiquidLiquid from shakertable, Composite (pit)3(1) 8/8, attempted on 8/20,8/22, 8/24(2)Storm - completed drillingbefore samples could becollectedSolidMuds from shakertable, Composite (pit)3(1) 8/8, attempted on 8/20,8/22, 8/24(2) Storm - completed drillingbefore samples could becollectedHydraulicFracturing WaterTankers/Impoundments/Containers2(1) 7/25 only 1 sample(2) 9/11 only 1 sampleCombinedHydraulicFracturing Fluid &FreshwaterStream of fluid goingdown hole2(1) 7/25 only 1 sample(2) 9/11 only 1 sampleInitial1Solid1(1) 8/30/12(2) 8/15 and 8/20(3) 9/17 for SHL 3 & 4 only(4) TBD(5) 10/2 - one sample onlyLiquid1(1) 8/30(2) 8/15 and 8/20(3) 9/17 for SHL 3 & 4 only(4) TBD(5) 10/2 - one sample onlyGroundwaterMonitoringPits:1 single-lined pit,3 centralized pitsEach pit'smonitoring wellsPrior to any wasteentering pit, onefollowing completion ofwaste entering the pitLiquidMonitoring wells6(1) 6/4, 6/7 and 6/19 - initial;10/31 - 11/1 - final(2) TBD(1) N/A(2) N/A(1) Consol/Noble - threecentralized pits(2) EQT Smithburg 28,Dodderidge Co(1) WAMS on 7/20, sampled7/23 - 7/28: Trailer on 7/19,collected 7/20 - 8/2, off 8/2(2) WAMS sampled 8/7 -8/13, one WAM til 8/18:Trailer on 8/2, collected 8/3 -8/16, off 8/16(3) N/A(4) N/A(5) Equipment previously onsite during fracking, ALLTrailer equipment monitoringcontinuously 8/29 - 9/26:WAMSStream of fluid comingup(1) Waco ECA Donna Pad(2) Weekley Site #1(3) Consol/Noble CentralizedPits(4) EQT Smithburg 28,Dodderidge Co(5) Maury Site HF done 9/14,Flowback did not start until10/1, scheduled through10/6(1) Waco - ECA Donna Pad(2) Maury Site(1) Mills Wetzel Pad #2(2) WVDNR A Pad -Chesapeake(1) Lemons Pad (+25 daysfrom 9/6)(2) WVDNR A Pad -Chesapeake(1) 7/27, 8/2, 8/9 and 8/30(2) 8/15 and 8/20(3) 8/13, 8/20, 8/28 and 9/17(4) TBD(5) 10/2 - one sample onlyshort flowback stage4Storage of flowbackLiquid(1) Trailer 9/26 - 10/16:WAMS 9/27 - 10/2(2) WAMS 10/19 - 10/25:Trailer on 10/17, collected10/19 on(1) WAMS collected 8/18 - 8/25:Trailer on 8/16, collected 8/17 -8/24, off 8/24(2) Equipment previously on siteduring vertical, Trailercontinuously monitoring since10/19; drilling occurred 10/25-10/31 but generator unpluggedby Chesapeake no data collected:WAMS 10/26 - 10/29(1) WAMS on 7/20, sampled7/23 - 7/28: Trailer on 7/19,collected 7/20 - 8/2, off 8/2(2) WAMS on 8/25, sampling9/7 - 9/13: Trailer on 8/24,some instruments collecting8/24 , remaining collecting8/29, both til 9/14Well Drilling andHydraulicFracturingVerticalDrillingOnce/week andcompositeHorizontalDrillingDrilling - producedwasteOnce/week andcompositeHydraulicFracturingOnce/week (recordingstage of frac)Drilling - producedwastePits:1 single-lined pit,3 centralized pitsWaste StorageComposite samples1/week for first 3weeks, during week 6Flowback streamLiquidComposite49 | Page 

### Table 4 : Water and Waste Stream Parameters

Parameter Preserva tive MDL (mg/L) Method EPA MCL (mg/L unless noted) Lab Inorganics Silver HNO 3 0.001 EPA E 200.7 0.1 mg/L, 2o REIC
Alk , Total None 1 EPA SM2320 B NA REIC Al uminum HNO 3 0.04 EPA E 200.7 0.05

- 0.2, 2o REIC

A rsenic HNO 3 0.007 EPA E 200.7 0.01 REIC Ba rium HNO 3 0. 0 02 EPA E 200.7 2 REIC Br omide None 0 .05 EPA E 300 .0 NA REIC Ca lcium HNO 3 0.05 EPA E 200.7 NA REIC C hloride None 0.1 EPA E 300 .0 250, 2o REIC Conductivity None NA EPA SM 2510 B NA REIC & Field C hromium HNO 3 0.001 EPA E 200.7 0.1 REIC Iron HNO 3 0. 0 1 EPA E 200.7 0.3, 2o REIC Mercury HNO 3 0.0001 EPA E245.1 0.002 REIC Magnesium HNO 3 0.05 EPA E 200.7 NA REIC M anganese HNO 3 0. 00 1 EPA E 200.7 0.05, 2o REIC

Sodium HNO 3 0.03 EPA E 200.7 NA REIC Ni ckel HNO 3 0.002 EPA E 200.7 NA REIC

pH None NA EPA SM4500

- H +

- B 6.5

- 8.5 REIC & Field
Lead HNO 3 0.003 EPA E 200.7 0.015 action level REIC Potassium HNO 3 0.03 EPA E 200.7 NA REIC

Nitrite H 2 SO 4 0.05 EPA 300 .0 1 REIC Nitrate H 2 SO 4 0.2 EPA 300 .0 10 REIC S ulfur HNO 3 0.05 EPA E 200.7 NA REIC Se lenium HNO 3 0.008 EPA E 200.7 0.05 REIC

Sulfate None 1 EPA E300.0 250, 2o REIC S trontium HNO 3 0. 00 1 EPA E 200.7 NA REIC Z inc HNO 3 0.003 EPA E 200.7 5, 2o REIC
Hardness None 1 EPA SM2340 B NA REIC

Carbonate − None 1 EPA SM 2320 B NA REIC

Bicarbonate None 1 EPA SM 2320 B NA REIC50 | Page Parameter Preserva tive MDL (mg/L) Method EPA MCL (mg/L unless noted) Lab Phosphate H 2 SO 4 0.02 EPA SM4500

- P BE NA REIC T otal D issolved

S olids None 5 EPA SM 2540 C 500 , 2o REIC T otal S uspended

S olids None 5 EPA SM 2540 D NA REIC Organics Methane None NA EPA OSW 3810 M NA REIC
Ethane None NA EPA OSW 3810 M NA REIC Propane None NA EPA SW 8260 B NA REIC T otal O rganic C arbon H 2 SO 4 0.2 EPA SM 5310 C Treatment technique REIC Chemical Oxygen Demand H 2 SO 4 4 EPA E410.4 NA REIC Oil & Grease HCl 2 EPA E1664 A NA REIC
BTEX HCl EPA SW8260 B B

- 0.005, T

- 1, E

- 0. 7, X

- 10 REIC Styrene HCl 0.38 EPA SW8260 B 0.1 REIC Tetrachloro

ethylene HCl 0.49 EPA SW8260 B 0.005 REIC Surfactants

(MBAS) None 0.1 EPA SM 5540 C 0.05, 2o REIC Petroleum Hydrocarbons None 0.25 EPA SW8015 NA REIC Radio
activity Gross Alpha (pH<2) HNO 3 NA EPA 900.0m 15 pCi/L Pace
Gross Beta (pH<2) HNO 3 NA EPA 900.0m 4 m R /yr Pace
Lead

- 210 (pH<2) HNO 3 NA EPA 901.1m NA Pace
Radium

- 226 (pH<2) HNO 3 NA EPA 901.1m * 5 pCi/L combined 226/228 Pace
Radium

- 228 (pH<2) HNO 3 NA EPA 901.1m * 5 pCi/L Combined 226/228 Pace Thorium

- 230,

- 228,

- 232 (pH<2) HNO 3 NA H A SL 300m NA Pace
Uranium

- 238, (pH<2) HNO 3 NA H A SL 300m 30 μg/L (238) Pace
Potassium

- 40 (pH<2) HNO 3 NA EPA 901.1m NA Pace
* For liquid samples, Radium

- 226 is EPA 903.1 and Radium

- 228 is EPA 904.0. 2° = secondary standards51 | Page 

### Sampling Sites Marcellus gas wells at the various stages of development were selected for this project. WVWRI researchers worked with state agencies and industry representatives to identify the gas well sites and obtain access to the drilling fluids, muds and cuttings, a nd the hydraulic fracturing and flowback waters. Eight different well sites were monitored as part of this study . R efer to Table
5 for site location information . A combination of the eight sites was used to capture all phases of drilling activity. More i nformation on each site is given in Appendix B

.

Table 5 : Sampling Site Locations

Site Sampling Date Sample County Sample Location Well Development Stage Impoundments (prior to conversion to pit)

SHL

- 1 IMP 6/7/12 Marshall Impoundment edge Freshwater SHL

– 2 IMP 6/7/12 Marshall Impoundment edge Freshwater SHL

– 3 IMP 6/7/12 Marshall Impoundment edge Freshwater MW

– 3 IMP 8/28/12 Wetzel Impoundment edge Freshwater Groundwater Monitoring SHL

– 2, MW

- 1 Dry Marshall Monitoring well Freshwater 11/1/12 Marshall Monitoring well After pit conversion SHL

– 2, MW

- 2 6/4/12 Marshall Monitoring well Freshwater 10/31/12 Marshall Monitoring well After pit conversion SHL

– 2 MW

- 3 6/4/12 Marshall Monitoring well Freshwater 10/31/12 Marshall Monitoring well After pit conversion SHL

– 2 MW

- 4 6/19/12 Marshall Monitoring well Freshwater 11/1/12 Marshall Monitoring well After pit conversion SHL

– 4 MW

– 1 6/4/12 Marshall Monitoring well Freshwater 10/31/12 Marshall Monitoring well After pit conversion SHL

– 4 MW

– 2 6/4/12 Marshall Monitoring well Freshwater 10/31/12 Marshall Monitoring well After pit conversion SHL

– 4 MW

- 3 6/4/12 Marshall Monitoring well Freshwater 10/31/12 Marshall Monitoring well After pit conversion SHL

– 3 MW

- 4 6/19/12 Marshall Monitoring well Freshwater 11/1/12 Marshall Monitoring well After pit conversion Hydraulic Fracturing (HF) HF Water (Waco Donna pad) 7/25/12 Marion Impoundment edge Make

- up water
Comb HF (Waco Donna pad) 7/25/12 Marion Blender sample port Combination make

- up water and fracturing52 | Page Site Sampling Date Sample County Sample Location Well Development Stage chemicals HF Water (Maury pad) 9/11/12 Wetzel Holding tank Make

- up water

Comb. HF (Maury pad) 9/11/12 Wetzel After blender Combination make

- up water and fracturing che micals Vertical Drilling
ST 1

- 1 liquid (Lem ons pad) 8/8/12 Wetzel Shaker Table Vertical Drilling ST 1

- 1 solid (Lem ons pad) 8/8/12 Wetzel Shaker Table Vertical Drilling ST 1

- 2 liquid (Lem ons pad) 8/15/12 Wetzel Shaker Table Vertical Drilling ST 1

- 2 solid (Lem ons pad) 8/15/12 Wetzel Shaker Table Vertical Drilling ST 1

- 3 (Lem ons pad) 8/15/12 Wetzel Shaker Table Vertical Drilling ST 1

- 3 solid (Le mons pad) 8/15/12 Wetzel Shaker Table Vertical Drilling ST 1

- 4 (Lemo ns pad) 10/2/12 Wetzel Shaker Table Vertical Drilling ST 1

- 4 solid (Le mons pad) 10/2/12 Wetzel Shaker Table Vertical Drilling ST 2 liquids (Mills Wetzel 2 pad) 8/8/12 Wetzel Shaker Table Vertical Drilling ST 2 solids (Mills Wetzel 2 pad) 8/8/12 Wetzel Shaker Table Vertical Drilling DNR ST 3

- 1

- L 10/25/12 Brooke Shaker Table Vertical Drilling DNR ST 3

- 1

- S 10/25/12 Brooke Shaker Table Vertical Drilling Waste Storage/Flowback Stream FS

– 1 (Waco Donna pad) 7/27/12 Marion Condensate Tank Flowback FS

– 2 (Waco Donna pad) 8/2/12 Marion Condensate Tank Flowback FS

– 3 (Waco Donna pad) 8/9/12 Marion Condensate Tank Flowback FS

– Final (Waco Donna pad) 8/30/12 Marion Condensate Tank Flowback Donna Pit C (Waco Donna pad) 8/30/12 Marion Condensate Tank Waste Storage FS

– 1

– SHL

- 3 8/13/12 Brooke Impoundment Edge Waste Storage FS

– 2

– SHL

- 3 8/20/12 Brooke Impoundment Edge Waste Storage FS

– 3

– SHL

- 3 8/28/12 Brooke Impoundment Edge Waste Storage FS

– Final

– SHL

- 3 9/17/12 Brooke Impoundment Edge Waste Storage

SHL

– 4

– Comp 9/17/12 Brooke Impoundment Edge Waste Storage

Weekl e y

– FS

– 1 8/15/12 Wetzel Separator before disposal tank Flowback

Weekl e y

– FS

– 2 8/20/12 Wetzel Separator before disposal tank Flowback

Maury

– FS

– 1 10/2/12 Wetzel Separator before disposal tank Flowback53 | Page 

### Sampling occurred for each stage of drilling activity at the following sites: Water Storage (Impoundment) 1. Consol/Noble Centralized Impoundments, Impoundments SHL

- 3 and SHL

- 2 (sampled 6/7/2012) 2. Mills Wetzel Pad #3

- Stone Energy (sampled 8/28/2012) Figure 1 is a map of the three Consol/Noble centralized impoundments

- to

- pits with incorporated
coordinates. Figures 2 and 3 illustrate initial sampling ac tivities of the impoundments.54 | Page 

### Figure 1 : Centralized Pits Locations55 | Page 

### Figure 2 : SHL
- 1 Impoundment Sampling

Figure 3 : SHL
- 1 Impoundment Sampling56 | Page 

### Drilling wastes (vertical section) 1. Lemons Pad

– Stone Energy ( Sampled 8/8/2012, 8/15/2012, 8/22/2012, and 10/2/12 ) 2. WVDNR A Pad

– Chesapeake Energy (Sampled 10/25/12) Four samples of liquids and solids (muds and cuttings) generated during the vertical drilling phase of a horizontal well were collected from the Lemons Pad

– Stone Energy site. The last of these samples was taken while air monitoring equipment was in use on the site. The point of collection for both the liquid and solid samples at the Lemons Pad is illustrated in Figures 4 a nd
5 and Figure 6 shows a sample of t he drilling fluids. For the WV DNR A site, one sample of the produced drilling solids and liquids was collected. Sample collection at both sites was coordinated with the air monitoring team.

Figure 4 : Lemons Pad

– Shaker Table Liquids57 | Page 

### Figure 5 : Lemons Pad

– Shaker Table Solids

Figure 6 : Lemons Pad

– Vertical Drilling Fluids58 | Page 

### Drilling wastes (horizontal section) 1. Mills Wetzel Pad #2

– Stone Energy (sampled 8/8/2012, sampling attempted 8/20/2012, 8/22/2012 and 8/24/2012)

2. WVDNR A Pad

– Chesapeake Energy (Sampling not completed due to weather and operator finishing drilling early) One sample of the produced drilling l iquids and solids was collected from the Mills Wetzel Pad #2 site. However, this sample was not a “true” horizontal drilling sample as the operator was still drilling the curve in the borehole and was not yet in the Marcellus shale strata. Information on

t his sample can be found in the vertical drilling section of this study. Several attempts were made
to obtain additional s amples from the Mills Wetzel Pad #2 site . However, due to drilling malfunctions and scheduling issues, WVDEP and the WVU project team decided to forgo sampling at this site in order to sample water and air at additional sites during various well development stages. The shaker table where liquid and solids samples were collected is shown
in Figure 7.
Sample co llection was planned for the WV DNR A Pad site during the vertical drilling phase. However, due to a combination of the operator completing drilling more quickly than anticipated
and poor weather conditions, no sample was obtained.59 | Page 

### Figure 7 : Mills Wetzel Pad #2 Shaker Table (where samples were pulled)

Hydraulic Fracturing Fluids 1. Donna Pad

- Waco /ECA (sampled on 7/25/2012) 2. Maury Pad

– Stone Energy (sampled on 9/11/2012) Samples of the water used to mix with the hydraulic fracturing fluids ( makeup water) were taken from the Donna Pad storag e pit by using a swing sampler as shown in Figure 8 . Samples of the hydraulic fracturing fluids and water mixture were taken from the blender prior to entering the Donna Pad well. Hydraulic fracturing sampling a ctivities of well pad staff and the location of the sampling point are illustrated in Figures 9 and 10 . Sample collection was coordinated with the air monitoring team at each of the sites. Hydraulic fracturing samples were taken on 9/11/12 at the Maury P ad. The makeup water sample was retrieved from an on

- site holding tank and the hydraulic fracturing fluid sample was taken after the blender, prior to entering the Maury Pad well. Sampling at the Maury pad was coordinated with the air monitoring team.60 | Page 

### Fi gure 8 : Donna Pad Pit Sampling of Hydraulic Fracturing (Makeup) Water

Figure 9 : Sampling Hydraulic Fracturing Fluids and Water Mixture before Entering Well61 | Page 

### Figure 10 : Sampling Location of Hydraulic Fracturing Fluids

Flowback 1. Donna Pad

- WACO/ECA (sampled 7/27/2012, 8/2/2012, 8/9/2012 and 8/30/2012) 2. Weekley Site #1

- Stone Energy (sampled 8/15/2012 and 8/20/2012) 3. Consol/Noble Centralized Pits (SHL

- 3 and SHL

- 4) (sampled 8/13/2012, 8/20/2012, 8/28/2012 and 9/17/2012) 4. EQT Smithburg 28 (will be sampled after monitoring well completion) 5. Maury Site

– Stone Energy (sampled 10/2/12) For each site, a water sample of the fluid stream coming back up

- hole was collected at the onset of well flowback. Depending upon the site operations, up to three additional water samples of the fluid stream from the well were taken during flowback and produced water phases. The point of collection depended upon the site and operating procedures in place. These samples were collected prior to entering storage facilities or after being contained in storage facilities. A62 | Page 

### composite sample was taken near the end of the flowback sta ge from the storage facility on

- site (i.e., pit, container) at the same time the last flowback water sample was taken.
Flowback samples were collected at a condensate tank on the Donna Pad

– WACO/ECA as
shown in Figure 11

. Figure 12 shows the point

- of

- collection for the composite liquid and solids sample of flowback/produced water on the Donna Pad . This type of pit structure i s typical among the sites visited. Figure 13 is the sample area at the Weekl e y pad. The sample was taken from a separator. Figure 14 is the Sand Hill #3 and #4 pits. A composite sample was taken from
six different points (each corner and the middle of the long sides) in the pit from the Sand Hill #4 Pit (SHL

- 4). The six samples were combined into a composite sample, which was used to fill all sampling bottleware.63 | Page 

### Figure 11 : Flowback Sampling Point at Condensate Tanks, Donna Pad

Figure 12 : Composite Flowback Stream Sample at Donna Pad Single
- Lined Pit6 4 | Page 

### Figure 13 : Weekley Pad Sample Area

– Sample taken from the nozzle (see arrow)65 | Page 

### Figure 14 : Sample area at the Sand Hill # 3 and #4 (at lower right) Pits
Groundwater Monitoring 1. Consol/Noble Centralized Pits

– Sand Hill Location Pits SHL2, SHL3 and SHL4 (sampled 6/4/2012, 6/7/2012, 6/19/2012 (initial sampling) and 10/31/12 and 11/112 (final)) 2. EQT Smithburg 28 ( Monitoring wells were not drilled and completed in time for inclusion in this report. The results of these wells will be included in the Water and Waste Report, Phase II.

Please refer t o Table 6 and Figures 15, 16 and 17 for additional in formation concerning the groundwater monitoring wells relative to their depths and proximity to the storage pits.66 | Page 

### Table 6 : Groundwater Monitoring Wells at Consol/Noble Centralized Pits

Site Name Sample Date Location Relative to Pit Total Well Depth

(ft) Depth to Water

(ft) SHL
- 2, MW
- 1, Noble Pits 6/4/2012 up
- gradient 77.02 DRY SHL
- 2, MW
- 2, Noble Pits 6/4/2012 down

- gradient 47.61 28.38 SHL
- 2, MW
- 3, Noble Pits 6/4/2012 down

- gradient 56.98 44.77 SHL
- 2, MW
- 4, Noble Pits (deep) 6/19/2012 down

- gradient 43.7 26.1 SHL
- 3, MW
- 1, Noble Pits 6/4/2012 up
- gradient 63.70 DRY SHL
- 3, MW
- 2, Noble Pits 6/4/2012 down

- gradient 60.59 DRY SHL
- 3, MW
- 3, Noble Pits 6/4/2012 down

- gradient 61.83 DRY SHL
- 3, MW
- 4, Noble Pits (deep) 6/19/2012 down

- gradient 45.65 40.65 SHL
- 4, MW
- 1, Noble Pits 6/4/2012 up
- gradient 51.4 38.7 SHL
- 4, MW
- 2, Noble Pits 6/4/2012 down

- gradient 56.92 40.11 SHL
- 4, MW
- 3, Noble Pits 6/4/2012 down

- gradient 46.82 39.98 SHL
- 2, MW
- 1 Noble Pits 11/1/2012 up
- gradient 77.02 49.36 SHL
- 2, MW
- 2, Noble Pits 10/31/2012 down

- gradient 47.61 22.07 SHL
- 2, MW
- 3, Noble Pits 10/31/2012 down

- gradient 56.98 44.51 SHL
- 2, MW
- 4, Noble Pits (deep) 11/1/2012 down

- gradient 43.7 29.97 SHL
- 3, MW
- 1, Noble Pits 11/1/2012 up
- gradient 63.70 DRY SHL
- 3, MW
- 2, Noble Pits 11/1/2012 down

- gradient 60.59 DRY SHL
- 3, MW
- 3, Noble Pits 11/1/2012 down

- gradient 61.83 DRY SHL
- 3, MW
- 4, Noble Pits (deep) 11/1/2012 down

- gradient 45.65 39.46 SHL
- 4, MW
- 1, Noble Pits 10/31/2012 up
- gradient 51.4 22.22 SHL
- 4, MW
- 2, Noble Pits 10/31/2012 down

- gradient 56.92 39.24 SHL
- 4, MW
- 3, Noble Pits 10/31/2012 down

- gradient 46.82 28.19 Deep wells were installed a further distance downslope of the pits and are in a different aquifer. The location of SH L

- 3, MW

- 4 (a deep well) is down

- gradient from the SHL

- 3 pit as well.67 | Page 

### Figure 1 5 : Location of Consol/Noble Centralized Pits68 | Page 

### Figure 16 : Consol/Noble Centralized Pit SHL369 | Page 

### Figure 17 : Consol/Noble Centralized Pits SHL2 and SHL4
Sampling at the EQT Smithburg 28 pad is planned pending the completion of monitoring wells. Due to landowner issues, progress was delayed and EQT is in the process of obtaining approvals and permits to drill the groundwater monitoring wells.70 | Page 

### Various sam pling bottles needed for groundwater sampling collection are shown in Figure 1 8

. Sample collection is illustrated in Figure 1 9

. Groundwater monitoring well equipment used for
the l ow
- flow sampling method ( 5 1 ) is shown in Figure 20
.

Figure 18 : Bottles for Typical Groundwater Sample71 | Page 

### Figure 19 : Collection of Groundwater Sample from Consol/Noble Centralized Pit SHL272 | Page 

### Figure 20 : Low Flow Sampling at SHL3 Groundwater Monitoring Well


### Field Sampling Methods Refer to Table 3 for corresponding information for the sub

- sections below. Sample bottles were prepared by the commercial laboratory, REI Consultants (REIC), and provided to WVWRI researchers for use. An example of the REIC chain

- of

- custody form is attached as Appendix C

. The Pace Analytical chain

- of

- custody is attached as Appendix D

. Samples were stored according to the various EPA analytical methods and pick

- ups were arranged with REIC and Pace Analytical to ensure analysis of samples within specified holding times.
General Equipment List 1. Decontamination materials
2. All sample containers
3. Cooler with ice73 | Page 

### 4. Photo

- Ionization Detector (PID)
5. GPS unit
6. Handheld radiation alert detector (Radiation Alert Inspector EXP)
7. Field notebook, calculator and field data sheets
8. Multi

- parameter water

- quality meter with accompanyi ng flow

- through cell ( YSI

- 556)
9. Calibration fluids
10. Health and safety plan and al l personal protective equipment
11. Five

- gallon buckets
12. Nitrile gloves
13. Tools a nd batteries for all equipment

Groundwater Monitoring 

### Specified Equipmen t List f or Groundwater Sampling 1. Electronic interface probe for determination of liquid prod ucts present and depth

- to

- water
2. Adjustable rate peristaltic pump and/or standard perfor mance PVC pump with controller
3. Teflon® and silicon tubing
4. Power source
5. Graduated c ylinder (flow measuring device)
6. Five

- gallon bucke t
7. Fifty

- five gallon drum for purge water
8. Activated carbon unit (purge water filtration device)74 | Page 

### Sampling Procedures for Groundwater Sampling Events Groundwater sampling proceeded from up

- gradient of the pit/impoundment to down

- gradient. Nitrile gloves were used during all sampling procedures and were changed between well locations to prevent sample contamination. Equipment that was not dedicated to a specific well was decontaminated using a mild detergent free of interfering residues between sampled wel ls

. This approaches follows EPA procedures for “Field Equipment Cleaning and Decontamination”
that can be found at http://www.epa.gov/epawaste/hazard/testmethods/faq/faqs_sampl.htm

. Water was tested for radioactivity using a radiation alert detector at both the onset of purging activities and post

- sampling activities. Duplicate samples were obtained for 10% of collecte d samples. Equipment blanks and/or field blanks were also used to ensure sample quality control. Sampling procedures were as follows:
1. The lock and cap were removed from the well casing and the headspace of the well was
monitored for volatile organic compo unds (VOC s) with a PID. PID data was recorded in
a field book.
2. The depth

- to

- water was measured from a marked reference point on the casing to the nearest 0.01 feet using the interface probe. The initial reading was confirmed by a second

measurement.
3. The total volume of water in the well casing was determined and recorded, along with all other appropriate data, including GPS location, date, time, and screened interval, in a
field book.
4. (For wells with depth

- to

- water 27 feet or less from the top of casing). Teflon® tubing was lowered to approximately the middle of the pre

- determined screened interval. Teflon® tubing was connected to the peristaltic pump using silicon tubing and the flow

through cell with multi

- meter was connected to the opposite side of the peristaltic pump.75 | Page 

### Teflon® tubing was attached to the exit point of the flow

- through cell and routed into a 5 gallon bucket to collect purge water. The pump was connected to a power source.
5. (For wells with depth

- to

- water greater than 27 feet from the top of casing). Teflon® tubing was connected to the standard performance PVC pump and slowly lowered to approximately the middle of the pre

- determined screened interval. The flow

- through cell
with multi

- meter was connected to the pump. Teflon® tubing was attac hed to the exit point of the flow

- through cell and routed into a five

- gallon bucket to collect purge water. The pump was connected to a power source.
6. Groundwater was pumped at a rate no greater than 0.5 liters per minute. Water

- quality readings of pH, e lectrical conductance (EC), temperature (in degrees Celsius), total dissolved solids (TDS), oxidation Salinity (Sal), and dissolved oxygen (DO) were
recorded from the multi

- parameter meter after the flow

- through cell had been purged and
after a minimum of one tubing volume . Water

- level measurements were taken every 30
seconds to 5 minutes, which allowed the sampler to control the pumping rate. Water
drawdown did not exceed 0.33 feet.
7. Water quality data was recorded every 3 to 5 minutes, depending on pumping rate and water drawdown. Grab sampling commenced after stabilization of water quality parameters (three consecutive readings of all parameters within 10% of the previous reading).
8. Sample bottles were filled in the order of volatile organic compound bottles first, followed by semi

- volatile organic compounds, inorganics, and other unfiltered samples.76 | Page 

### 9. Samples were immediately cooled and prevented from exposure to sunlight by placing
them on ice in a d edicated sample cooler. A chain

- of

- custody was completed and all samples were shipped or delivered to the laboratory within specified hold ing times.
10. All appropriate equipment was decontaminated using a mild soap/water solution and all purge water was properly disposed of following proper EPA procedures for “Field Equipment Cleaning and Decontamination” that can be found at : 

### http://www.epa.gov/epawaste/hazard/testmethods/faq/faqs_sampl.htm

.

Water Sto rage for Well Development 

### Specified Equipment List for S ampling Freshwater Impoundments 1. Swing samplers (dippers)
2. Disposable bott les for use with swing samplers
3. Five

- g allon buckets
Sampling Procedur es for Freshwater Impoundments The sample locations selected were dependent on the availability of access to the impoundment as well as the safety and well

- being of the sampler. If possible, samples were taken from the inlet pipes. If the inlet pipes were not discharging water, samples were taken from the e dge of the impoundment near the inflow point. Grab samples were the method employed for the impoundments. Swing samplers and/or direct method sampling via five

- gallon buckets were used to obtain the sample. The following procedures were used during sample collection:

1. Sample locations were recorded using a GPS. A PID was used to check fo r background
off

- gassing of VOC s. The coordinates and PID data were recorded in a field book. A
handheld radiation alert detector was also used to check for background radiation levels,
and this data was also recorded in a field book.77 | Page 

### 2. A multi

- parameter water

- quality meter was used to determine water quality readings of pH, EC, temperature, TDS, salinity , and DO. One water quality reading was recorded during each sampling date due to limited impoundment access.
3. Samples were retrieved via the direct sampling method by using a swing sampler wit h a disposable bottle or a five

- gallon bucket. H andheld radiation alert detector , PID, a nd water quality readings were determined and recorded

. 4. If additional water was needed to fill all sample containers, a second sample was obtained using step 3.
5. Sample bottles were filled in the order of volatile organic compound bottles first,
followed by semi

- volatile organic compounds, inorganics, and other unfiltered samples.
6. Samples were immediately cooled and prevented from exposure to sunlight by placing them on ice in a dedicated sample cooler. A chain of custody was completed and all samples we re shipped or delivered to the laboratory within specified holding times.
7. All appropriate equipment was decontaminated after each use.

Moving Waste Stream 

### Specified Equipment List for Sampling Vertical Drilling Operation s 1. Se diment samplers (sludge judge)
2. Five

- gallon bucket
Sampling Procedures for Vertical Drilling Operations Drilling produced muds and cuttings were collected once per week for three weeks from a shaker
table and a final sample was taken six weeks after the third sample. Both liquid and sol id ph ase wastes were sampled. The WV DNR A site was only sampled once due to late inclusion into the study.78 | Page 

### Shaker Table Samples 1. Sample locations were recorded using a GPS. A PID was used to check for background
off

- gassing of VOC’s. The coordinates and PID data were recorded in a field book. A
handheld radiation alert detector was also used to check for background radiation levels,
and this data was also recorded in a field book.
2. A liquid grab sample was obtained using a swing sampler or five

- gallon bucket. Water quality, PID and radiation alert detector readings were taken and recorded.
3. Liquid samples were filled in the order of volatile organic compound bottles first, followed by semi

- volatile organic compounds, inorganics, and other unfiltered samples.
4. Solid samples were obtained using the grab sample method and placed in laboratory approved sample bottles. PID and radiation alert detector head space readings were taken
and recorded.
5. Samples were immediately cooled and prevented from exposure to sunlight by placing
them on ice in a d edicated sample cooler. A chain

- of

- c ust ody was completed and all samples were shipped or delivered to the laboratory within specified holding times.
6. All appropriate equipment was decontaminated after each use.
Pit Samples The pit samples were grab samples. Swing samplers and/or direct method sa mpling via five

gallon buckets were used. Sample locations were dependent on the accessibility of the pits and the safety and well

- being of the sample handler.

1. Sample locations were recorded using a GPS. A PID was used to check for background
off

- gassing of VOC’s. The coordinates and PID data were recorded in a field book. A
handheld radiation alert detector was also used to check for background radiation levels,
and this data was also recorded in a field book.79 | Page 

### 2. Due to site access issue s, swing samplers and/or a five

- gallon bucket were used to obtain the sample from the edge of the pit. Radiation alert detector , water quality, and PID readings were taken and recorded.
3. Step 2 was repeated (if needed) to obtain another sample and fill all sample bottles. A ll remaining water was properly disposed of.
4. Liquid samples were filled in the order of VOC bottles first, followed by semi

- volatile organic compounds, inorganics, and other unfiltered samples.
5. Using a sludge judge sediment sampler, a solid sample was c ollected from the bottom of a pit at the same location as the liquid sample and placed in laboratory

- approved sample bottles. The solid sample was collected from one point; however, this sample approximated a composite sample, as all of the wells flowed in to the pit. PID and
radiation alert detector head space readings were also recorded from the sludge sample.
6. Sample bottles were filled in the order of VOC bottles first, followed by semi

- volatile organic compounds and inorganics.
7. Samples were immediately cooled and prevented from exposure to sunlight by placing them on ice in a dedicated sample c ooler. A chain

- of

- custody was completed and all samples were shipped or delivered to the laboratory within established holding times.
8. All appropriate equipment was decontaminated after each use.
Sampling Procedures for Horizontal Drilling Operations The sampling procedures for horizontal drilling operations followed the same direct methods as the vertical drilling operations.
Sampling Procedures for Hydraulic Frac turing Hydraulic fracturing fluid (chemical mixture only) was not sampled because a sample could not be obtained immediately after the individual chemicals were mixed together. The chemicals were80 | Page 

### mixed with water before a sample could be obtained. Hydra ulic fracturing water ( makeup water) was sampled once from a pit (Donna site) and once from a tank (Maury site). Methods from the “sampling procedures for freshwater impoundments” listed above were followed for the pit sample. The tank s ample was obtained using a five

- gallon bucket. Water quality, radioactivity, and VOC readings were monitored and recorded in a field book at each site.
The combined hydraulic fracturing fluid and freshwater mixture was sampled once. The sample
was obtained in a five

- gallon bucket from a sampling port on the blender truck. Water quality, radioactivity, and VOC readings were monitored and recorded in a field book. All methods for sampling during hydraulic fracturing operations (such as filling bottle ware, sample handling,
and decontamination) followed proper methods and protocols as aforementioned in this
document.

Waste Storage 

### Flowback Stream The flowback stream was sampled at various locations during the well production and development process. Sample location was dependent upon site accessibility. Methods ranged from obtaining grab samples at a pit to sampling ports on separators and condensate tanks. All methods for sampling the waste storage (such as filling bottle ware, sample handling, and decontamination) fol lowed proper methods and protocols as aforementioned in this document.


### Analytical Methods Standard operating procedures are designed to optimize the accuracy and representativeness of water chemistry data. WVWRI technicians have been certified for sample collection following EPA standard methods and procedures. Guidelines were followed for sample preparation, collection, packaging and transport to maintain the integrity of the samples. Proper chain

- of

custody requirements were adhered to.81 | Page 

### Organics and Inorganics Samples were stored as required by the various EPA analytical methods and pick

- ups arranged with the certified laboratory, REIC Consultants, within specified holding times. An example of
the chain

- of

- custody form used by REI Consultants is atta ched as Appendix C . All sample analyses and laboratory activities were performed based on REI Consultants standard operating procedures and EPA sampling and analyses protocols. Table 7 provides an overview of REI Consultants quality assurance and quality control (QA/QC) procedures. This information is excerpted from the REI Consultants Quality Manual ( 5 2 ). QC is specifically spelled out in the individual standard operating procedures (SOPs) for each analytical test. This table is an overview of QC samp les that were included and/or required for the various analytical tests. REI Consultants were responsible for the regular instrumentation maintenance and quality checks required of a certified laboratory. WVWRI was responsible for the regular maintenance , quality checks and calibrations of field sampling and monitoring equipment.
Radioactivity Samples were stored as required by the various EPA analytical methods and pick

- ups arranged with the certified laboratory, Pace Analytical, within specified holding times. An example of the
chain

- of

- custody form used by Pace Analytical is attached as Appendix D . All sample analyses and laboratory activities were performed based on Pace Analytical SOPs and EPA sampling and analyses protocols. Ta ble 8 provides an ov erview of Pace Analytical quality assurance and quality control (QA/QC) procedures. This information is excerpted from the Pace Analytical Quality Manual ( 5 3 ). QC is specifically sp elled out in the individual SOPs for each analytical
test. This table is an overview of QC samples that were included and/or required for the various analytical tests. Pace Analytical was responsible for the regular instrumentation maintenance82 | Page 

### and quality checks required of a certified laboratory. WVWRI was responsible for t he regular maintenance, quality checks and calibrations of field sampling and monitoring equipment.

Table 7 : REI Consultants

– Inorganic and Organic Data Check Inorganic Data Checks Organics Data Check Sample Chain of Custody (COC) Sample Chain of Custody (COC) Extraction & Analysis sample holding times Extraction & Analysis sample holding times Calibration: Initial Calibration

• Initial Calibration Verification (ICV) Continuing Calibration Verification (CCV)

• Initial Calibrat ion Verification Blanks

• Continuing Calibration Verification (CCV) Surrogate Recoveries Blanks Duplicate Samples Laboratory Control Spike (LCS) Matrix Spike (MS)/Matrix Spike Duplicate (MSD) Quality Control Spike (QCS) Sample Internal Standard Performance Duplicate (DUP) Sample Compound Identification Matrix Spike (MS) Sample Compound Quantitation and Reporting Limits Field Duplicates System Performance Method Specific QC Field Duplicates Overall Assessment Equipment Blanks Chromatogram Retention Times Mass Spectrometer Tuning Criteria Compliance Method Specific QC Overall Assessment83 | Page 

### Table 8 : Pace Analytical

– Radioactivity Data Check Radioactivity Data Checks Blanks Method Blank Laboratory Control Sample (LCS) Matrix Spike/Matrix Spike Duplicate (MS/MSD) Sample Duplicates Surrogates

Internal Standards Field Blanks Trip Blanks



### Data Management Routine data related to the collection of samples was recorded during each site visit. Data was
written in field record books and transferred to an electronic data file located on the WVWRI shared server once field technicians returned to the office. Times, dates and personnel involved
in data collection were also recorded in field record books and transferred to the electronic data file. Copies of chain

- of

- custody forms for each set of samples sent to REI Consultants and Pace Analytical were scanned and included as part of the electronic data file. Other data regarding sampling methods or other p ertinent information regarding visits and well development was recorded in field record books. As needed, the data transferred to the electronic data file was reviewed and reported to the WVDEP as part of the monthly progress updates. Photographs

were us ed to assist with documenting field activities and conditions. Data collected in the field and analytical results obtained from REI Consultants and Pace Analytical were reviewed after
each site visit and upon receipt from the respective laboratories . Any measurements (parameter, concentration) above environmental water quality standards were noted and potential causes were investigated. Potential outliers of data were revi ewed as well. Outliers include unexplained spikes in data or unexplained zero/nega tive readings.84 | Page 

### Reference of field and analytical laboratory results to other commercial and industrial activities were made as a basis for comparison and understanding of horizontal gas well development impacts on the surrounding environment. Based on the data analysis, potential health concerns
or risks associated with the well development occurring at that site were noted and are included as part of the Results section of this report . Long

- term monitoring recommendations are included as part of the fina l report to WVDEP as well

.85 | Page 

## Data Analysis, Results and Comparison with Water Quality Standards The study sought to :
1. Characterize drilling muds and cuttings and identify pollutants.
2. Compare hydraulic fracturing fluids with flowback and identify pollutants

. 3. Identify whether the groundwater monitoring wells indicate contamination of surrounding groundwater as a result of impoundment leakage.
In the following analysis all determinations below the detection limit were assigned a value of

zero.



### Dri lling Muds and Cuttings Characterization and Pollutant Identification Drilling muds were analyzed as liquids while drill cuttings were analyzed as solids. With the exception of arsenic, mercury, nitrate and selenium, the average concentrations of the prim ary and secondary drinking water parameters in dri lling mud were in excess of all of the inorganic drinking water standards as shown in Table 9 . They also exceeded the drinking water standard for benzene and surfactant (MBAS) as illustrated in Table 10 . Drilling muds contained very high concentrations of sodium , potassium and chloride . TPH (diesel range) was present in all drilling muds. Concentrations ranged from 23 to 315 mg/L.
Air monitoring requirements, with respect to the Occupational Safety and Health Administration (OSHA), vary depending according to materials and exposures. Monitoring was based on the requirements of Hazardous Waste Operations and Emergency Response Regulations (29 CFR 1910.120(h)) and the United States Environmental Prote ction Agency Standard Operating Safety Guide (Publication 9285.1

- 03). Nearly all drilling mud and drill cutting samples were higher than background with regard to radioactivity. The relation between these field readings and regulatory s tandards is not ev ident as shown in Table 11

. Radiation monitoring was conducted86 | Page 

### utilizing an Inspector EXP Geiger Mueller with an external pancake probe. The Inspector EXP is capable of detecting alpha, beta and gamma radiation as required by the previously referenced

re gulations. The meter determined background levels of radiatio n in milliroentgens per hour (mrem /hr). Further, samples were screened for potential radioactivity for possible worker exposure and compared to background levels. Alpha, beta and gamma radiati on were included in background determinations since readings were taken in the open air. However, readings from the samples in containers would most likely only represent gamma radiation since alpha and beta typically cannot escape the sample container.

R adioactivity readings were obtained for 46 of the 51 samples obtained. Background levels o f radiation ranged from 0.005 mrem/hr to 0.022 mrem /hr. Sample levels of radiati on ranged from
0.007 mrem/hr to 0.018 mrem /hr. The standard for contamination is typically twice background. A review of the individual background levels of radiation indicated that criterion was not exceeded in any sample. One sample was exactly twice the background level of radiation for
that site but less than some of the other ba ckground levels from previous readings. The acceptable annual dose of radiation for individuals working with r adioactive materials is 5,000

mrem . Based on the readings obtained from the field instrumentation, appropriate sampling techniques and Pers onal Protective Equipment (PPE) would minimize exposure of sampling staff to radioactivity.

Table 12 includes radioactivity results received to date for drilling mud samples and one flowback solids sample

. In the absences of standards for semi

- solid to solid m aterials, the drinking water standard s for the radioactive parameters were used. Only the standard for gross alpha radiation was exceeded. According to EPA ( http://www.epa.gov/radiation/u nderstand/alpha.html ):87 | Page 

### The health effects of alpha particles depend heavily upon how exposure takes place. External exposure (external to the body) is of far less concern than internal exposure because alpha particles lack the energy to penetrate the outer dead layer of skin. However, if alpha emitters have been inhaled, ingested (swallowed), or absorbed into the blood stream, sensitive living tissue can be exposed to alpha radiation. The resulting biological damage increases the risk of cancer; in particular, alpha radiation is known to cause lung cancer in humans when alpha emitters are inhaled. The greatest exposure to alpha radiation for average citizens comes from the inhalation of radon and its decay products, several of which also emit potent alpha radiation.



### Hydrauli c F racturing F luids and F lowback Comparison and Pollutant Identification Three types of liquids used in the horizontal drilling and hydraulic fracturing processes were evaluated to determine if drinking water standards were exceeded: Makeup (MU) water co nsists of varying proportions of fresh water and recycled flowback water that is mixed with chemicals
to make hydraulic fracturing fluids (HFF) which are injected into the formation along with a proppant, and flowback (FB) is the fluid which returns via th e wellhead to the surface after hydraulic fracturing is complete.
Table 13 compares these fluids with regard to their drinking water exceedances. All flowback samples exceeded drinking water standards for barium, chloride, iron, manganese, total dissolved solids and radium 226. Eighty

- percent of flowback samples exceeded drink ing water standards for gross alpha, beta and radium 228. The organic parameters benzene, toluene, MBAS and styrene exceeded drinking water standards at rates of 77, 23, 15 and 8%, respectively. Selenium exceeded the drinking water standard in 23% of f lowback samples while chromium and lead exceeded their drinking water standards in 8% of the flowback samples. Overall, drinking water standards were exceeded for eighteen parameters in the flowback samples. Six parameters in the hydraulic fracturing flu ids exceeded drinking water standards. The hydraulic fracturing fluids in this case consisted of diluted flowback which may explain the presence of contaminants such as barium, chloride, iron, manganese and benzene albeit in lower88 | Page 

### concentrations than foun d in flowback. The results suggest that many of the exceedances are the result of contaminants acquired while the fluids are in contact with the Marcellus Formation.
Four freshwater (makeup water) samples, two hydraulic fracturing fluids and thirteen flow back samples were analyzed. Water quality of water and waste streams deteriorated as gas well development stages progressed. The hydraulic fracturing fluid samples include d two of makeup water only and two of the fully formulated hydraulic fracturing wat er for injection. One hydraulic fracturing fluid sample contained benzene in measurable quantities while ten of thirteen flowback samples contained benzene in concentrations in excess of the primary drinking

wa ter standard of 5 μg/L.
Both hydraulic frac turing fluids, all of the drilling mud s and flowback samples contained detectable TPH ( diesel range ) ; but, there is no drinking water standard for TPH (diesel range)

. It is important to note, this determination, also known as diesel range organics (DRO) does not indicate that diesel is present. Rather, it indicates that hydrocarbons in the range of C11 to C28 are present. This could include diesel or common hydraulic fracturing fluid additives such as guar gum, an extract of the guar bean used to increase the viscosity of the hydraulic fracturing fluid to efficiently deliver the proppant into the formation.
Figu re 21 indicates that there is no correlation between ben zene and TPH (diesel range). It also indicates that for most of the flowback samples, benzene exceeded the primary drinking water standard. Only on e drilling mud sample and one hydraulic fracturing fluid sample contained
detectable benzene while all but one hydraulic fracturing fluid/ d rilling mud s sample contained detectable TPH (diesel range). This suggests that the source of benzene is likely in t he formation, rather than the hydraulic fracturing fluid. All flowback samples contained high ionic89 | Page 

### concen trations including sodium, chloride, bromide and barium. Table 9 summarizes the average values of the inorganic constituents and Table 10 summarizes the average organic
concentrations.
Flowback was tested for radioactivity. The SDWA lists four radioactivity parameters under its primary drinking water standards. Our results were compared with the applicable SDWA
standards

. Table 14 indicates that flowback water exceeded the SDWA standa rd with respect to alpha radiation and radium (226 and 228)

. 

### Impoundment I ntegrity The impoundments initially contained freshwater which was a mixture of Ohio River water and treated mine drainage. Water quality of the freshwater impoundment is indicated in Table 9 under the column labeled “FW impound.” It contained no constituents in excess of SDWA
limits. There was no evidence o f significant leakage of flowback from the impoundments.
Nitrate and lead were detected in monitoring wells in excess of primary drinking water standards. The concentration of nitrite exceeded the MCL (1 mg/L) in three of five shallow monitoring wells by a maximum of 0.47 mg/L. However, while nitrate exceeded the primary MCL in samples taken after conversion of the impoundments to accept flowback, the single lead exceedance occurred prior to conversion as shown in Table 9 . As is common in West Virginia wells, iron, aluminum and manganese exceed the secondary drinking water standard s in both shallow and deep wells before and after conversion of the impoundments from holding fresh
water to flowback ( 54 )

. After conversion to storage of flowback water, the groundwater monitoring wells around the ‘impoundments’ did not, however, indicate elevated chloride, bromide or barium concentrations as would be expected if flowback leakage occurred in significant quantities. In addition, while flowback contains measura ble benzene and TPH90 | Page 

### ( diesel ) , neither was detected in the monitoring wells . See Table 10

. One of the deep monitoring wells exceeded the primary drinking water level for gross alpha radiation. However, this occurred while the impoundment was holding fresh water . S ee Table 15

. Figure 22 illustrates the relationship between chloride and bromide appears to b e a good
indicator of flowback . All of the flowback samples were aligned along the high end of the
trendline while h ydraulic fracturing fluids (and their makeup water) were aligned along the lower end of the same curve indicating lower concentrations of both chloride and bromide. This is a log

- log graph and zero values cannot be plotted so coordinates with non

- detect levels of bromide

or chloride do not appear. While the chloride and bromide concentrati ons were high in drilling mud, its trendline d eviated from the flowback and hydraulic fracturing fluid trendlines mainly due to the higher chloride content of drilling mud relative to brom ide. This may be due to the common use of sodium chloride in drilling mud. In contrast, the water from the freshwater impoundments and their groundwater monitoring wells contained almost no bromide and little
chloride . Refer to the lower left hand corne r of F igure 22 . Samples of Monongahela River water from another study are included for comparison. They also appear in the lower left hand corner and the trendline is essentially horizontal. These results suggest that the high bromide
concentrations in flowback water are acquired by salt dissolution within the Marcellus formation

. The alignment of both hydraulic fracturing fluid and makeup water along the Bromide/Chloride (Br/Cl) trendline suggests that the makeup water includes some amount of recycled flowback.
Three centralized impoundments were sampled before and after they were converted from freshwater storage to flowback storage. In addition , their respective monitoring wells were sampled before and after the conversion. The barium/c hloride ( Ba/Cl ) ratios were plotted for impoundment water and the monitoring wells. Barium was used in this case because it is, like91 | Page 

### bromide, a good marker for flowback water. The Ba/Cl

- relationship clearly discriminated
between flowback and freshwater

. Figu re 2 3 shows the clustering of groundwater samples at the lower left corner of the figure along with the freshwater impoundment samples ( the three samples overlay each other). Flowback, on the other hand trends far to the upper right with much higher concentra tions of both barium and chloride. Note that the highest monitoring well values of both barium and chloride occurred when the impoundments were used for freshwater
storage. Only one of fourteen monitoring well samples exceeded a drinking water standard. That sample was for a deep monitoring well during the period when the impoundment was used for freshwater storage. The chloride concentration was 348 mg/L while bromide was below detect and barium was 0.28 mg/L

. The monitoring wells thus show ed no evidence of receiving leakage from the impoundments. Most significantly, no evidence of flowback leakage was detected in the impoundment monitoring

. While the monitoring wells detected no contaminants it is not clear that the monitoring interval of 1 46 days was sufficient to capture any leakage from the impoundments. A longer sampling is suggested with, perhaps, aquifer permeability testing.92 | Page 

### Table 9 : Average Concentrations of Inorganic Parameters

• Average concentrations of inorganic parameters tested in Summer and Fall of 2012

• Shaded cells indicate d rinking water standard exceeded.

• MDL=minimum detection limit

• DW=SDWA drinking water standard: a=primary b=secondary FW=freshwater

• MW=impoundment monitoring well: S=shallow , D=deep, FB=flowback, HF=hydraulic fracturing MDL units DW std MCL FW impound MWS FW MWS FB MWD FW MWD FB Drilling mud (vert sec) HF fluid FB As 0.007 mg/L a 0.01 0.00 0.00 0.00 0.00 0.00 0.92 0.00 0.00 Ba 0.002 mg/L a 2 0.05 0.08 0.08 0.58 0.26 12.81 5.70 514.68 Cr 0.001 mg/L a 0.1 0.00 0.00 0.00 0.04 0.00 2.60 0.00 0.03 Hg 0.0001 mg/L a 0.002 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Nitrate 0.02 mg/L a 10 0.03 0.37 1.07 0.07 0.13 3.18 0.00 0.02 Nitrite 0.05 mg/L a 1 0.15 0.09 1.10 0.04 0.00 4.90 0.00 0.06

Pb 0.003 mg/L a 0.015 0.00 0.00 0.00 0.02 0.00 1.15 0.00 0.01 Se 0.008 mg/L a 0.05 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.06
Ag 0.001 mg/L b 0.1 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Al 0.04 mg/L b 0.05 0.0 0.8 2.7 15.0 9.8 1208.0 0.1 1.4 Cl 0.1 mg/L b 250 22.8 2.8 5.9 181.7 5.7 14640.0 4712.3 42683.1 Fe 0.01 mg/L b 0.3 0.0 2.0 3.2 24.8 14.1 2192.0 9.1 67.1 Mn 0.001 mg/L b 0.05 0.0 0.2 0.1 2.2 1.5 22.3 0.6 5.5 pH mg/L b 6.5 7.01 6.66 6.47 6.83 7.20 9.24 7.17 6.61 SO4 1 mg/L b 250 62.2 28.2 28.8 41.6 33.6 1567.7 65.7 38.7 TDS 5 mg/L b 500 241.0 233.6 175.2 408.0 259.0 34550.0 9369.5 74710.8 Zn 0.003 mg/L b 5 0.0 0.0 0.0 0.1 0.1 5.9 0.5 0.1

Br 0.05 mg/L 0.06 0.00 0.00 0.05 0.00 22.50 54.60 465.96 Ca 0.05 mg/L 36.78 59.24 51.82 86.80 101.00 1842.50 528.75 7269.23 K 0.03 mg/L 2.54 1.69 2.25 6.12 6.10 8791.50 29.66 260.06 Mg 0.05 mg/L 6.96 12.68 9.16 18.40 25.80 394.71 68.69 835.00 Na 0.3 mg/L 20.47 4.68 7.08 13.00 10.01 2858.50 2202.50 26202.31 Ni 0.002 mg/L 0.00 0.00 0.00 0.03 0.03 2.19 0.00 0.00 S 0.05 mg/L 23.10 12.91 10.84 14.75 14.55 992.50 19.74 36.16 Sr 0.001 mg/L 0.20 0.23 0.17 0.42 0.44 40.15 62.63 1365.38

alk CO3 1 mg/L 109.78 203.20 103.88 199.00 210.50 1705.00 111.95 187.23 alk HCO3 1 mg/L 0.00 0.00 0.00 0.00 0.00 379.33 0.00 0.00 alk tot 1 mg/L 109.78 203.20 103.88 199.00 210.50 3127.50 111.95 187.23

EC NA μS/cm 428.75 382.60 302.00 762.00 470.00 59550.00 15680.00 107861.54 Hardness 1 mg/L 120.35 200.20 478.00 332.00 358.50 4973.33 1600.00 19588.15

PO4 0.02 mg/L 0.01 0.10 0.00 0.46 0.00 15.53 2.94 8.03 TSS 5 mg/L 2.00 170.20 110.17 2720.00 284.00 47300.00 118.25 211.8593 | Page 

### Table 10 : Average Concentrations of Organic Parameters

• Average concentrations of organic parameters testing in Summer and F all of 2012

• Shaded cells indicate d rinking water standard exceeded.

• MDL=minimum detection limit

• DW=SDWA drinking water standard: a=primary b=secondary FW=freshwater

• MW=impoundment monitoring well: S=shallow, D=deep, FB=flowback, HF=hydraulic fracturing MDL units DW std MCL FW impound MWS FW MWS FB MWD FW MWD FB Drilling mud (vert sec) HF fluid FB Benzene 0.42 μg/L a 5 0.00 0.00 0.00 0.00 0.00 40.25 7.35 149.59 Ethylbenze 0.43 μg/L a 700 0.00 0.00 0.00 0.00 0.00 9.55 2.18 52.52

Styrene 0.38 μg/L a 100 0.00 0.00 0.00 0.00 0.00 0.00 0.00 10.85 Toluene 0.42 μg/L a 1000 0.00 0.00 0.77 0.30 0.00 80.43 22.08 621.71 Xylene (m,p) 0.9 μg/L a 10000 0.00 0.00 0.00 0.00 0.00 87.50 41.00 698.71 Xylene (o) 0.41 μg/L a 10000 0.00 0.00 0.00 0.00 0.00 22.20 8.75 142.27

MBAS 0.1 mg/L b 0.5 0.08 0.00 0.00 0.00 0.00 67.68 0.00 0.19

COD 4 mg/L 14.25 0.00 0.00 0.00 7.00 5875.00 539.50 1420.08 Ethane NA μl/L 0.00 0.00 0.00 0.00 0.00 0.00 571.19 Methane NA μl/L 0.00 0.00 0.00 0.00 0.00 88.50 3420.48

O&G 2 mg/L 0.00 0.46 1.18 3.80 2.40 53.30 5.95 63.52 propane NA μg/L 0.00 0.00 0.00 0.00 0.00 0.00 0.00 86.92 Tetrachloroethene 0.49 μg/L 0.00 0.00 0.00 0.00 0.00 5.00 0.00 0.00 TOC 0.2 mg/L 2.51 0.58 1.70 0.34 1.22 2362.50 105.36 176.35 TPH (Diesel) 0.067 mg/L 0.00 0.00 0.00 0.00 0.00 130.23 38.71 60.56 TPH (Gas) 0.25 mg/L 0.00 0.00 0.00 0.00 0.00 3.85 1.58 25.75 TPH (Oil) 0.053 mg/L 0.08 0.00 0.00 0.00 0.00 98.45 3.27 10.2394 | Page 

### Table 11 : Field Radiation Readings for Drill Cuttings and Drilling Muds

Drill cuttings (solids) Drilling Mud (liquid) Mixture (slurry) Radioactivity (mrem /hr) Background Radioactivity (mrem /hr)

Sample
ST2 at 13:00 (solids) 0.008 0.009 ST1

- 1 at 11:00 (solids) 0.013 0.013 ST1

- 2 at 10:30 (solids) 0.011 0.016 ST1

- 3 at 11:00 (solid) 0.005 0.009 ST1

- 4 at 1:30 (solids) 0.008 0.015 ST1

- 1 at 11:00 (liquid) 0.013 0.013 ST1

- 2 at 10:30 (liquid) 0.011 0.016 ST1

- 3 at 11:00 (liquid) 0.005 0.009 ST1

- 4 at 1:30 (liquid) 0.008 0.009 ST2 a6t 13:00 (slurry) 0.008 0.009 The Inspector EXP displays current radiation levels in millir em per hour (mrem /hr) , where rem = roentgen equivalent man ( 55 ).



### • Radiation readings taken with handheld field alert detector

. • Shaded cells indicate that the sam ples exceeded background levels.95 | Page 

### Table 12 : Radioactivity Results of Drilling Muds and Flowback Solids Samples

• Shaded cells indicate SDWA MCL was exceeded.96 | Page 

### Table 13 : Exceeda nces of Drinking Water Standard s Horizontal Drilling and Hydraulic Fracturing Fluids

• makeup water (MU)

• hydraulic fracturing fluid (HFF)

• flowback (FB) Water Quality Parameters

• Inorganic (I)

• Organic (O)

• Radioactive (R) The latter determinations were only avai lable for five flowback samples.97 | Page 

### Table 14 : Summary of Radioactive Determinations from Flowback Liquids Samples

• Shaded cells indicate SDWA MCL was exceeded. reported MCL FB,FS-1 (SHL-3) FB,FS 2 (SHL-3) FB,FS-3 (SHL-3) FB,FS Final (SHL-3) FB,Comp. (SHL-4) parameter units MCL units 8/13/2012 8/20/2012 8/28/2012 9/17/2012 9/17/2012 Gross Alpha pCi/L 15 pCi/L 8.69 527 372 965 184 Gross Beta pCi/L 4 mr/yr 34 317 138 226 67.8 Lead-210 pCi/L -62.3 NR NR -46.4 -258 Radium-226 pCi/L 5 pCi/L 29.6 1,194 15.4 397 154 Radium-228 pCi/L 5 pCi/L 4.99 216 53.5 132 66.5 Thorium-228 pCi/L 2.35 0.3 0.595 2.24 0.952 Thorium-230 pCi/L 0.411 9.37 0.846 0 0.032 Thorium-232 pCi/L 0.375 -0.008 0 -0.009 0.006 Uranium-238 pCi/L 30 μg/L 1.22 -0.022 0.356 0.097 0.042 Potassium-40 pCi/L 52.8 221 -11.596 6.82 43.298 | Page 

### Table 15 : Summary of Radioactive Determinations from Groundwater Monitoring Wells

• Shaded cells indicate SDWA MCL was exceeded.

• Radioactive results from flowback samples are included for comparison purposes. SDWA MCL SHL-2, MW-2, SHL-2, MW-3, SHL-4, MW-1, SHL-4, MW-2, SHL-4, MW-3, Liquids units MCL units 6/4/2012 6/4/2012 6/4/2012 6/4/2012 6/4/2012 average Gross Alpha pCi/L 15 pCi/L 1.14 -0.253 3.17 0.214 1.08 1.07 Gross Beta pCi/L 50 pCi/L 1.8 0.715 3.32 0.649 1.82 1.66 Lead-210 pCi/L 216 -54.4 334 512 746 351 Radium-226 pCi/L 5 pCi/L 0.646 0.0553 0.229 0.167 0.411 0.30 Radium-228 pCi/L 5 pCi/L 0.637 0.407 0.835 0.283 0.748 0.58 Thorium-228 pCi/L 0.142 0.008 0.538 0.223 -0.023 0.18 Thorium-230 pCi/L -0.029 -0.003 0.29 0.01 0.008 0.06 Thorium-232 pCi/L 0.17 0.006 0.506 0.069 -0.01 0.15 Uranium-238 pCi/L 30 μg/L 0.456 0.19 0.53 0.441 0.531 0.43 Uranium-238 μg/L 30 μg/L 0.68 0.28 0.79 0.66 0.79 0.64 Potassium-40 pCi/L -1.36 -6.23 -32.5 -25.2 -30.8 -19.22

SDWA MCL SHL-2-MW-4, SHL-3-MW-4, Liquids units MCL units 6/19/2012 6/19/2012 average Gross Alpha pCi/L 15 pCi/L 37.8 11.6 24.7 Gross Beta pCi/L 50 pCi/L 18.6 6.73 12.665 Lead-210 pCi/L -1,170 -1,050 -1,110 Radium-226 pCi/L 5 pCi/L 2.82 4.74 3.78 Radium-228 pCi/L 5 pCi/L 0.466 0.679 0.5725 Thorium-228 pCi/L 0.485 1.02 0.7525 Thorium-230 pCi/L 0.029 0.133 0.081 Thorium-232 pCi/L 0.226 0.521 0.3735 Uranium-238 pCi/L 30 μg/L 0.197 0.659 0.428 Uranium-238 μg/L 30 μg/L 0.29 0.98 0.64 Potassium-40 pCi/L 13.2 105 59.1

SDWA MCL FS 2, Noble Pits (SHL-3) FS-3, Noble Pits (SHL-3) FS Final, Noble Pits (SHL-3) SHL-4 Composite,Noble Pits (SHLFS-1, Weekly Pad Liquids units MCL units 8/20/2012 8/28/2012 9/17/2012 9/17/2012 8/15/2012 average Gross Alpha pCi/L 15 pCi/L 8.69 527 372 965 184 411.338 Gross Beta pCi/L 50 pCi/L 34 317 138 226 67.8 156.56 Lead-210 pCi/L -62.3 NR NR -46.4 -258 -122.233333 Radium-226 pCi/L 5 pCi/L 29.6 1,194 15.4 397 154 358 Radium-228 pCi/L 5 pCi/L 4.99 216 53.5 132 66.5 94.598 Thorium-228 pCi/L 2.35 0.3 0.595 2.24 0.952 1.2874 Thorium-230 pCi/L 0.411 9.37 0.846 0 0.032 2.1318 Thorium-232 pCi/L 0.375 -0.008 0 -0.009 0.006 0.0728 Uranium-238 pCi/L 30 μg/L 1.22 -0.022 0.356 0.097 0.042 0.3386 Uranium-238 μg/L 30 μg/L 1.82 -0.03 0.53 0.14 0.06 0.51 Potassium-40 pCi/L 52.8 221 -11.596 6.82 43.2 62.4448 MW (shallow)

flowback MW (deep)99 | Page 

### Figure 21 : Relationship between TPH and Benzene

• The relationship between TPH (diesel range) and benzene is plotted for all samples.

• Note this is a log

- log plot and zero (non

- detect) values are not plotted.

• The red, horizontal line is the primary drinking water limit for benzene.100 | Page 

### Figure 22 : Relationship of Chloride and Bromide in Source Waters

• All samples were plotted on chloride/bromide axes to determine the orientation of the various source waters.

• Note this is a log

- log plot and zero (non

- detect) values are not plotted.

• Trendlines are included along with their models and correlation co efficients.101 | Page 

### Figure 23 : Barium/Chloride (Ba/Cl) Relationship in Impoundment Water and Groundwater

• Groundwater was monitored at three centralized impoundments at the Noble Site. All were converted from freshwater (FW) to flowback (FB) storage during the study.

• The figure shows the Ba/Cl ratios of the impoundment waters, the monitoring well shallow (MWS) and monitoring well deep (MWD) monitoring wells before and after the conversion.

• The blue, horizontal line is the p rimary drinking water limit for barium and the red, vertical line is the secondary drinking water limit for chloride.102 | Page 

### Identification of Potential Health Concerns and Recommendations
Three types of water and one solid waste were studied:

• Flowback water

• Drilling mud s

• Hydraulic fracturing fluid s

• Drill cuttings Flowback, drilling muds and hydraulic fracturing fluids all exceeded SDWA limits to varying degrees. The extent to which they are properly and safely handled will determine the degree of
huma n exposure via drinking water

. An attempt to prioritize the potential for human exposure via groundwater contamination is reflected in Table 16

. Transported volume and liquid/solid rankings are binomial. It is assumed that exposure increases with volume, particularly to the
extent that the material is transported off

- site. Liquid contamin ants are simply more mobile than any of the solid materia ls in this study and therefore pose a greater exposure risk.

Table 16 : Groundwater Exposure to Shale Gas Waste Streams

Some materials could not be sampled and are marked ND for not determined. Table 16 is not complete as not all of the materials could be sampled within the timeframe of project. With that qualification, flowback yields the highest exposure since : i t is a liquid; it is transported off site; it103 | Page 

### has multiple toxicities and it i s produced i n high volume. Hydraulic fracturing fluid is not as
toxic as flowbac k and it is usually prepared on

- site, minimizing transportation risk. It may be spilled on t he drill pad through accident or during a blowout. P roper lining and containment on

site, h owever, would minimize exposure to g roundwater. Both flowback and hydraulic fracturing fluid may escape the wellbore if it is not installed and cemented. The risk of migration of these fluids from the target formation to drinking water, considering the d istance is remote but not absent. Care must be taken to avoid faults and old gas wells that may conduct th ese fluids to potable aquifers. Drilling mud exceeded the primary and secondary SDWA standards more than the previous two
materials but its volume i s much lower than flowback or hydraulic fracturing fluid. While drill cuttings will contain contaminants, the volume is generally such t hat they are easily isolated on

site and taken to landfills for disposal. Therefore, their exposure risk is low if prop erly handled. For example, storage of flowback in large impoundments resulted in no evidence of leakage. This is of particular interest since the impoundment geotechnical study which is part of this effort identified several design and construction flaws in impoundment construction. That no flowback leakage was detected suggest s that the designs are robust. This project has significantly improved knowledge of the human health risks associated with shale gas development. As a result , diagnostic tools such as the Br/Cl and Ba/Cl ratios for identifying flowback contamination have been developed

. Flowback was identified as the primary waste stream of concern. Practices that prevent environmental and human health exposures are critical. The following a r e recommended:

• Ensure the integrity of the handling chain for each of the waste streams, identify the weak points and focus the inspectors’ attention to those areas.

• Ensure the integrity of wellbore s and cement.104 | Page 

### Future research should focus on fill ing out the remainder of Table 16 . In addition, while the scope of this project is limited to the well development and completion stages of shale gas extraction, future work regarding chemical exposures at the producing well sites is needed to supplement this work

.105 | Page 

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3. Modern Shale Gas Development in the United States: A Primer; Ground Water Protection Council and ALL Consulting; Department of Energy Office of Fos sil Energy DE

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– Water Resource Challenges; R. Timothy Weston K&L Gates; 2008.

5. Hydraulic Fracturing Considerations for Natural Gas Wells of the Marcellus Shale ; Daniel Arthur, Brian Bohm and M ark Layne, ALL Consulting; The Ground Water Protection Council 2008 Annual Forum; 2008.

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.
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8. The Real Facts about Fracture Stimulation: The Technology Behind America’s New Natural Gas Supplies; American Exploration & Production Council; January 2010.

9. Marcellus Shale W ater Management Challenges in Pennsylvania; A.W. Gaudlip and L.O. Paugh, SPE, Range Resources Appalachia LLC, and T.D. Hayes, Gas Technology Institute, Society of Petroleum Engineers; SPE 119898; 2008 SPE Shale Gas Production Conference; November 2008.

10. Wa ter Resources and Use for Hydraulic Fracturing in the Marcellus Shale Region; J. Daniel Arthur, Mike Uretsky and Preston Wilson, ALL Consulting; 2010.106 | Page 

### 11. Natural Gas Plays in the Marcellus Shale: Challenges and Potential Opportunities; David Kargbo, Ron Wilhelm and David Campbell; USEPA; Environmental Science & Technology ; Volume 44; Number 2010.

12. Treatment of Abandoned Mine Drainage for Use as Marcellus Ga s Well Hydrofracture Makeup Water; ProChem Tech, International, Inc.; www.prochemtech.com ; 2009.

13. Sampling and Analysis of Water Streams Associated with the Development of Marcellus Shale Gas Final Report; Thomas Hayes, Gas Technology Institute; for Marcellus Shale Coalition; December 2009.

14. Radioactivity in Marcellus Shale Report prepared for Residents for the Preservation of Lowman and Chemung (RFPLC); Marvin Resnikoff, Ekaterina Alexandrova and Jackie Travers, R adioactive Waste Management Associates; May 2010.

15. Waste Management of Cuttings, Drilling Fluids, Hydrofrack Water and Produced Water; New York State Water Resources Institute; www.wri.eas .cornell.edu/gas_wells_waste.html

.
16. America’s New Energy Future: The Unconventional Oil and Gas Revolution and the U.S. Economy Volume 1: National Economic Contributions; An IHS Report; October 2012.

17. Water Management Technologies Used by Marcellus Shale G as Producers Final Report; John Veil, Argonne National Laboratory; Department of Energy Office of Fossil Energy FWP

- 49462; July 2010.

18. Data Confirm Safety of Well Fracturing; Kevin Fisher, The American Oil & Gas Reporter, www.aogr,com ; July 2010.

19. Chemicals Used in Hydraulic Fracturing; for U.S. House of Representatives Committee on Energy & Commerce Minority Staff; April 2011.

20. ‘Environmentally Friendly’ No Longer an Oxymoron to Oil and Gas; Tayvis Dunnahoe, Hydraulic Fr acturing ; www.EPmag.com ; August 2012.

21. Marcellus Shale in West Virginia: Hydraulic Fracturing Chart; WVONGA 2012.

22. A Fluid Situation: Typical Solution Used in Hydraulic Fracturing; www.energyindepth.org

.107 | Page 

### 23. Hydraulic Fracturing Fluids

– Composition and Additives; www.geology.com ; republished from: Modern Shale Gas Development in the United States by the Department of Energy; 2009.

24. Critical Evaluations of Additives Used in Shale Slickwater Fracs; P. Kaufman and G.S. Penny, CESI Chemical a Flotek Co., and J. Paktinat, Universal Well Services; Inc. SPE 119900; 2008 SPE Shale Gas Production Conference; November 2008.

25. Radiological Survey Report : Marcellus Shale Drilling Cuttings; CoPhysics Corporation; April 2010.

26. Marcellus Shale Potential Public Health Concerns Correspondence and Supplemental Reports: Supplemental Generic Environmental Impact Statement on the Oil & Gas Regulatory Program

– Well Permit Issuance for Horizontal Drilling and High

- Volume Hydraulic Fracturing to Develop the Marcellus Shale and other Low

- Permeability Gas Reservoirs; State of New York Department of Health; July 2009.

27. Incidental TENORM: A Guidance for State Solid Wa ste Managers; Association of State and Territorial Solid Waste Management Officials; April 2011.

28. Radiation Sources in Natural Gas Well Activities; Gayle Nicoll, Occupational Health & Safety Online; http://ohs online.com/articles/

. 29. Evaluating the Environmental Implications of Hydraulic Fracturing in Shale Gas Reservoirs; J. Daniel Arthur, Brian Bohm, Bobbi Jo Coughlin and Mark Layne, ALL Consulting; 2008.

30. NORM Survey Summary; IOGA News; April 1995.

31. Regulator y Issues in the US, Nancy Sauer; Hydraulic Fracturing ; www.EPmag.com ; August 2012.

32. Methane Contamination of Drinking Water Accompanying Gas

- Well Drilling and Hydraulic Fracturing; Stephen Osborn, Avner Vengosh, Nathaniel Warner and Robert Jackson, Duke University, Durham, North Carolina; www.pnas.org/cgi/doi/10.1073/pnas.1100682108 ; PNAS Early Edition 2011.

33. Hydraulic Fracturing and Safe Drinking Water Act Issues; Mary Tiemann and Adam Vann, Congressional Research Service;7

- 5700; www.crs .gov ; R41760; July 2012.108 | Page 

### 34. The Impact of Marcellus Gas Drilling on Rural Drinking Water Supplies; Elizabeth Boyer, Bryan Swistock, James Clark, Mark Madden and Dana Rizzo, Pennsylvania State University; for The Center for Rural Pennsylvania; March 2012.

35. Hy draulic Fracturing & Water Resources: Separating the Frack from the Fiction; Heather Cooley and Kristina Donnelly, Pacific Institute; June 2012.

36. Hydraulic Fracturing or ‘Fracking’: A Short Summary of Current Knowledge and Potential Environmental Impacts; Dave Healy, University of Aberdeen; Aberdeen, United Kingdom; May 2012.

37. OIL AND GAS: Information on Shale Resources, Development and Environmental and Public Health Risks; United States Government Accounting Office Report to Congressional Requestors; Sept ember 2012.

38. Addressing the Environmental Risks from Shale Gas Development

– Briefing Paper 1; Mark Zoback, Stanford University, Saya Kitasei, WorldWatch Institute, and Brad Copithorne, Environmental Defense Fund; WorldWatch Institute Natural Gas and Susta inable Energy Institute; July 2010.

39. In Fracking’s Wake: New Rules are needed to Protect Our Health and Environment from Contaminated Wastewater; Rebecca Hammer, Natural Resource Defense Council, Jeanne VanBriesen, Carnegie Mellon University and Larry Levi ne, Natural Resource Defense Council; NRDC Issue Brief, 1B:12

- 05

- A, May 2012.

40. Land Application of Hydrofracturing Fluids Damages a Deciduous Forest Stand in West Virginia; Mary Beth Adams, USDA Forest Service; Journal of Environmental Quality , Volume 40, July/August 2011.

41. Water Management Essential in Hydraulic Fracturing; Jerry Greenberg; Hydraulic Fracturing , www.EPmag.com ; August 2012.

42. How to Remove Radioactive Iodine

- 131 From Drinking Water; Jeff McMahon, Forbes; www.forbes.com ; April 2011.

43. Local Limits Development Guidance Appendices; USEPA; EPA 833

- R

- 04

- 002B; July 2004.109 | Page 

### 44. Pa.: Marcellus wastewater shouldn’t go to treatment plants; Don Hopey and Sean Hamill, Pittsburgh Post

- Ga zette; http://www.post

- gazette.com/sotires/local/breaking/ ; March 2012.

45. Disposal of Produced Water from Oil & Gas Exploration: Environmental Impacts on Waterways in Western Pennsylvania, Thesis; Cidney Christie, Nicholas School of the Environment, Duke University; Durham, North Carolina; April 2012.

46. Service Companies Ease Operator Efforts; MJ Selle; Hydraulic Fracturing ; www.EPmag.com ; August 2012.

47. Te ch Brief: Oil & Gas Extraction & Source Water Protection; Zane Satterfield, National Environmental Services Center; DWFSOM154DL; Volume 11, Issue 2, Fall/Winter 2011.

48. Hydraulic Fracturing: New ASTM International Subcommittee to Develop Needed Standards; http://www.astm.org/ ; Standardization News, November/December 2012.

49. Naturally

- Occurring Radioactive Materials (NORM); www.world

- nuclear.org , August 2011.

50. Groundwater Qualit y in West Virginia, 1993

– 2008; Douglas Chambers, Mark Kozar, Jeremy White and Katherine Paybins, USGS West Virginia Water Science Center; Scientific Investigations Report, 2012

– 5186, 60p; 2012.

51. 1996 Low

- Flow (Minimal Drawdown) Ground

- Water Sampling Proc edures; Robert W. Puls and Michael J. Barcelona; Environmental Protection Agency; April 1996.
52. Comprehensive Quality Assurance Plan: Revision 28; Effective Date: July 25, 2011; REI Consultants, Inc. 2011.
53. Quality Assurance Manual: Revision 15.1; Effective Date: May 5, 2012; Pace Analytical Services, Inc. 2012.
54. Ground

- water quality in unmined areas and near reclaimed surface coal mines in the northern and central Appalachian coal regions, Pennsylvania and West Virginia; McAuley, S.D. and Kozar, M.D.; U.S. Geological Survey Scientific Investigations Report 2006

- 5059, 57p; 2006.

55. Radiation Alert Quality Handheld Detectors, Inspector+ and Inspector EXP+ User Manual, August 29, 2006.110 | Page 

## Appendix A: WVWRI Project Staff

Name Role Email Office Telephone Address

Paul Ziemkiewicz, PhD Principal Investigator paul.ziemkiewicz@mail.wvu.edu 304-293-6958 WV Water Research Institute West Virginia University PO Box 6064 Morgantown, WV 26506-6064

Jennifer Hause Project Manager jhause@wvu.edu 304-293-7003 WV Water Research Institute West Virginia University PO Box 6064 Morgantown, WV 26506-6064

Brady Gutta Program Coordinator/Geologist brady.gutta@mail.wvu.edu 304-293-7002 WV Water Research Institute West Virginia University PO Box 6064 Morgantown, WV 26506-6064

Benjamin Mack Research Associate ben.mack@mail.wvu.edu 304-293-7009 WV Water Research Institute West Virginia University PO Box 6064 Morgantown, WV 26506-6064

Jason Fillhart Environmental Scientist jefillhart@mail.wvu.edu 304-293-7074 WV Water Research Institute West Virginia University PO Box 6064 Morgantown, WV 26506-6064

Melissa O'Neal Environmental Technician/Laboratory Manager melissa.o'neal@mail.wvu.edu 304-293-7006 WV Water Research Institute West Virginia University PO Box 6064 Morgantown, WV 26506-6064

Doug Patchen, PG Geologist doug.patchen@mail.wvu.edu 304-293-6216 WV Water Research Institute West Virginia University PO Box 6064 Morgantown, WV 26506-6064111 | Page 

## Appen dix B: REI Consultants Chain
- of
- Custody Form112 | Page 

## Appendix C: Pace Analytical Chain of Custody Form113 | Page 

## Appendix D: Individual Site Checklists114 | Page 

### Site Checklist

– Chesapeake DNR A Pad 

## Description Task Completed/Notes Site Identification Identify site for ETD

- 10 study Chesapeake DNR Pad (A) Industry Contact Initial contact w/ companies to establish site access Main contact

- Chesapeake
Access to Site Confirm access to water & waste streams based on well stage development:

• Impoundment

- freshwater

• Groundwater

• Drilling fluids

• Muds & cuttings

• Hydraulic fracturing fluids

• Hydraulic fracturing water

• Flowback/Produced w ater

• Pits

- flowback storage Access granted from Chesapeake for sampling muds and cuttings from the shaker table during the vertical portion of the drilling process

Contact and Scheduling Contact companies/site supervisor establish sampling date(s) and meeting locations Vertical Drilling

– 10/25/ 20 12
Source Water Identify and obtain inform at ion on source water for hydraulic fracturing operations for each site (if relevant) Not Applicable

Hydraulic Fracturing Fluids Obtain list/breakdown of h ydraulic fracturing fluids (if relevant) Not Applicable
Locations Obtain & confirm GPS coordinates for:

• Well pad location

• Sampling points (if off pad)

• Water withdrawals (if relevant)

• Permitted discharges (if relevant)

• Pits

• Impoundments

• GW monitoring wells 40° 19’ 16.1”N 80° 32’ 12.2”W

Field Measurements Measurement of field parameters:

• pH

• Electric conductivity (EC)

• Temperature , °C

• TDS

• DO

• Salinity • pH = 9.38

• EC = 4 μS/cm

• Temperature = 33.06°

• TDS = 2 mg/L , oil

- like substance causing interference with reading

• DO = 9.39 mg/L

• Salinity = 0.0 ppt Refer to Appendix E also Duplicate Samples Identify duplicate sampling events Full Duplicate on 10/25/ 20 12
Site Observations Document visual observations of site Refer to the Water and Waste Stream Monitoring Plan section of the report Photographic Documentation Obtain permission prior to and take photos of site, sample collection, and catalog and document photos No Photos Taken (Operator Preference) Permitting Provide copies of permit for each site to WRI Not Available115 | Page 

## Description Task Completed/Notes Drilling Logs Obtain and provide copies of drilling logs to WRI Received November 2012
Health and Safety/Emergency Response Obtain copies of company specific Environmental Health & Safety P lans and Emergency Response Plans for recordkeeping purposes only Received November 2012

Site Mapping Obtain and provide copies of maps/diagrams o f pad layout & location Received November 2012 Sampling Specifics Describe pad activities at time of sampling Collect samples, noting:

• Time, date, sampler(s)

• Sampling point

• PID measurements

• RAD sweep readings

• Weather conditions

• Other field/env ironm enta l surroundings to be noted • 11:00 am, 10/25/2012, JF/BM

• Sample s taken from shaker table

• Drilling depth approximately 5,300 f ee t
• 73°F, sunny with some cloud cover
• For PID and RAD readings , refer to Appendix E Preparation of Samples Sample preparation:

• Equipment

• Labeling

• Storage

• Transport

• COC forms

• Sample pick

- up/delivery to certified lab Refer to the Water and Waste Stream Monitoring Plan section of the report

Sample Verification • Receive results verifying all parameters analyzed Yes Data Entry Enter data into master spreadsheets Entered , MO/JF

Results Note daily maximum values, average results, values exceeding MCLs if applicable Refer to the Data A nalysis section of the report116 | Page 

### Site Checklist

– Lemons Pad 

## Description Task Completed/Notes Site Identification Identify site for ETD

- 10 study Lemons Pad Industry Contact Initial contact w/ companies to establish site access Main contact

- Stone Energy
Access to Site Confirm access to water & waste streams based on well stage development:

• Impoundment

- freshwater

• Groundwater

• Drilling fluids

• Muds & cuttings

• Hydraulic fracturing fluids

• Hydraulic fracturing water

• Flowback/Produced w ater

• Pits

- flowback storage Access granted from Stone Energy for sampling muds and cuttings from the shaker table during the vertical portion of the drilling process

Contact and Scheduling Contact companies/site supervisor establish sampling date(s) and meeting locations Vertical drilling

– 8/8, 8/15, 8/22, and 10/2/ 20 12
Source Water Identify and obtain information on source wate r for hydraulic fracturing operations for each site Not Applicable

Hydro Fracturing Fluids Obtain list/breakdown of h ydraulic fracturing fluids Not Applicable
Locations Obtain & confirm GPS coordinates for:

• Well pad location

• Sampling points (if off pad)

• Water withdrawals (if relevant)

• Permitted discharges (if relevant)

• Pits

• Impoundments

• GW monitoring wells 39°39’03.3’’N 80°47’39.6’’W

Field Measurements Measurement of field parameters:

• pH

• Electric conductivity (EC)

• Temperature , °C

• TDS

• DO

• Salinity Refer to Appendix E for all field measurements during each individual sampling event at this site

Duplicate Samples Identify duplicate sampling events Collected one complete duplicate set of both solids and liquids on 10/2/2012 Site Observations Document visual observations of site Refer to the Water and Waste Stream Monitoring Plan section of the report Photographic Documentation Obtain permission prior to and take photos of site, sample collection, and catalog and document photos Completed, included as part of the Water and Waste Stream Monitoring Plan section of the report Permitting and Drilling Provide copies of permit and drilling logs for each site to WRI Partial data received November 2012117 | Page 

## Description Task Completed/Notes

Health and Safety/Emergency Response Obt ain copies of company specific Environmental Health & Safety P lans and Emergency Response Plans for recordkeeping purposes only No

Site Mapping Obtain and provide copies of maps/diagrams of pad layout & location Partial data received November 2012 Sampling Specifics Describe pad activities at time of sampling Collect samples, noting:

• Time, date, sampler(s)

• Sampling point

• PID measurements

• RAD sweep readings

• Weather conditions

• Other field/environmental surroundings needing to be noted Refer to Appendix E for all sampling specifics during each individual sampling event at this site

Preparation of Samples Sample preparation:

• Equipment

• Labeling

• Storage

• Transport

• COC forms

• Sample pick

- up/delivery to certified lab Refer to the Water and Waste Stream Monitoring Plan section of the report

Sample Verification • Receive results verifying all parameters analyzed Yes Data Entry Enter data into master spreadsheets Entered , MO/JF

Results Note daily maximum values, average results, values exceeding MCLs if applicable Refer to the Data A nalysis section of the report118 | Page 

### Site Checklist

– Maury Pad 

## Description Task Completed/Notes Site Identification Identify site for ETD

- 10 study Maury Pad Industry Contact Initial contact w/ companies to establish site access Main contact

- Stone Energy
Access to Site Confirm access to water & waste streams based on well stage development:

• Impoundment

- freshwater

• Groundwater

• Drilling fluids

• Muds & cuttings

• Hydraulic fr acturing fluids

• Hydraulic fracturing water

• Flowba ck/Produced w ater

• Pits

- flowback storage Access granted from Stone Energy for sampling makeup water and hydraulic fracturing fluid during the hydraulic fracturing process, as well as flowback water during the flowback stage

Contact and Scheduling Contact companies/site supervisor establish sampling date(s) and meeting locations Hydraulic Fracturing

– 9/11/ 20 12 Flowback

– 10/2/ 20 12 Source Water Identify and obtain infor mation on source water for hydraulic fracturing operations for each site Mixture of recycled water and freshwater from local source (11%:89%) Hydro Fracturing Fluids Obtain list/breakdown of h ydraulic fracturing fluids Received February 2013
Locations Obtain & confirm GPS coordinates for:

• Well pad location

• Sampling points (if off pad)

• Water withdrawals (if relevant)

• Permitted discharges (if relevant)

• Pits

• Impoundments

• GW monitoring wells 39°36’58.6’’N 80°47’00.7’’W

Field Measurements Measurement of field parameters:

• pH

• Electric conductivity (EC)

• Temperature , °C

• TDS

• DO

• Salinity Refer to Appendix E for all field measurements during each individual sampling event at this site

Duplicate Samples Identify duplicate sampling events None Site Observations Document visual observations of site Refer to the Water and Waste Stream Monitoring Plan section of the report Photographic Documentation Obtain permission prior to and take photos of site, sample collection, and catalog and document photos Completed, included as part of the Water and Waste Stream Monitoring Plan section of the report Permitting Provide copies of permit for each site to WRI No Drilling Logs Obtain and provide copies of drilling logs to WRI Not Applicable119 | Page 

## Description Task Completed/Notes

Health and Safety/Emergency Response Obt ain copies of company specific Environmental Health & Safety P lans and Emergency Response Plans for recordkeeping purposes only No

Site Mapping Obtain and provide copies of maps/diagrams of pad layout & location No Sampling Specifics Describe pad activities at time of sampling Collect samples, noting:

• Time, date, sampler(s)

• Sampling point

• PID measurements

• RAD sweep readings

• Weather conditions

• Other field/environmental surroundings needing to be noted Refer to Appendix E for all sampling specifics during each individu al sampling event at this site

Preparation of Samples Sample preparation:

• Equipment

• Labeling

• Storage

• Transport

• COC forms

• Sample pick

- up/delivery to certified lab Refer to the Water and Waste Stream Monitoring Plan section of the report

Sample Verification • Receive results verifying all parameters analyzed Yes Data Entry Enter data into master spreadsheets Entered , MO/JF

Results Note daily maximum values, average results, values exceeding MCLs if applicable Refer to t he D a ta Analysis section of the report120 | Page 

### Site Checklist

– Mills Wetzel Pad #2 

## Description Task Completed/Notes Site Identification Identify site for ETD

- 10 study Mills Wetzel Pad #2 Industry Contact Initial contact w/ companies to establish site access Main contact

- Stone Energy
Access to Site Confirm access to water & waste streams based on well stage development:

• Impoundment

- freshwater

• Groundwater

• Drilling fluids

• Muds & cuttings

• Hydraulic fracturing fluids

• Hydraulic fracturing water

• Flowback/Produced w ater

• Pits

- flowback storage Access granted from Stone Energy for sampling muds and cuttings from the shaker table during the vertical portion of the drilling process

Contact and Scheduling Contact companies/site supervisor establish sampling date(s) and meeting locations Vertical Drilling

– 8/8/ 20 12
Source Water Identify and obtain infor mation on source water for hydraulic fracturing operations for each site Not Applicable

Hydro Fracturing Fluids Obtain list/bre akdown of h ydraulic fracturing fluids Not Applicable
Locations Obtain & confirm GPS coordinates for:

• Well pad location

• Sampling points (if off pad)

• Water withdrawals (if relevant)

• Permitted discharges (if relevant)

• Pits

• Impoundments

• GW monitoring wells 39°”N 80°”W

Field Measurements Measurement of field parameters:

• pH

• Electric conductivity (EC)

• Temperature , °C

• TDS

• DO

• Salinity • pH = 9.06

• EC = 173,962 μS/cm

• Temperature = 34.22 °C

• TDS = 96,160 mg/L

• DO = 0.17 mg/L

• Salinity = 117.14 ppt Refer to Appendix E also Duplicate Samples Identify duplicate sampling events None
Site Observations Document visual observations of site Refer to the Water and Waste Stream Monitoring Plan section of the report

Photographic Documentation Obtain permission prior to and take photos of site, sample collection, and catalog and document photos Completed, included as part of the Water and Waste Stream Monitoring Plan section of the report121 | Page 

## Description Task Completed/Notes

Permitting Provide copies of permit for each site to WRI No Drilling Logs Obtain and provide copies of drilling logs to WRI Yes, partial information received on

- site
Health and Safety/Emergency Response Obt ain copies of company specific Environmental Health & Safety P lans and Emergency Response Plans for recordkeeping purposes only No

Site Mapping Obtain and provide copies of maps /diagrams of pad layout & location No Sampling Specifics Describe pad activities at time of sampling Collect samples, noting:

• Time, date, sampler(s)

• Sampling point

• PID measurements

• RAD sweep readings

• Weather conditions

• Other field/environmenta l surroundings needing to be noted • 1:00 pm, 8/8/2012, JF/BM

• Samples taken from shaker table

• Drilling depth approximately 5,226 feet, not yet horizontal

• 92 °F, sunny with few clouds

• For PID and RAD readings, refer to Appendix E

Preparation of Samples Sample preparation:

• Equipment

• Labeling

• Storage

• Transport

• COC forms

• Sample pick

- up/delivery to certified lab Refer to the Water and Waste Stream Monitoring Plan section of the report

Sample Verification • Receive results verifying all parameters analyzed Yes Data Entry Enter data into master spreadsheets Entered , MO/JF

Results Note daily maximum values, average results, values exceeding MCLs if applicable Refer to the D at a Analysis section of the report122 | Page 

### Site Checklist

– Mills Wetzel Pad #3 

## Description Task Completed/Notes Site Identification Identify site for ETD

- 10 study Mills Wetzel Pad #3 Single

- Lined Impoundment Industry Contact Initial contact w/ companies to establish site access Main contact

- Stone Energy
Access to Site Confirm access to water & waste streams based on well stage development:

• Impoundment

- freshwater

• Groundwater

• Drilling fluids

• Muds & cuttings

• Hydraulic fracturing fluids

• Hydraulic fracturing water

• Flowback/Produced w ater

• Pits

- flowback storage Access granted for sampling the impoundment near the Mills Wetzel #3 Pad

Contact and Scheduling Contact companies/site supervisor establish sampling date(s) and meeting locations Impoundment

– 8/28/ 20 12
Source Water Identify and obtain infor mation on source water for hydraulic fractur ing operations for each site Not Applicable

Hydro Fracturing Fluids Obtain list/breakdown of h ydraulic fracturing fluids Not Applicable
Locations Obtain & confirm GPS coordinates for:

• Well pad location

• Sampling points (if off pad)

• Water withdrawals (if relevant)

• Permitted discharges (if relevant)

• Pits

• Impoundments

• GW monitoring wells 39°31’57.69”N 80°40’21.88”W

Field Measurements Measurement of field parameters:

• pH

• Electric conductivity (EC)

• Temperature , °C

• TDS

• DO

• Salinity • pH = 8.09

• EC = 231 μS/cm

• Temperature = 30.46 °C

• TDS = 150 mg/L

• DO = 7.68 mg/L

• Salinity = 0.11 ppt Refer to Appendix E also Duplicate Samples Identify duplicate sampling events None
Site Observations Document visual observations of site Refer to the Water and Waste Stream Monitoring Plan section of the report Photographic Documentation Obtain permission prior to and take photos of site, sample collection, and catalog and document photos Completed, included as part of the Water and Waste Stream Moni toring Plan section of the report Permitting Provide copies of permit for each site to WRI No123 | Page 

## Description Task Completed/Notes Drilling Logs Obtain and provide copies of drilling logs to WRI Not Applicable
Health and Safety/Emergency Response Obtain copies of company specific Environmental Health & Safety P lans and Emergency Response Plans for recordkeeping purposes only No

Site Mapping Obtain and provide copies of maps/diagrams of pad layout & location No Sampling Specifics Describe pad activities at time of sampling Collect samples, noting:

• Time, date, sampler(s)

• Sampling point

• PID measurements

• RAD sweep readings

• Weather conditions

• Other field/environmental surroundings needing to be noted • 4:30 pm, 8/28/2012, JF/BM

• Samples taken from MW3 impoundment

• 84 °F, mostly sunn y
• For PID and RAD readings, refer to Appendix E

Preparation of Samples Sample preparation:

• Equipment

• Labeling

• Storage

• Tran s port

• COC forms

• Sample pick

- up/delivery to certified lab Refer to the Water and Waste Stream Monitoring Plan section of the report

Sample Verification • Receive results verifying all parameters analyzed Yes Data Entry Enter data into master spreadsheets Entered , MO/JF

Results Note daily maximum values, average results, values exceeding MCLs if applicable Refer to the Data A nal ysis section of the report124 | Page 

### Site Checklist

– Sand Hill Location 

## Description Task Completed/Notes Site Identification Identify site for ETD

- 10 study SHL

- 1, 2, 3, and 4, Consol/Noble Sand Hill location Industry Contact Initial contact w/ companies to establish site access Main contact

- Noble Energy and Subcontractor

- Moody & Associates Access to Site Confirm access to water & waste streams based on well stage development:

• Impoundment

- freshwater

• Groundwater

• Drilling fluids

• Muds & cuttings

• Hydraulic fract uring fluid

• Hydraulic fracturing water

• Flowback/Produced w ater

• Pits

- flowback storage Access granted for sampling centralized impoundments/pits, flowback, and groundwater (via groundwater monitor wells)

Contact and Scheduling Contact companies/site supervisor establish sampling date(s) and meeting locations Impoundments

- 6/7/ 20 12 Groundwater

– (6/4, 6/7 and 6/19/ 20 12

– Initial), (10/31 and 11/1/ 20 12

– Final) Flowback

- 8/1 3, 8/20, 8/28 and 9/17/ 20 12 Pits

- 9/17/ 20 12 Source Water Identify and obtain infor mation on source water for hydraulic fracturing operations for each site Ohio River, Wheeling Creek, and
r eturn water from previous operations Hydro Fracturing Fluids Obtain list/breakdown of h ydraulic fracturing fluids Not Applicable
Locations Obtain & confirm GPS coordinates for:

• Well pad location

• Sampling points (if off pad)

• Water withdrawals (if relevant)

• Permitted discharges (if relevant)

• Pits

• Impoundments

• GW monitoring wells SHL2

- MW

- 1 39°58’03.79” 80°33’42.87”

- MW

- 2 39°58’00.85” 80 33’40.94”

- MW

- 3 39°57’58.49” 80 33’43.26”

- MW

- 4 39°57’59.14” 80°33’45.22”

- Pit Center 39°58’00.78” 80 33’42.31” SHL3

- MW

- 4 39°58’20.57” 80°33’16.32”

- Pit Center 39°58’26.80” 80°33’18.49” SHL4

- MW

- 1 39°57’48.81” 80°33’46.15”

- MW

- 2 39°57’44.06” 80°33’48.76”

- MW

- 3 39°57’45.05” 80°33’45.58”

- Pit Center 39°57’46.09” 80°33’46.80” Field Measurements Measurement of field parameters:

• pH

• Electric conductivity (EC)

• Temperature , °C

• TDS

• DO

• Salinity Refer to Appendix E for all field measurements during each individual sampling event at this site

Duplicate Samples Identify duplicate sampling events SHL

- 4

- MW

- 3, Collected a complete set of duplicates during groundwater sampling on 10/31/12125 | Page 

## Description Task Completed/Notes Site Observations Document visual observations of site Refer to Water and Waste Stream Monitoring Plan section of the report Photographic Documentation Obtain permission prior to and take photos of site, sample collection, and catalog and document photos Completed, included as part of the Water and Waste Stream Monito ring Plan section of the report Permitting Provide copies of permit for each site to WRI Yes, Received from Consol and WVU CEE Drilling Logs Obtain and provide copies of drilling logs to WRI Not Applicable
Health and Safety/Emergency Response Obt ain copies of company specific Environmental Health & Safety P lans and Emergency Response Plans for recordkeeping purposes only Yes, Received from Consol

Site Mapping Obtain and provide copies of maps/diagrams of pad layout & location Yes, Received from Cons ol Sampling Specifics Describe pad activities at time of sampling Collect samples, noting:

• Time, date, sampler(s)

• Sampling point

• PID measurements

• RAD sweep readings

• Weather conditions

• Other field/environmental surroundings needing to be noted Refer to Appendix E for all sampling specifics during each individual sampling event at this site

Preparation of Samples Sample preparation:

• Equipment

• Labeling

• Storage

• Transport

• COC forms

• Sample pick

- up/delivery to certified lab Refer to the Water and Waste Stream Monitoring Plan section of the report

Sample Verification • Receive results verifying all parameters analyzed Yes Data Entry Enter data into master spreadsheets Entered , MO/JF

Results Note daily maximum values, average results, values exceeding MCLs if applicable Refer to the D at a Analysis section of the report126 | Page 

### Site Checklist

– Weekley Pad 

## Description Task Completed/Notes Site Identification Identify site for ETD

- 10 study Weekl e y Pad Industry Contact Initial contact w/ companies to establish site access Main contact

- Stone Energy
Access to Site Confirm access to water & waste streams based on well stage development:

• Impoundment

- freshwater

• Groundwater

• Drilling fluids

• Muds & cuttings

• Hydraulic fracturing fluids

• Hydraulic fracturing water

• Flowback/Produced w ater

• Pits

- flowback storage Access granted from Stone Energy for sampling flowback water during the flowback stage

Contact and Scheduling Contact companies/site supervisor establish sampling date(s) and meeting locations Flowback

– 8/15/12 and 8/20/ 20 12
Source Water Identify and obtain infor mation on source water for hydraulic fracturing operations for each site Unknown

Hydro Fracturing Fluids Obtain list/breakdown of h ydraulic fracturing fluids Yes, Received February 2013
Locations Obtain & confirm GPS coordinates for:

• Well pad location

• Sampling points (if off pad)

• Water withdrawals (if relevant)

• Permitted discharges (if relevant)

• Pits

• Impoundments

• GW monitoring wells 39°36’58.6’’N 80°47’00.7’’W

Field Measurements Measurement of field parameters:

• pH

• Electric conductivity (EC)

• Temperature , °C

• TDS

• DO

• Salinity Refer to Appendix E for all field measurements during each individual sampling event at this site

Duplicate Samples Identify duplicate sampling events None Site Observations Document visual observations of site Refer to the Water and Waste Stream Monitoring Plan section of the report Photographic Documentation Obtain permission prior to and take photos of site, sample collection, and catalog and document photos Completed, included as part of the Water and Waste Stream Monitoring Plan section of the report Permitting Provide copies of permit for each site to WRI No127 | Page 

## Description Task Completed/Notes Drilling Logs Obtain and provide copies of drilling logs to WRI Not Applicable
Health and Safety/Emergency Response Obt ain copies of company specific Environmental Health & Safety P lans and Emergency Response Plans for recordkeeping purposes only No

Site Mapping Obtain and provide copies of maps/diagrams of pad layout & location No Sampling Specifics Describe pad activities at time of sampling Collect samples, noting:

• Time, date, sampler(s)

• Sampling point

• PID measurements

• RAD sweep readings

• Weather conditions

• Other field/environmental surroundings needing to be noted Refer to Ap pendix E for all sampling specifics during each individual sampling event at this site

Preparation of Samples Sample preparation:

• Equipment

• Labeling

• Storage

• Transport

• COC forms

• Sample pick

- up/delivery to certified lab Refer to the Water and Waste Stream Monitoring Plan section of the report

Sample Verification • Receive results verifying all parameters analyzed Yes Data Entry Enter data into master spreadsheets Entered , MO/JF

Results Note daily maximum values, average results, values exceeding MCLs if applicable Refer to the D a ta Analysis section of the report128 | Page 

### Site Checklist

– Waco/Donna Pad 

## Description Task Completed/Notes Site Identification Identify site for ETD

- 10 study Waco Donna Pad Industry Contact Initial contact w/ companies to establish site access Main contact

- Waco Oil and Gas Access to Site Confirm access to water & waste streams based on well stage development:

• Impoundment

- freshwater

• Groundwater

• Drilling fluids

• Muds & cuttings

• Hydraulic fracturing fluids

• Hydraulic fracturing water

• Flowback/Produced w ater

• Pits

- flowback storage Access granted for sampling flowback water storage from the single

- lined pit, hydraulic fracturing fluids , and flowback water from the flowback stage

Contact and Scheduling Contact companies/site supervisor establish sampling date(s) and meeting locations Pit

- 7/25/12 and 8/30/ 20 12 (Pit was makeup water for hydraulic fracturing process) Flowback

- 7/27, 8/2, 8/9 and 8/30/ 20 12 Hydraulic Fracturing

7/25/ 20 12 Source Water Identify and obtain infor mation on source water for hydraulic fracturing operations for each site Nearby pond (surface water source) Hydro Fracturing Fluids Obtai n list/breakdown of h ydraulic fracturing fluids Yes, Received November 2012
Locations Obtain & confirm GPS coordinates for:

• Well pad location

• Sampling points (if off pad)

• Water withdrawals (if relevant)

• Permitted discharges (if relevant)

• Pits

• Impoundments

• GW monitoring wells Pit

- 39° 34’ 29.30’’ N 80° 17’ 31.40 W
Pad

- 39° 34’ 27.19’’ N 80° 17’ 39.89’’ W

Field Measurements Measurement of field parameters:

• pH

• Electric conductivity (EC)

• Temperature , °C

• TDS

• DO

• Salinity Refer to Appendix E for all field measurements during each individual sampling event at this site

Duplicate Samples Identify duplicate sampling events None Site Observations Document visual observations of site Refer to the Water and Waste Stream Monitoring Plan section of the report129 | Page 

## Description Task Completed/Notes Photographic Documentation Obtain permission prior to and take photos of site, sample collection, and catalog and document photos Completed, included as part of the Water and Waste Stream Monitoring Plan section of the report Permitting Provide copies of permit for each site to WRI Yes, Received November 2012 Drilling Logs O btain and provide copies of drilling logs to WRI Yes, Received November 2012
Health and Safety/Emergency Response Obt ain copies of company specific Environmental Health & Safety P lans and Emergency Response Plans for recordkeeping purposes only No

Site Mapping Obtain and provide copies of maps/diagrams of pad layout & location to WRI Yes, Received November 2012

Sampling Specifics Describe pad activities at time of sampling Collect samples, noting:

• Time, date, sampler(s)

• Sampling point

• PID measurements

• RAD sweep readings

• Weather conditions

• Other field/environmental surroundings needing to be noted Refer to Appendix E for all sampling specifics during each individual sampling event at this site

Preparation of Samples Sample preparation:

• Equipment

• Labeling

• Storage

• Transport

• COC forms

• Sample pick

- up/delivery to certified lab Refer to the Water and Waste Stream Monitoring Plan section of the report

Sample Verification • Receive results verifying all parameters analyzed Yes Data Entry Enter data into master spreadsheets Entered, MO/JF

Results Note daily maximum values, average results, values exceeding MCLs if applicable Refer to the D a ta Analysis section of the report130 | Page 

## Appendix E: Field Spreadsheets131 | Page units °C μS/cm (mg/L) pH (mg/L) ppt Stage Target Sample Identification and Location Date Temp. EC TDS pH DO Salinity SHL-3-IMP, Noble Pits 6/7/2012 20.72 364 258 8.75 7.51 NS SHL-2-IMP, Noble Pits 6/7/2012 NS NS NS NS NS NS SHL-1-IMP, Noble Pits 6/7/2012 22.76 387 263 8.61 9.28 NS Mills Wetzel #3 IMP 8/28/2012 30.46 231 150 8.09 7.68 0.11 SHL-2, MW-2, Noble Pits 6/4/2012 12.48 286 244 7.08 3.24 NS SHL-2, MW-3, Noble Pits 6/4/2012 13.53 274 228 7.27 5.63 NS SHL-4, MW-1, Noble Pits 6/4/2012 13.51 297 248 7.3 6.84 NS SHL-4, MW-2, Noble Pits 6/4/2012 12.28 281 241 7.73 8.74 NS SHL-4, MW-3, Noble Pits 6/4/2012 12.28 277 238 7.52 4.61 NS SHL-2 MW-1, Noble Pits 11/1/2012 11.84 909 590 7.75 4.89 0.45 SHL-2, MW-2, Noble Pits 10/31/2012 11 175 113 6.42 13.12 0.08 SHL-2, MW-3, Noble Pits 10/31/2012 11.05 386 251 7.44 7.35 0.19 SHL-4, MW-1, Noble Pits 10/31/2012 12.2 308 200 6.75 4.35 0.15 SHL-4, MW-2, Noble Pits 10/31/2012 10.64 467 304 7.05 8.73 0.23 SHL-4, MW-3, Noble Pits 10/31/2012 12.31 184 119 6.32 11.89 0.09 SHL-2 MW-4, Noble Pits 6/19/2012 14.82 338 273 7.29 6.36 NS SHL-3 MW-4, Noble Pits 6/19/2012 21.48 492 342 7.51 6.31 NS SHL-2 MW-4, Noble Pits 11/1/2012 11.28 427 277 7.3 7.39 0.21 SHL-3 MW-4, Noble Pits 11/1/2012 11.25 470 306 7.32 6.19 0.23 HF Water HF Water, Donna Pad 7/25/2012 26.14 7242 4611 7.96 5.88 NS Frac Fluid Comb. HF, Donna Pad 7/25/2012 28.99 24192 14602 7.02 7.49 NS HF Water HF Water, Maury Pad 9/11/2012 13.26 965 627 6.78 4.85 0.48 Frac Fluid Comb. HF, Maury Pad 9/11/2012 23.29 20,597 13,390 6.63 5.78 12.32 ST 2 at 13:00 (slurry) Mills Wetzel #2 8/8/2012 34.22 173962 96160 9.06 0.17 117.14 ST 2 at 13:00 (solids) Mills Wetzel #2 8/8/2012 ST 1-1 at 11:00 (liquid) Lemons Pad 8/8/2012 29.06 110145 66420 10.01 4.11 74.48 ST 1-1 at 11:00 (solids) Lemons Pad 8/8/2012 ST 1-2 at 10:30 (liquid) Lemons Pad 8/15/2012 29.61 42203 27450 7.35 4.63 27.02 ST 1-2 at 10:30 (solids) Lemons Pad 8/15/2012 ST 1-3 at 11:00 (liquid) Lemons Pad 8/22/2012 29.77 14963 9731 8.82 4.19 8.66 ST 1-3 at 11:00 (solid) Lemons Pad 8/22/2012 ST 1-4 at 1:30 (liquid) Lemons Pad 10/2/2012 24.66 10457 6799 12.71 7.31 5.91 ST 1-4 at 1:30 (solid) Lemons Pad 10/2/2012 DNR ST 3-1-L (sludge) DNRA Pad 10/25/2012 33.06 4 2 9.38 9.39 0 DNR ST 3-1-L (sludge) DUP DNRA Pad 10/25/2012 33.06 4 2 9.38 9.39 0 DNR ST 3-1-S (solid) DNRA Pad 10/25/2012 DNR ST 3-1-S (solid) DUP DNRA Pad 10/25/2012 FS -1, Donna Pad 7/27/2012 40.35 94345 47450 6.92 1.47 49.57 FS-2, Donna Pad 8/2/2012 25.86 160501 102700 6.49 0.74 NS FS-3, Donna Pad 8/9/2012 17.47 133036 101000 7.07 1.28 124.67 FS -Final, Donna Pad 8/30/2012 20.87 170,822 111,000 6.61 1.46 141.44 FS-1, Noble Pits (SHL-3) 8/13/2012 28.51 16,283 10,590 6.99 1.55 9.5 FS 2, Noble Pits (SHL-3) 8/20/2012 24.8 125901 81830 6.9 2.69 96.01 FS-3, Noble Pits (SHL-3) 8/28/2012 28.39 26426 17180 6.16 0.57 16.1 FS Final, Noble Pits (SHL-3) 9/17/2012 33.04 54461 35400 6.22 1.29 36.08 SHL-4 Composite, Noble Pits (SHL-4) 9/17/2012 27.2 40499 2632 7.07 2.57 25.83 FS-1, Weekly Pad 8/15/2012 27.79 119,710 77,800 6.81 1.24 90.16 FS-2, Weekly Pad 8/20/2012 25.83 132,680 86,230 6.75 0.9 102.48 FS-1, Maury Pad 10/2/2012 28.61 112879 73330 6.86 1.08 83.81 Donna Pit-C (liquid) Donna Pad 8/30/2012 28.23 84044 54630 7.82 9.53 59.11 Donna Pit-C (solid) Donna Pad 8/30/2012 Site Pit Field Readings/Observations

Fresh Water Impoundment Fresh Water

Pits: Centralized Monitoring Wells (Shallow)

Hydraulic Fracturing

Vertical Drilling Drilling - produced

waste Pits: centralized Monitoring Wells (Deep)

Flowback Site Pit

Centralized Pits132 | Page units mr/hr mr/hr parameter dependent parameter dependent
Stage Target Sample Identification and Location Date Weather Conditions Ra di oa cti vi ty (Background) Ra di oa cti vi ty (Sample) 6-Gas (Background) 6-Gas (Sample) SHL-3-IMP, Noble Pits 6/7/2012 83 ° F, Sunny w/s ome cloud cover 0.011 0.011 Non Detect 1% LEL SHL-2-IMP, Noble Pits 6/7/2012 83 ° F, Sunny w/s ome cloud cover 0.008 0.016 Non Detect Non Detect SHL-1-IMP, Noble Pits 6/7/2012 83 ° F, Sunny w/s ome cloud cover 0.008 0.011 Non Detect Non Detect Mi l l s Wetzel #3 IMP 8/28/2012 84 ° F, Mos tly Sunny 0.009 0.014 7% LEL 7% LEL SHL-2, MW-2, Noble Pits 6/4/2012 86 ° F, Sunny w/little cloud cover NS NS Non Detect Non Detect SHL-2, MW-3, Noble Pits 6/4/2012 86 ° F, Sunny w/little cloud cover NS NS Non Detect Non Detect SHL-4, MW-1, Noble Pits 6/4/2012 86 ° F, Sunny w/little cloud cover NS NS Non Detect Non Detect SHL-4, MW-2, Noble Pits 6/4/2012 86 ° F, Sunny w/little cloud cover NS NS Non Detect Non Detect SHL-4, MW-3, Noble Pits 6/4/2012 86 ° F, Sunny w/little cloud cover NS NS Non Detect Non Detect SHL-2 MW-1, Noble Pits 11/1/2012 38° F, Overca s t, Ra i n 0.012 0.01 1% LEL, 21.5% O2 1% LEL, 21.5% O2 SHL-2, MW-2, Noble Pits 10/31/2012 40° F, Overca s t, Dri zzl e 0.016 0.013 21.5% O2 Non Detect SHL-2, MW-3, Noble Pits 10/31/2012 40° F, Overca s t, Dri zzl e 0.013 0.013 21.3% O2 Non Detect SHL-4, MW-1, Noble Pits 10/31/2012 40° F, Overca s t, Dri zzl e 0.017 0.013 2% LEL, 21.5% O2 1% LEL, 21.3% O2 SHL-4, MW-2, Noble Pits 10/31/2012 40° F, Overca s t, Dri zzl e 0.012 0.016 LEL, 21.1% O2, 2ppm IBL 21.3% O2, 2ppm IBL SHL-4, MW-3, Noble Pits 10/31/2012 40° F, Overca s t, Dri zzl e 0.016 0.011 1% LEL, 21.1% O2 1% LEL, 21.1% O2 SHL-2 MW-4, Noble Pits 6/19/2012 92 ° F, Sunny, clear 0.009 0.015 Non Detect Non Detect SHL-3 MW-4, Noble Pits 6/19/2012 92° F, Sunny, clear 0.011 0.013 Non Detect Non Detect SHL-2 MW-4, Noble Pits 11/1/2012 38° F, Overca s t, Ra i n 0.022 0.09 21.8% O2 21.6% O2 SHL-3 MW-4, Noble Pits 11/1/2012 38° F, Overca s t, Ra i n 0.015 0.013 1% LEL, 21.5% O2 1% LEL, 21.6% O2, 1ppm IBL HF Water HF Wa ter, Donna Pa d 7/25/2012 89° F, Sunny w/few clouds 0.015 0.018 Non Detect Non Detect Fra c Fl ui d Comb. HF, Donna Pad 7/25/2012 89° F, Sunny w/few clouds 0.01 0.012 7.8% LEL Non Detect HF Water HF Wa ter, Ma ury Pa d 9/11/2012 70 °, Sunny, clear 0.016 0.014 87% LEL, 21.9 O2 44% LEL, 21.9 O2 Fra c Fl ui d Comb. HF, Maury Pad 9/11/2012 70 °, Sunny, clear 0.011 0.01 1% LEL 2% LEL ST 2 a t 13:00 (s l urry) Mi l l s Wetzel #2 8/8/2012 92° F, Sunny w/few clouds 0.008 0.009 4% LEL 5%LEL ST 2 a t 13:00 (s ol i ds ) Mi l l s Wetzel #2 8/8/2012 92° F, Sunny w/few clouds 0.008 0.009 4% LEL 5%LEL ST 1-1 at 11:00 (liquid) Lemons Pad 8/8/2012 89° F, Sunny w/few clouds 0.013 0.013 Non Detect Non Detect ST 1-1 at 11:00 (solids) Lemons Pad 8/8/2012 89° F, Sunny w/few clouds 0.013 0.013 Non Detect Non Detect ST 1-2 at 10:30 (liquid) Lemons Pad 8/15/2012 90° F, Sunny 0.011 0.016 Non Detect 2% LEL ST 1-2 at 10:30 (solids) Lemons Pad 8/15/2012 90° F, Sunny 0.011 0.016 Non Detect 2%LEL ST 1-3 at 11:00 (liquid) Lemons Pad 8/22/2012 84° F, Partly Sunny 0.005 0.009 2% LEL 1%LEL ST 1-3 at 11:00 (solid) Lemons Pad 8/22/2012 84° F, Partly Sunny 0.005 0.009 2% LEL 1%LEL ST 1-4 at 1:30 (liquid) Lemons Pad 10/2/2012 66° F, Overca s t, Dri zzl e 0.008 0.009 20% LEL 20% LEL ST 1-4 at 1:30 (solid) Lemons Pad 10/2/2012 66° F, Overca s t, Dri zzl e 0.008 0.015 20% LEL 20% LEL DNR ST 3-1-L (sludge) DNRA Pad 10/25/2012 73° F, Sunny w/little cloud cover 0.008 0.01 Non Detect 403 IBL, 100% LEL, 77.6 ppm VOC's DNR ST 3-1-L (s ludge) DUP DNRA Pad 10/25/2012 73° F, Sunny w/little cloud cover 0.008 0.01 Non Detect 403 IBL, 100% LEL, 77.6 ppm VOC's DNR ST 3-1-S (s ol i d) DNRA Pa d 10/25/2012 73° F, Sunny w/little cloud cover 0.007 0.008 1% LEL 30% LEL, 43.2 ppm VOC's DNR ST 3-1-S (s olid) DUP DNRA Pad 10/25/2012 73° F, Sunny w/little cloud cover 0.007 0.008 1% LEL 30% LEL, 43.2 ppm VOC's FS -1, Donna Pad 7/27/2012 83° F, Sunny w/s ome cloud cover 0.019 0.017 3% LEL Non Detect FS-2, Donna Pad 8/2/2012 80° F, Sunny w/s ome cloud cover 0.011 0.013 Non Detect 2% LEL FS-3, Donna Pad 8/9/2012 79° F, Sunny w/s ome cloud cover 0.009 0.013 91% LEL 91% LEL FS -Fi na l , Donna Pa d 8/30/2012 80° F, Sunny, clear 0.011 0.01 1% LEL, 21.2% O2 1% LEL, 21.2% O2 FS-1, Noble Pits (SHL-3) 8/13/2012 77° F, Sunny w/s ome cloud cover 0.014 0.008 Non Detect 6% LEL FS 2, Noble Pits (SHL-3) 8/20/2012 89° F, Sunny w/s ome cloud cover 0.014 0.01 5% LEL 5% LEL FS-3, Noble Pits (SHL-3) 8/28/2012 84° F, Mos tly Sunny 0.008 0.013 3% LEL 5%LEL, 43ppm-H2S FS Fi na l , Nobl e Pi ts (SHL-3) 9/17/2012 75 ° F, Sunny w/s ome cloud cover 0.011 0.008 5% LEL 2% LEL, >100ppm H2S SHL-4 Compos ite, Noble Pits (SHL-4) 9/17/2012 75 ° F, Sunny w/s ome cloud cover 0.09 0.009 6% LEL 6% LEL, 2ppm IBL FS-1, Weekly Pad 8/15/2012 90° F, Sunny 0.01 0.007 2% LEL 2% LEL FS-2, Weekly Pad 8/20/2012 88° F, Sunny 0.008 0.009 3% LEL, 21.2% O2 21% O2 FS-1, Maury Pad 10/2/2012 68° F, Rain, Cloudy 0.011 0.013 26% LEL, >100ppm H2S 38.8% LEL, >2000ppm IBL Donna Pit-C (liquid) Donna Pad 8/30/2012 80° F, Sunny, clear 0.014 0.007 4% LEL 3% LEL Donna Pi t-C (s ol i d) Donna Pa d 8/30/2012 80° F, Sunny, clear 0.014 0.007 4% LEL 3% LEL Fi el d Rea di ngs /Obs erva ti ons

Si te Pi t Fresh Water Impoundment Fres h Wa ter

Pits: Centra l i zed Monitoring Wells (Shallow)

Hydra ul i c Fracturing

Verti ca l Dri l l i ng Dri l l i ng - produced waste Pits: centra l i zed Monitoring Wells (Deep)

Flowback Si te Pi t

Centra l i zed

Pits