Commitment to Transparency: A Deep Dive into CNX’s Water Quality Program at NV110
Context Corner Edition 16
August 29, 2025

By Carrie Crumpton, CNX Vice President of Environmental Strategy
In November 2023, CNX announced its historic Radical Transparency™ (RT) public-private collaboration with Governor Josh Shapiro and the Pennsylvania Department of Environmental Protection (DEP) from the NV110 pad in East Finley Township, Washington County.
Since then, the Radical Transparency program and website has taken shape with over 700,000 data points collected to date. Water quality testing is a complex topic and we have received some questions about these activities in general and for the NV110 pad specifically. In this Context Corner we take a deep dive into water quality testing at NV110 and how it relates to the Radical Transparency program.
It’s important to understand why we do water testing. Pennsylvania law does not require that a natural gas driller perform water testing, rather it presumes that an unconventional well operator is responsible if a water supply within 2,500 feet of an unconventional well becomes contaminated within 12 months of drilling or fracking. To preserve the ability to rebut this presumption, the operator must conduct a pre-drill water survey using an independent DEP-accredited lab and provide the results to both the owner of the water supply and the DEP.
The DEP does not have a required list of which water quality parameters (referred to as “analytes”) that must be analyzed—only that testing must occur before drilling or alteration of the well and that test results must be shared. The DEP provides a “recommended” list of analytes most relevant to gas development activity, and CNX tests for those parameters, in addition to other parameters not required but helpful to well owners. We provide this voluntary service to collaborate with our communities and ensure we are addressing issues others may ignore. Additionally, neither the law nor DEP requires that an operator test water to suitable drinking water standards. For an example of a pre-drill test report from NV110, please see the following two links for an actual anonymized NV110 test report, and the same well’s anonymized post-drill report.
Pre-drill.pdf
PDF - 1012 Kb
Post-drill.pdf
PDF - 1.9 Mb
There is much to understand about our water quality monitoring program, including why it is done, how it has evolved, and what it means for communities. Pre-drill testing provides a baseline of water quality before any operational activity has occurred, establishing a benchmark to determine if gas development activity has negatively impacted water quality.
This allows us to detect any changes and ensure our operations aren’t impacting residential water sources. For more information about the program’s rationale, refer to this post from March 2024: FAQ’s Water Testing, which introduced some of these concepts.
When did CNX’s water testing program change—and why?
Our water quality monitoring program significantly evolved in late 2023 with the launch of CNX’s Radical Transparency program—a first-of-its-kind public-private collaboration with Pennsylvania Governor Josh Shapiro. This program introduced real-time, open-source data sharing for air and water quality, chemical disclosures, and enhanced monitoring.
The timeline below illustrates some of the iterative changes that were in process while developing the RT program on NV110 and expanding our multi-quarter baseline water quality monitoring program at the MAM14 pad, a greenfield site where we could conduct quarterly water testing prior to any activity.

Why did CNX expand the program to include multiple quarters?
Water quality isn’t static—it changes with the seasons, rainfall, and land use. By sampling across multiple quarters, we capture a more complete baseline. This proactive approach helps us understand natural variability and strengthens our data integrity. Additional samples provide more data, providing a comprehensive picture of water supply conditions. Of course, water quality from private water wells varies significantly by area. Water-bearing zones can contain naturally occurring contaminants, bacteria, and naturally occurring methane, and these conditions can change throughout the year. Normal fluctuations occur in water supplies due to changing seasons and a variety of other factors, including the construction and maintenance of the water wells themselves. Additional samples help capture that information and provide insight into factors impacting water quality.
Why isn’t NV110 water quality data available on the Radical Transparency website, even though I opted in to disclose my results?
The NV110 pad’s water quality data isn’t posted because the pre-drill testing occurred before the program was established. At that time, CNX didn’t request landowner permission to publicly share the data. While some may have opted in to disclose post-drill results, the water monitoring portion of the Radical Transparency initiative was designed to launch in areas without prior drilling, allowing for consistent pre- and post-drill comparisons across multiple quarters.
For sites like NV110, where drilling had already occurred, we lack the same multiple quarter baseline data that is for comparison purposes that accounts for seasonal fluctuations as described above.
The first pad with complete water quality monitoring data under the new RT program is MAM14, which you can view here. Even though the NV110 water test results are not disclosed on the RT website, the results from the pre-drill testing that was performed was provided to both well owners and the DEP, as was our standard practice before the RT program was established. For NV110, we also performed post-drill testing and provided those results to the well owners. In one case, we performed both pre-drill and post-drill testing on a well outside of the 2,500-foot zone of presumption as a courtesy to that well owner at their request.
Why did CNX switch vendors for post-drill water testing on NV110?
As stated above, pre-drill testing on NV110 was completed by January 2022. When we established the RT program in 2023, we needed an efficient means to present water testing data on our RT website. Given the number of analytes for which we test and the number of unique tests for each well under the RT water testing program, the volume of water test results data was an order of magnitude larger than our previous testing program. We needed the ability to receive the data electronically via an API feed ensuring data integrity from the testing labs through publication rather than introducing the possibility of human error in transcribing the data into the RT website. Through competitive bidding, we selected a partner who met all of our water testing standards and could provide data through an API-style feed directly to our platform—maintaining data integrity from the independent testing lab, to the vendor, and then to CNX. This approach avoids human data errors. Reflecting the process where well owners are provided with results directly from the water testing company, CNX does not have the ability to edit or change the results embodied in the electronic data, eliminating transcription errors. The independent laboratories that perform the water testing and provide the results are selected by the water testing vendor (not CNX) and are certified by the states where we operate. This aligns with how we manage our air quality monitoring with Clean Air Engineering. Learn more here.

How does CNX decide what water quality parameters to test for, and why were the parameters for NV110 different from those used in the Radical Transparency program—for example, why was arsenic tested pre-drill but not post-drill?
In 2021, the DEP revised its technical guidance document that operators can reference for the recommended list of test analytes.
PA DEP OG recommendations 8000-FS-DEP4300.pdf
PDF - 385 Kb
We utilized that guidance for the NV110 pre-drill testing and further analyzed for parameters well beyond the minimum list outlined in the guidance. We tested for parameters that establish a baseline to identify whether future operations have had any impact on water quality, and we selected other meaningful analytes like sulfate, conductivity, hardness, and coliform bacteria to help both CNX and landowners to identify both nuisance and health-related concerns that can be found in mining or agricultural regions.
Our testing parameters for water quality have evolved as the DEP and industry have evolved. As stated above, the DEP revised its "Recommended Oil and Gas Predrill Parameters" over time to distinguish between recommended and minimum analytes for which to test. In one revision, dated July 2021, analytes such as arsenic and zinc were not designated as minimum recommendations, although they were included in some of CNX’s earlier pre-drill testing efforts.
Historically, CNX utilized a truncated post-drill list focused on key indicator analytes, which included the DEP’s minimum requirements and applied that post drill analysis to residential drinking water sources within 1,500 feet of the unconventional well. However, difficulty in managing multiple parameter lists and radius requirements for pre- and post-drill analyses led CNX to adopt a standardized pre- and post-drill analyte list informed by recommendations from multiple states, and expanded our post-drill radius to 2,500 feet.
This standardization, informed by Spring/Summer activities in 2024, reduced confusion across jurisdictions and enabled more direct comparisons to the four-quarter baseline analyses now conducted at new sites. As a result, when reviewing pre- and post-drill data for legacy wells like NV110, differences in parameter sets are due to the age of the pre-drill sampling and the iterative development of CNX’s post-drill program. This is why arsenic appears in pre-drill but not post-drill tests. The changes that came with the establishment of the RT program reflect CNX’s ongoing commitment to improving analytics and thorough environmental assessments at new well sites as we learn more and receive questions from communities.
Why doesn’t CNX test for and report more analytes?
We test for indicator analytes, not necessarily for every possible analyte or chemical in a groundwater sample. These are substances that, if elevated, suggest something may be wrong. For example, a spike in conductivity might indicate higher mineral content, prompting further examination of sodium, calcium, or total dissolved solids for a potential source of any increased mineral content.
Indicator parameters are an effective way to monitor water quality, allowing early detection and guiding further investigation if needed.
With this program, we’re not analyzing water samples to determine compliance with any set of required limits that are imposed on a public drinking water supplier. Instead, our focus is on education, transparency, and community awareness. That means we select analytes and methods that are widely accepted for screening, research, and environmental impact. To be clear, CNX’s water testing program is designed to diagnose an impact from gas development activity, not to determine water potability.
For example, while EPA Method 200.8 is often required for formal drinking water compliance (like the analysis you would see conducted by a public drinking water authority) due to its ultra-low detection limits, CNX may use EPA Method 6010 or similar methods that are applied under the Resource Conservation and Recovery Act (RCRA) and widely used to analyze for trace metals in aqueous samples. The method now utilized (specifically EPA Method 6010D) is part of the SW-846 compendium, EPA’s official set of methods for waste testing, and is recognized under 40 CFR Part 136. This set of methods govern test procedures for the analysis of pollutants in water. These methods are designed to be utilized to analyze environmental samples, including waste and groundwater, and are well-suited to our goal of identifying potential contamination from nearby gas development activities.
By aligning with these methods, we are able to detect indicator parameters that may suggest the need for further investigation and provide reliable screening data that can help residents see what’s in their water pre- and post-gas development activity.
Ultimately, our method selection reflects our commitment to Radical Transparency—giving communities the tools and information they need to make informed decisions about their water.

To summarize: all of this testing is not intended to determine potability. It is intended to detect whether there has been any impact on water wells from nearby gas drilling, and if so, to direct additional, more detailed investigation and, potentially, remediation, if warranted.
Certain testing methods listed in my results can be used to detect hundreds of different analytes – why don’t you provide all those results?
As discussed above, CNX provides its third-party environmental consultants a specific list of analytes for which to test. While an instrument like an Inductively Coupled Plasma – Optical Emission Spectroscopy (ICP/OES) or an ICP – Mass Spectroscopy unit, ICP-MS, can detect for nearly every element on the periodic table, that doesn’t mean each run or analysis captures the entire scope of an ICP's capabilities. Each analyte needs its own calibration curve, quality control checks, and other validations. Just because the instrument has the capability to “see” an element, does not mean that the unit has been calibrated or set up to run for every element. Different analytes utilize different sensitivities or have different interferences that must be accounted for depending on the analyte. This adds cost and complexity. As part of its water testing program, CNX requests specific information to be provided, and certified laboratories prepare instruments and calibrations to provide reliable results for those analytes specified. Instead, a helpful analogy is an x-ray machine. An x-ray can scan the whole body, but a doctor does not order a full body x-ray to diagnose the cause of foot pain. Rather, she orders an x-ray of the lower leg and foot.
Why doesn’t CNX test for everything DEP tests for using their SAC codes?
SAC Code stands for Standard Analysis Code and is part of the standardized system for identifying and/or requesting specific laboratory analysis at the DEP’s laboratory. CNX has limited experience with SAC codes, which only comes from cooperation with the DEP when conducting environmental investigations. SAC codes are internal Department identifiers that identify to the DEP’s lab in Harrisburg what analyses need to be run on an accompanying sample. These codes allow for accurate and efficient processing within their own laboratory and can also be utilized when there are specific testing requirements for permit compliance. However, pre- and post-drill programs are not permit requirements. Parameter lists provided to independent third-party labs from CNX for example perform the same function as the DEP’s internal organization (SAC) on their internal lab submission forms.
Why do my results reference EPA’s Safe Drinking Water standards if CNX doesn’t utilize drinking water test methods?
CNX is not a water purveyor and is not required to utilize drinking water test methods for its pre- or post-drill sampling. The methods that CNX utilizes for baseline analyses are validated methods recognized by regulatory agencies and yield a concentration result. Some metals are toxic at certain concentrations and by comparing the results we provide to the federally recognized safe drinking water standards (which define Maximum Contaminant Levels (MCLs)), you can assess whether the water may pose a health risk. While we aren’t certifying potable drinking water, we are providing homeowners/water purveyors with valuable information about their drinking water source to help them inform their decision to take corrective actions where needed. It’s important to remember we also provide this reference information with the pre-drill data – because regardless of gas activity, Pennsylvania well water can contain a number of constituents that may exceed the EPA’s safe drinking water standards. This is another example of CNX building community trust through transparency.

Conclusion
We hope this post offers insight and detail into CNX’s water quality program and Radical Transparency. CNX is deeply committed to helping residents understand the quality of their drinking water. As highlighted in a recent Context Corner article, our passion stems from years of observations: poor water well construction, lack of private water well construction standards in many states, and historically high levels of coliform and E. coli bacteria in private wells—serious human health issues that have a blind eye turned on them by local environmental groups.
While CNX doesn’t attempt to determine if water is safe to drink or certify water as safe to drink, we provide comparative data so homeowners and water purveyors can assess potential risks. Our goal is to empower communities with information—not just about potential drilling impacts, but about overall water health. We call on environmental groups who purport to care about these same goals to join in the responsibility to address these health concerns. Our communities deserve better and CNX is intent on filling the void left by enviromental groups and others who are simply ignoring such a serious matter.
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