Geologist concerned about drilling truck traffic

Reposting of Article
Geologist concerned about drilling truck traffic

By Elizabeth Skrapits (Staff Writer)
Published: February 19, 2010

DALLAS TWP. - Back Mountain Community Partnership members heard from a geologist Thursday about the use of water in natural gas drilling and what happens to the salt- and chemical-laden water afterwards.
EnCana Oil and Gas USA Inc., in partnership with WhitMar Exploration Co., plan to drill three exploratory natural gas wells in Luzerne County: in Fairmount Township near the Ricketts Glen Hotel on Route 118; in Lake Township on Zosh Road near the Lehman Township border; and in Lehman Township on Peaceful Valley Road.

WhitMar/EnCana have leased more than 15,000 acres in the Back Mountain area, BMCP Chairman Allen Fox of Jackson Township said.

Of the BMCP member municipalities, the companies have leased approximately 4,300 acres in Lehman Township, 2,400 in Jackson Township, 1,300 in Dallas Township, and no acreage yet in Dallas Borough or Franklin and Kingston townships, according to Fox.
EnCana representatives attended the January BMCP meeting, where residents peppered them with questions, primarily about water contamination concerns and potential effects of drilling on the environment.
The company did respond in writing, but BMCP members have not had a chance to read and digest it, so they will wait until the March meeting to present it, Fox said. But Wilkes University geologist Brian Oram was on hand at Thursday's meeting to talk about drilling and water.

Hydraulic fracturing - "fracking" - involves blasting thousands of gallons of water deep underground to break up the shale, which releases natural gas.
Only 10 percent to 30 percent of the water comes back, and what does can be re-used for fracking, Oram said. Often water is hauled to wastewater treatment plants, where it is diluted for re-use, he said, but noted that there are no facilities in the area for treating the briny water. He believes getting rid of used water will be one of natural gas drillers' biggest hurdles in the region.

A treatment facility was recently approved in Williamsport; another is scheduled to open in the Muncy area, BMCP vice-chairman James Reino of Kingston Township said.
Wyoming Valley Sanitary Authority is working with Scranton-based PA Northeast Aqua Resources LLC on a plan to treat up to 150,000 gallons of fracking water a day, but so far has not received approval from the state Department of Environmental Protection.

Franklin Township representative Michael Prokopchack asked how the briny water from fracking was different from the salt water sprayed on roads.
Fracking water can contain trace elements including metals and organic chemicals, Oram said. Salt water used for roads does not have the contaminants, he said.

But there is an impact on the shallow freshwater aquifer from road salt, Oram said. And he is more concerned about the trucks carrying used fracking water.
"I don't have a big fear of fracking a Marcellus Shale well. I have a bigger fear of that truck going down the road, tipping over, and we have private wells that have no construction standards," he said. "I spent the last 20 years of my life dealing with people who have the worst-constructed private wells."
Another concern of Oram's is that there aren't any independent, Pennsylvania-based third-party inspectors available to make sure the well casings are done in the right way, using the proper grade of cement.
"Is it fair to say an 18-hole golf course will use more water for irrigation than it does in fracking?" Prokopchak asked.
"Absolutely," Oram replied. However, he said the difference is that while golf course irrigation consumes water, it puts it back into the atmosphere while fracking takes it out of the cycle altogether.
Oram said he would prefer to see partially-degraded water used for fracking rather than taking it from a "nice pristine freshwater stream." He also would like to see water transported by rail instead of by road. There needs to be long-term planning, he said.
eskrapits@citizensvoice.com, 570-821-2072

Comments
Good Article - my only comments are as follows:

a. Proposed legislation being considered should be supported and will provide a significant step in improving and protecting the health/safety of the community and the environment and maintain the integrity of the resource.

b.Third party inspections should be done by PA - Businesses using PA licensed professionals.

c. We need to look at long-term planning for this industry and begin to think "out of the box" on issues related to managing the water resources, water reuse, and stormwater management.

d. We need private well construction standards and we need to encourage private well owners to get their water tested, identifiy problems with existing well construction, and aid in improving/fixing well construction issues - remember - "We All Live Downstream"

Thanks

Brian

DEP revising oil and gas well regs

This is a reposting of an article- I think it is critical for citizens, professionals, and organizations to review and comment.


Public comment sought by March 2
By SANDY LONG

PENNSYLVANIA — In efforts to provide better protection to Pennsylvania’s water resources, the state’s Department of Environmental Protection (DEP) is revising its existing rules for the construction of oil and gas wells and soliciting comments on the proposed revisions by March 2.

The proposed rulemaking would incorporate and update existing requirements, with modifications, regarding the drilling, casing, cementing, testing, monitoring and plugging of oil and gas wells.

The effects of unregulated drilling are still being addressed today. Last year, the DEP plugged 259 abandoned oil and gas wells located in the western and north-central regions of the state in nine counties. Many of the wells were leaking oil, acid mine drainage or natural gas.

The department has documented more than 8,600 wells throughout the state that were abandoned prior to the passage of modern oil and gas drilling regulations.

“Abandoned wells create passageways for pollution to enter and contaminate drinking water,” said DEP secretary John Hanger. “They also can allow natural gas to enter water supplies or build up in a home, which can create a dangerous enclosed space. Modern regulations require that wells be cased properly during use and sealed once they are taken out of service but, unfortunately, there are thousands of wells that were simply abandoned before people understood the dangers.”

The costs to plug a well vary with its age, depth and the terrain in which it is found. Typically, DEP crews clear a site and clean or remove the old well. After casings are removed and the well bore is clear, the well is filled with grout or cement and other materials.

Funding for the state’s Abandoned and Orphan Well Plugging Program comes from surcharges on well-drilling permits and from the Growing Greener program.

According to the DEP, Pennsylvania has the highest number of abandoned wells in the Appalachian region and is one of the top five states nationally. Since the first commercial oil well was drilled in Pennsylvania in 1859, DEP estimates as many as 350,000 oil and gas wells have been drilled in the state, with many of those wells having been abandoned without proper plugging.

Locally, the Wayne Conservation District has begun investigating the locations of such wells in the county. To report an abandoned well, call 570/253-0930.

View the proposed changes to the gas and oil well regulations at

http://www.dep.state.pa.us/dep/deputate/minres/oilgas/Oil%20&%20Gas%20Documents/CHAPTER%2078%20Revisions%20January%2027%202010.pdf

Written comments on the draft proposed rulemaking should be sent to the DEP, Bureau of Oil and Gas Management, P.O. Box 8765, Harrisburg, PA 17105-8765. Comments may also be submitted electronically to the department at ra-epoilandgas@state.pa.us.

Is flowback and waste from gas drilling radioactive?

This is a reposting of an article writtent by Sharon Corderman - but I get this question alot.

Rewards and Risks of the Marcellus
Part I in a series
By Sharon Corderman
Published: Wednesday, February 17, 2010 2:46 PM CST

Claims have been made that the potential exists for some level of radioactive material to be in the wastewater and drill cuttings coming from the Marcellus shale. According to Peter Davies, professor of biology at Cornell University, New York’s Department of Environmental Conservation (DEC) reported that brine samples taken from 12 Marcellus wells that were actively producing gas last year came back with higher than expected levels of “NORM” - naturally occurring radioactive material. In fact, some brines were reported to have levels of radium-226 as high as 250 times the allowable level for discharge into the environment and thousands of times higher than the maximum allowed in drinking water.
The Penn State School of Forest Resources released a water guide for landowners in 2008 that warns that “gas well waste fluids usually contain levels of some pollutants that are far above levels considered safe for drinking water supplies. As a result, even small amounts of pollution from waste fluids can result in significant impacts to nearby drinking water supplies.” Bryan Swistock a Penn State water resources extension specialist who prepared the guide, said that there is not a large risk, “but the idea that there is no risk, which is what some people will say, is far from the truth.”
“It is especially important to understand the potential radioactivity of wastes that may be disposed of in areas that are located close to residences or public facilities such as schools,” wrote Lisa Sumi in a May 2008 report prepared for the Oil & Gas Accountability Project. “For example,” she continued, “during drilling, there may be a large volume of radioactive Marcellus shale rock removed (in other words, the drill cuttings), especially from horizontally drilled wells. If these rock wastes are disposed of by on-site burial or land-spreading, the radioactivity may become an issue for those living nearby. Radioactive wastes should be taken to a facility that is designed to handle low-level radioactive waste.”
In recommendations to the New York DEC for the handling and disposal of these radioactive wastes, Professor Davies stated that while these NORM wastes are known as “naturally occurring” it should be emphasized that such materials are not normal just because they are naturally occurring at thousands of feet below the surface. “On the surface they are not part of the normal environment and should be treated as hazardous,” he said.

My Comments

1. Yes the shale may be more radioactive then some of the rocks near the surface, but the cutting are properly handled and disposed.

2. I believe we have more low level radiological waste from the medical community and we still not have not addressed the issue of spent fuel rods.

3. Radon in Air - this is already a problem and concern for much of PA - You should have your Radon in Air Level Checked NOW - Website Reference
http://www.water-research.net/radonwater.htm

4. If levels of radiological elevated, this would suggest that the brine water should be returned to the ground via deep well injection.

Natural Gas Drilling Tip Line - Direct to EPA Region 3

Natural Gas Drilling Tip Line


EPA's Mid-Atlantic Region has a natural gas drilling tip line for reporting dumping and other illegal or suspicious hauling and/or disposal activities.
Tip line number (toll free): 1-877-919-4372 (877-919-4EPA)
URL: http://www.epa.gov/region03/marcellus_shale/tipline.html
Tip email address: eyesondrilling@epa.gov
Tip mailing address:

EPA Region 3

1650 Arch Street (3CEOO)

Philadelphia, PA 19103-2029



Documenting Suspicious Activity:

To the extent possible, record:

• Location of the event

• Date of the event

• Time of the event

• Who, if anyone you interacted with during the event
Photos and videos are great ways to document observations. Be sure to record the date and time the photo or video was taken. Email your digital files, or mail your photographic prints, video cassettes, or CD-ROM disks to EPA using the contact information above.
When describing what you observed, include:

• Activity taking place, including description of equipment and materials involved

• Descriptions of vehicles

- Color

- Company name or logo

- License plate number

- Type of vehicle

• Destination of discharge (physical location and stream name, if known)

• Environmental impacts: discoloration, dying vegetation, dead fish or other wildlife.

Effort to support - local citizen and watershed groups and local government

Recommended Natural Gas Well Construction Techniques for Pennsylvania

Because of the recent interest in the Marcellus Shale in PA, there has been a significant increase in drilling of deep natural gas production wells.  One of the primary concerns or issues is Pennsylvania, would be the potential for these wells to impact surrounding freshwater wells.  Since most of these freshwater wells are wells that are classified as private or unregulated wells and these wells are typically constructed with no minimal construction standard, a primary concern for developing the Marcellus Shale would be to throughly document the construction characteristics, water level, and quality of these wells.   Since it may not be easy to modifiy the existing wells, the primary recommendations are as follows:

1. A detailed well inventory should be completed and it could be supplemented by the PAGWIS database.
2. The private well data that is critical would be the well location (GPS- using same standard or better and datum) that is being used by the Department of Conservation and Natural Resources - Web Driller Website.  The following is the information that is required for the on-line well submission form- http://www.dcnr.state.pa.us/topogeo/groundwater/WebDriller/wdtips.aspx

Driller Well ID – A unique identification number assigned by the driller. It can be any unique combination up to 15 characters long. Once the report is submitted, this number cannot be changed.


Type of Activity – The subject of the driller’s report. “New Well” is the default activity. Click on the dropdown menu to select something other than “New Well.” When another option is chosen, a new box opens up: “Original Well By.” Select the appropriate button (either “Current Driller” or “Another Driller”). If “Another Driller” is selected, an additional box appears asking for the name of the “Original Driller.” If the original driller is not known, indicate “unknown.” If “Well Abandonment” is chosen as the Type of Activity, an additional box “Reason for Abandonment” appears. Select the reason from the dropdown menu.

Date Drilled – Click the date on the calendar.

Drilling Method – Select from the dropdown menu.

Owner – This can be a business entity or a person.

Coordinate Method – The method of determining the well’s location coordinates. Choose from the dropdown menu. When using a hand-held GPS for determining the coordinates, choose “GPS – Global Positioning System.”

Location Type – The type of coordinate system used to locate the well. Choose between “Latitude/Longitude” and “UTM.” Latitude/longitude is the most common method. UTM stands for the Universal Transverse Mercator global coordinate system that is based in meters. If UTM is selected, the latitude and longitude boxes change to the required fields of “UTM Northing” and “UTM Easting.”

Latitude and Longitude – Values of the coordinates of the well location. If using a GPS, set your GPS units to “decimal degrees,” and your datum to North American Datum (NAD) 1983. Latitude and longitude must be reported in decimal degrees in this format: xx.xxxxx for latitude and (negative) -xx.xxxxx for longitude. This format should be set on your GPS as decimal degrees. To convert “degrees and decimal minutes” to “decimal degrees,” divide the minutes by 60 and add this number to the degrees. (There are 60 minutes in a degree and 60 seconds in a minute. There are 3,600 seconds in a degree.)

3.  The size of the pump should be documented, drillers log reviewed, and water level measured.
4. Regarding baseline monitoring, the monitoring should include parameters that can be related to the drinking water standard, parameters characteristic of saline/brine water, parameters that may be related to existing sources of contamination, and constituents related to the mixture and blend of fracing and development chemicals used on-site.
5. Based on a review of the private well logs and water levels, it may be advisable to use a multiple freshwater casing approach.  This multiple casing approach would add additional casing to provide a second barrier between the shallow and deeper portions of the freshwater aquifer.  For most of NEPA, it would be likely that the first cemented casement should probably be at a depth of 250 to 300 feet, the next casement at about 700 to 800 feet, next casement maybe 1500 to 2000 feet, and finally something at about  2500 to 3000 feet.  This would properly seal off freshwater, saline water, and most shallow gas.    In addition, the inner most cement should not just extend 500 to 1000 feet above the kickoff point, but extend up into the protective casing or better to the surface.
6. From the results of the background analysis, the results should not only be used to establish a formal baseline, but used by the community to identify areas were the wells should be improved or upgraded.  The solution to a contaminated private well may not be simply adding treatment, but modifying the well to prevent the contamination from occurring or abandoning the well and drilling a new sanitary well.
7. Local agencies should implement a Water Well Construction and Siting Ordinance and require existing wells that are contaminate to be properly repaired and upgraded.
 
Just a few thoughts
 
Brian Oram, PG
B.F. Environmental Consultants Inc.
other posts on this subject -

Getting Your Water Tested – Why?

In Pennsylvania, there are no statewide regulations that truly guarantee that a private well is properly constructed and that the water from the well is potable, i.e., drinkable. In Pennsylvania and other states, a private well is not defined as a public water supply system and not regulated by the PADEP or EPA. There are some counties in Pennsylvania that do provide some regulatory oversight with respect to the siting, construction, and water quality for a private well beyond the generalized recommendation that private wells be located 100 feet from a septic system. In general, the EPA and other organizations have recommended that private wells are tested at least annually and the testing should be conducted using certified and approved procedures and/or conducted by a certified laboratory. Because of the large-scale and extent of the Marcellus Shale Formation and concerns related to the chemical and biological nature of the formation fluid and frac fluids, the primary recommendation from professionals, state agencies, and others is that private wellowners should have their water tested following the same process that is used for regulated water supplies.

The sampling process used for regulated water supplies follows a protocol known as a Chain-of-Custody. For this process, a third-party person, i.e., not the wellowner or an interested party, that has been trained and approved by a certified laboratory will collect a water sampling following approved and standard practices. This individual will document the time and location of the testing, specific the list of parameters to be tested, document the water conditions in the field, and in some cases conduct some type of field testing or analysis. The third party sampler should document the type of water source, i.e., well, spring, or surfacewater. If the water is treated, the third party sampler should document the type of treatment system. If the private well has a treatment system, it may be advisable to collect a water sample before and after the existing treatment system. The sampler then properly labels the containers, completes the chain-of-custody documents, and transports the samples as required by the state-certified or National Environmental Laboratory Accreditation Program (NELAP) certified laboratory. The sampler role is to make sure the samples were properly collected, preserved, and transported to the laboratory. When the sampler returns to the laboratory, the certified laboratory will review the sampling and collection process, check sample temperature, and review chain-of-custody sheet. If the sampler followed the laboratory protocols, the laboratory will accept the samples and sign the chain-of-custody documents. These documents will follow the sample through the laboratory testing process and a copy of this sheet will typically be provided with the laboratory results. The certified laboratory is required to maintain a copy of these records for a period of at least five years. Because the records are owned by the client, it is strongly recommend that the private well owner or water supply owner contract with the laboratory rather than relying on a company or corporation to pay to conduct this background analysis. If you rely on a company or corporation to pay or contact with the laboratory, it would be in your best interest to have the company agree to provide you a copy of the results within a timely manner and you should be given the right to directly request copies of the results from the laboratory. By using this process, the data that is collected should withstand cross-examination and be supportive of any legal action.

There is no statewide certification for water samplers, but it would be advisable to use an individual that is approved by the laboratory, an individual that carries a profession license, or by an agent for the laboratory. Because the sampling and laboratory testing may be part of a legal action, it would be advisable to use an individual that is a licensed professional or an employee of a certified laboratory. It would be best if this individual is experienced and has provided expert testimony in the Commonwealth. If you would like more information on drinking water quality in Pennsylvania, I would recommend you visit the Center for Environmental Quality at Wilkes University – http://www.water-research.net. Regarding baseline sampling, it is best if this testing is conducted prior to major construction or exploration activity, but even after activity may have started this information will provide a baseline for documenting the existing conditions of the water supply. In addition to documenting water quality and appearance, it may be advisable to document the static and dynamic water level in the well and yield of the well.

If you are interested in participating in the development of a regional database of water quality data for private wells, please contact Mr Brian Oram at Wilkes University- brian.oram@wilkes.edu. If you would like more information on background water quality analysis and laboratory testing or would like someone to meet with you or your group, please contact B.F. Environmental Consultants at http://www.bfenvironmental.com or (570) 675-0253.


Respectfully submitted


Mr. Brian Oram, PG

Workforce Development Related to the Marcellus Shale and Environmental Careers in Northeastern PA

The development of the Marcellus Shale in Northeastern Pennsylvania has resulted in the need for additional and continued training on a number of environmental issues and health and safety practices. To meet this demand, B.F. Environmental Consultants has developed the Online University to help provide affordable education, certification programs, and continuing education courses on subjects ranging from bloodborne pathogens, alternative energy, workforce development, petrochemical, geotechnical, OSHA, HAZWOPER Training, environmental monitoring, and more.

The program and outreach provides education and information to the community, workforce, and industry. The Safety engineering courses encompass a wide variety of online classes designed to help those in the health and safety professions increase their knowledge with such diverse areas as: Control of Hazardous Energy (Lockout/Tagout),
Fire Protection and Prevention, Legionnaires’ Disease, Permit-Required-Confined Spaces, Small Business Safety and Health Management, OSHA, HAZOPER, and much more.

The Petrochemical Oil and Gas courses are self-paced and open enrollment, and many offer mandatory continuing education credits. A wide variety of topics are covered in this category including the transportation of liquids in pipelines, technologies for oil and gas exploration, and types of corrosion and control techniques. In the Gas Pipeline Hydraulics course, students will learn how to calculate the properties of a natural gas mixture.

The comprehensive geotechnical engineering training courses include training in the Design and Construction of Earth Dams, lateral earth pressure, retaining walls, bearing capacity of shallow footings and soil properties.

For More Information on these Training Opportunities - please visit
http://www.bfenvironmental.com/engineers.php

Petrochemical Training Courses

Advanced Oil & Gas Drilling and Completion Technologies Training Course is an online training course offered through B.F. Environmental Consultants Inc. The course outlines the current best practices and modern technology has allowed for more efficiency in the search and drilling for oil and gas. Today, more resources are found using fewer wells and at the same time are drilled deeper and faster than ever before while encountering fewer dry holes. The course covers horizontal direction drilling, multilateral drilling, synthetic muds, and MWD Technology.

A few of the technologies used today that have made drilling less costly with a higher success rate and at the same time reducing environmental impacts include the following:

Horizontal and directional drilling
Multilateral drilling
Polycrystalline Diamond Compact (PDC) drill bits
Synthetic drilling muds
Measurement-While-Drilling (MWD) technology

In this course, the student will review the sections and fact sheets covering drilling and completions from the U.S. Department of Energy's Office of Fossil Energy's publication "Environmental Benefits of Advanced Oil and Gas Exploration and Production". This course is most relevant to engineers wishing to attain knowledge on several of the advanced technologies used today in oil and gas drilling and well completion.

The student must take a multiple-choice quiz consisting of twenty (20) questions at the end of the course to obtain PDH credits.

Specific Knowledge or Skill Attained

This course teaches the following specific knowledge and skills:

Latest advances in drilling bits and drilling muds
Horizontal, directional, and multilateral drilling techniques
Hydraulic and CO2-sand fracturing techniques used to stimulate production of declining formations
The environmental and economic benefits of coiled tubing relative to drilling pipe
Measurement-While-Drilling technology used to measure downhole and formation parameters to allow more efficient, safer and more accurate drilling.

To learn more about this course - go to
http://www.bfenvironmental.com/energy.php

For a full listing of our petrochemical training programs, go to
http://www.bfenvironmental.com/workshops.php

25 PA Code Ch. 95 Wastewater Treatment Requirements - Comment letter

To Whom It May Concern:

It is critical that our state government take a long-term and proactive action in the establishment of discharge criteria for industrial discharges in the Commonwealth of Pennsylvania. Discharges that contain high salinity and may contain trace levels of metals, organics, and other materials, or substances that may pose an unidentified synergistic reaction or impact, should be thoroughly covered. With the rapid increase of Marcellus Shale and Black Shale Development, special attention should be given to flowback, production, and brine water discharge activity. The communities and businesses within Pennsylvania rely on our freshwater resources for potable water, recreational and wildlife habitat, and to support ecotourism. With these concerns in mind, the Pocono Northeast Resource, Conservation & Development Council is strongly encouraging the following recommendations related to the proposed revisions to “25 PA Code Ch. 95 Wastewater Treatment Requirements.”

Baseline Data

1. The maximum daily effluent concentration and mass loading should be established based on base-flow conditions, and it should take into consideration the impacts associated from up-gradient sources of point / non-point pollution with the primary goal of maintaining a TDS of not more than 500 mg/L in stream at the point of discharge. For sulfates and chlorides, the permit should establish a maximum in-stream concentration at the point of discharge of 250 mg/L, and it would be advisable to develop enhanced standards for oxygen, biological oxygen demand, sodium, and other key water quality parameters. These additional standards should be established because the increased salinity will alter the solubility and rate of natural re-aeration.

2. Because most of our freshwater systems are low in alkalinity, the effluent criteria should evaluate the potential for the formation of chemical precipitates that result in reducing the alkalinity of the receiving water.

3. It would be advisable to conduct biological toxicity testing of each waste stream to identify unanticipated synergistic affects or the possibility for bioaccumulation.


Permitting Process
1. The permitting process should require establishment of the baseline quality of the waste stream. The waste characterization should include a suite of biological, organic, major cations/anions, radionuclides, and other parameters that are specific to the industrial process and chemicals used in the development activity. For Marcellus Shale operations, this would include a characterization of the flow back, production, and brine water effluent, and include a detailed accounting of the types and quantity of chemicals used in the process.

2. The permitting process should be designed to encourage industrial users to reuse and recycle water and segregate waste streams. The waste streams should be segregated at the treatment facility.

3. Since each Marcellus Shale drilling operation is unique, the permitting process should require characterization of each waste stream from each well pad. The permitting process should also require the applicant to submit a copy of the hydraulic fracture sequence, chemical type and quantity used, detailed MSDS sheets, and other information characterizing the waste.

4. The permitting process should be divided into industry specific categories that take into consideration the fluid characteristics, volume, and impacts of each waste stream.

5. The permitting process should include a requirement for cradle to grave tracking of water used in each operation and the wastes generated by the respective operation. This requirement would provide for detailed accounting of the water and waste generated by a project. This effort should be coordinated with the SRBC or DRBC.

6. The permitting process should address issues and concerns related to aquatic invasive species and require proper disinfection and treatment of vehicles and other containers used to convey the wastewater.

Permit Fees
1. Permit fees should be set at a level to provide and fund long-term up-gradient and down-gradient monitoring for biological and chemical parameters. This monitoring should also include monitoring areas immediately up-gradient of potable water intakes, and the funding should facilitate the access to real-time monitoring data for communities and water suppliers to help fund the research and development of innovative treatment or water reuse systems to manage this water.

Treatment Plants
1. The treatment plant permit needs to include controls to inhibit the growth of aquatic invasive species in holding tanks, equalization tanks, or other treatment tanks used to store or process the brine, frac, or process water. If the system does not prevent the growth of these invasive species, the holding tanks or equalization systems will become a suitable environment for these organisms to become established within the watershed.

If you have any questions or comments, please contact the Pocono RC&D Council at 570-282-8732 ext. 604.