25 PA Code 78 Oil and Gas Wells - Comments on New Regulations

Comments from

Mr. Brian Oram,
Our comments are as follows:
B.F. Environmental Consultants Inc. is in support of the proposed changes to 25 PA Code 78 Oil and Gas Wells as outlined in the draft regulations. The changes provide a significant improvement over existing regulations and help to protect local citizens and the environment. Based on a review of the draft regulations, the primary concerns were identified:
a. copies of permit applications be available for review at a local PADEP office;

b. it would be preferable to have a minimum annular space of at least 2 inch and not 1-inch around the casing;

c. placement of the casements should be based on a field measurement of conductivity to ensure that the well is protecting both the freshwater zone and the water bearing zone with a total dissolved solids of < 10,000 mg/l. This is an EPA requirement, i.e., USDW- Determination of Underground Sources of Water;

d. in all cases, a multiple casing or string approach should be used to separate the shallow and deep groundwater flow system- because of the fractured nature of the local bedrock it is not appropriate to use a single string to seal off a freshwater, saline, or brackish water zones;
e. Copies of frac chemicals and other chemicals used at developing or maintaining these wells with copies of MSDS sheets should be available at a location when each community or municipality; and
f. If possible, the third party inspectors should be individuals that carry a license or certification by Pennsylvania and have specific training and experience to provide this service.
Just my comments - related to proposed regulations.

Mr. Brian Oram