Tuesday, March 9, 2010

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

1 comment:

  1. EPA Protects waters to a TDS of 10,000 mg/L

    EPA announces "Eyes on Drilling" tipline (01/27/10) We are asking citizens to call 1-877-919-4EPA (toll free) if they observe what appears to be illegal disposal of wastes or other suspicious oil and natural gas drilling activity. Anyone may also send reports by email to eyesondrilling@epa.gov.