Wednesday, March 31, 2010

PA DEP Continues to Analyze Dimock Water Supplies

PA DEP Continues to Analyze Dimock Water Supplies
Posted on: Friday, 27 March 2009, 13:00 CDT

No Indications of Contamination from Gas Well Hydro Fracturing Activities

WILKES-BARRE, Pa., March 27 /PRNewswire-USNewswire/ -- Responding to recent concerns expressed by residents of Dimock Township, Susquehanna County, the Department of Environmental Protection has collected dozens of water supply samples in the Carter Road area and determined that nearby gas well hydro fracturing activity has not impacted local wells.

"Our laboratory analyzed the water samples from wells in the area to look for indicators that would identify and indicate impacts from gas drilling and hydro fracturing," said DEP Northeast Regional Director Michael Bedrin.
Bedrin said indicators can include total dissolved solids, chlorides, specific conductivity, pH, alkalinity, hardness, sodium, calcium, barium, iron, manganese, potassium and aluminum.

"DEP will continue to pursue this investigation and collect additional samples so that residents can be assured their drinking water is safe," Bedrin added.

DEP has been actively investigating stray gas in Dimock since January when a resident reported an explosion in an outside well pit. Samples of private wells were taken from approximately 24 homes to check for dissolved methane. Nine wells were found to be impacted, with methane in four of those wells at levels that could pose a threat of explosion in enclosed areas of the home.

DEP cited these water wells in its request to Cabot Oil and Gas Co. for an ongoing alternative water supply and proper venting for as long as the methane readings remain at elevated levels. Cabot is providing those homes with alternative water supplies and is monitoring natural gas levels.

To date, no indoor vapor problems have been encountered. Additionally, the company has installed a treatment system at another home where the department concluded the water supply was impacted by drilling activities.

DEP is inspecting existing wells in the area and monitoring new drilling activity. The department continues to schedule residential visits to take water samples and monitor for gas.

"As Cabot implements its remedial actions, DEP will continue to sample home wells to determine if the company's activities are reducing the dissolved methane levels there," Bedrin said. "This procedure is time consuming and laborious, but it is a necessary process for us to get this problem solved."

Cabot corrected a recent records violation by submitting required drilling information.

The company is also implementing a new protocol for casing and cementing new gas wells. The new approach will address the unique geology of a particular area and will provide another barrier to migrating gas. For pre-existing wells, Cabot will install an additional cement sealer to prevent gas from migrating.

DEP recently opened a new oil and gas management district office in Williamsport to augment its regulatory activities in the state's north-central and northeastern regions of Marcellus Shale formation. The department has hired new staff for that office in addition to existing staff in Meadville, Pittsburgh and Harrisburg.

For further information, visit, keyword: Oil and Gas, then click on "Marcellus Shale."

CONTACT: Mark Carmon, 570-826-2511
SOURCE Pennsylvania Department of Environmental Protection
Source: PR Newswire
Very good article - glad to see progress is being made - I believe this stresses the importance of the following:
1.  Improvements to the upper terminus of the gas wells and using multiple casements and cement layers;
2. Sealing off and protecting the freshwater system - not just from the Marcellus but the shallow gas deposits.
(Multiple casings)
3. Confirmation testing on concrete seals.
4. Conducting base line analysis
5. Private well construction standards
6. Putting in place emergency response plans prior to drilling and not after.
7. Creating local hotline for calls
8. Getting citizens information and developing field screening tools.

Many of these issues are covered in proposed updated regulations.

EPA reviewing Superfund site - Reposting because of interest

This is not my work - but the work if Tom Ragan

EPA reviewing Superfund site

By TOM RAGAN (Staff Writer)

Published: March 31, 201
The U.S. Environmental Protection Agency is conducting a fourth five-year review at the McAdoo Associates Superfund site located in Kline Township and McAdoo Borough.
The first five-year review was completed in 1994 and the last one was completed and approved in July 2005.
More than 7,000 drums and six above-ground tanks have been removed since contamination was discovered in November 1979. EPA ordered removal of the waste from two locations in 1982.
The Superfund site is actually two sites about 1.3 miles apart. The one in McAdoo covers about one-third of an acre, and the other in Kline Township covers about 8 acres.
The five-year review is a requirement for EPA to inspect cleanups to make sure the site remains fully protective of human health and the environment.
"We do physical site inspections about every two years and we sample the groundwater and soil to ensure that the synthetic membrane cap is intact," Brad White, the EPA remedial project manager, said.
He said that just because the site was cleaned up 20 years ago doesn't mean it is completely clean.
"There is still residual contamination," White said.

The EPA will continue to monitor the site until there is nothing left to monitor. The site remains fenced off and samples will be taken to separate laboratories for testing, according to the EPA.
Area residents receive municipal water and are not exposed to contaminated water. The site once was linked to abnormally high cases of cancer but EPA officials say that there is no evidence of site-related cancers.
EPA officials will continue to monitor groundwater and soil at the site for many years to come.
The EPA invites the public to express any comments and concerns about either site located in Kline Township and McAdoo. Visit the EPA Web site for Superfund sites at:

The results of the five-year review are expected to be available in August 2010.

I have worked in the area and conducted some water quality monitoring and worked with local agency and Carbon County Groundwater Guardians - glad to see the area is getting a second look

Saturday, March 27, 2010

HB 2304 - prohibiting the Department of Environmental Protection and the Environmental Quality Board

A copy of HB 2304 can be found Here

Act prohibiting the Department of Environmental Protection and the Environmental Quality Board from promulgating rules and regulations under certain acts.  If the PADEP or the EQB finds it necessary to make a change to benefit the health, safety, and welfare of the public.  This should be done in a timely manner and not require notification on a federal level, but should be open to public comment.

I believe this would result in unnecessary delays.  It is likely that the review process by the Department and EQB has already been working on this issue for a period of time and it is critical that we have "living" legislation to address concerns that develop because of technology or an activity that was not visioned.

Just my thoughts


PS: I would prefer changing state law to establishing guidance documents and policies.

PA HB 1205 - Proposed changes Oil and Gas Law

A copy of PA HB 1205 can be found by following this link - HB 1205

Based on a review of this house bill - I like the following items:

1. Increasing the baseline radius to 2000 feet - but this does not address the issue of the horizontal leg of the well and does not really address local geology.  It is important to note that it is my professional opinion that the fracing process or horizontal leg of the well is not the point or portion of the drilling that is a primary area of concern.   The primary area of concern is the area around the well and drilling pad and the vertical wellbore construction and prevent of surface leaks and spills.  A company needs to have a Spill Prevention and Action Plan.

2. Increasing the time line - I am not sure 2-years is the best number, but it is better than 6 months.

3. The issue of prior contamination and timing in the law- the wording could be interpreted to mean that the baseline quality is solely based on an analysis that was collected 30 days prior to drilling.    This is not appropriate - If this raises a question in my mind - this is a potential weakness in the wording of the law.

4. The notification time line is not appropriate -the private well owners should be notified within 48 hours if there is a problem with the water quality that may pose a health concern and receive a written report in 30 to 60 days - 10 days for written is creating paper work - they need to get a copy of the testing results and there should be some form of education to help them understand the results and take action if needed.

5. Follow up water testing as written is not appropriate - if the time line is two years.  Then the gas company should test the water at least once a year for two years.   The follow-up testing should include the parameters tested in the initial baseline, plus any parameters specific to the chemicals or processes used in developing the well (see comment 8).

6. The proposed law does not address the issue of a possible contaminant event or concern.   The owner should have the right to have the Commonwealth Investigate water quality contamination events and the cost reimbursed by the Gas Company or a fund established by the Gas Company- if a gas company is found responsible.  If some other agent is found responsible - the PADEP should act on behalf of the private citizen to correct this issue.  

7. A fund should be established to help improve, fix, or abandon wells (Cement or grout them closed) that are identified as contaminated during the initial baseline assessment or found to be vulnerable pathways for future contamination.  It is in the benefit of the Commonwealth to eliminate this route of contamination or potential impact to the community.

8. Frac chemicals - I believe the listing of chemicals and MSDS sheets a company may used in the process is listed in the permit application to the state.  At a minimum, the Spill Prevention Plan should require the company to have MSDS sheets for these chemicals on-site, spill containment systems for these chemicals, and provide a summary of the chemicals and quantities used in the frac process or other processes.

Just my thoughts


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The Black Belt training program integrates online learning with hands-on data analysis. The course material provides an in-depth look at the DMAIC problem-solving methodology, as well as deployment and project development approaches. The course flow follows the DMAIC methodology, with the appropriate tools and concepts taught at each stage of project deployment. Since software will be used for data analysis, the course material concentrates on the application and use of the tools, rather than on detailed derivation of the statistical methods. Workshops are incorporated extensively throughout the training to challenge the student's analytical and problem-solving skills. Upon successful completion of the course, the student will achieve Black Belt Certification issued by their accredited college or university, using industry-acclaimed criteria endorsed by the International Quality Federation.

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House Bill 2235 - Moratorium for Leasing State Forest Land

Personally - I consider the mineral and gas rights owned by the State via State Forest and other land the same as a Royality Owner. A royality owner has the right to lease or not to lease property. I am a little concern about the 5 year time line and it was not clear in the regulations what is going to be done to fund this evaluation. To be honest, the State Forest and other leasing programs are significantly better than the Oil and Gas Law and permitting process used by the State. These programs have better provisions for control, siting, and bonding.

The primary weakness in the HB 2235 is that is does not appear to provide funding for the assessment and the assesment does not look at critical management options. These options, provisions, or considerations would include evaluating the leasing process to develop a lease that protects the environment and the states assests, feasibility analysis to determine if it may be better to allow the State to directly hirer a contractor to develop the Gas Resource rather than leasing out the resource ((This way that State in the gas business - why should we give away 80 % of this value),  PA should maintain ownership and control of the pore space and does not address issues related to how monies for leasing could be allocated and utilized to benefit the community.

Funds from leasing should be used in ways that helps us to get off fossil fuels - even the best estimates are there are only 100 years of gas available.  The money should not go to pay current salaries, but used to fund environmental education, alternative energy projects (such as grants to citizens to improve efficiency,  install solar, wind, or ground source systems - i.e., decrease energy demand and consumption and install systems at the point of us), sustainable infrastructure, improve water and wastewater treatment plants, purchase forested land for other drilling  (carbon capture) and other programs that create economic value and reduce energy and water consumption.

This bill only seems to cover conducting some type of environmental inventory, but provides nothing related to the interpretation of the data to make recommendations on areas that could be accessed via the vertical leg of the well.    Yes our forested lands are critical habitate, but we need to manage the resource.   Also - this assessment should include an easement of the geology for the area.   If the report only identifies the surface features, the recommendations may not make sense from a geological or energy stand point.

This bill only covers a portion of the work that is needed to evaluate the option to lease State Owned Land or not.  The HB should include an evaluation of Best Practices that should be utilizied in these areas. A partial listing of best practices may include the following:

a. Using partially degraded water or treated wastewater or stormwater for frac fluid and using recirculation systems;

b. Selecting Frac Chemicals that are as environmentally benign as possible and commercially available;

c. Prohibit the on-site disposal of cuttings and the use of lined ponds for storing water that had been used for fracking;

d. Require the implementation of a monitoring program that includes on-site monitoring wells and pre and post monitoring for streams, wetlands, and surfacewater;

e. Require a multiple casement approach that properly seals the unconsolidated and shallow consolidated aquifer and protects water with a TDS of < 10,000 mg/L;

f. The leasing process should not include provisions for deep well injection or carbon sequestration - these rights should be retained by PA (pore space should be owned by the state) and;

f. Require third party inspectors hirer by the State or the State should hire a gas company as a consultant and pay their fees, but PA maintain the full royality rights.
Just my thoughts


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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