Saturday, April 24, 2010

DEP fines driller for illegally transferring fracking water

Reporting of an Article "DEP fines driller for illegally transferring fracking water" -
Wayne Independent
Sat Apr 24, 2010, 08:00 AM EDT
Williamsport, Pa. -

The Department of Environmental Protection has fined Stallion Oilfield Services of Canonsburg $6,500 for operating a transfer station without a permit last year at its facility in Old Lycoming Township, Lycoming County.

The financial penalty represents DEP’s latest enforcement action against Stallion. It previously issued a notice of violation to the company in June 2009, which prompted the company to stop operating its transfer station.

“DEP conducted an inspection at Stallion in June 2009 and discovered that the company was operating a fracking water transfer station without the required DEP permit,” said DEP North-central Regional Director Robert Yowell. “Businesses that support the natural gas exploration industry like Stallion must improve their compliance with Pennsylvania’s waste management regulations. DEP continues to look aggressively for these illegal transfer stations and will take appropriate enforcement action whenever we find them.”

There were 21 fracking water tanks at the site divided into two staging areas. The tanks were used to store fracking flowback water from natural gas wells.

DEP inspectors also found a 450-square foot area where fracking water had spilled onto the ground. Soil samples showed high levels of chlorides and barium, which are common constituents of fracking water. Stallion subsequently excavated and properly disposed of about seven cubic yards of soil.

DEP’s follow-up inspection in August 2009 confirmed that the company had halted the illegal transfer station activity.

The fine was paid to the Solid Waste Abatement Fund, which helps to pay for cleanups across the state.

For more information, call (570)327-3659 or visit

My main comment - Great Job !- Fine should be significantly higher- lets start adding some zeros.  This fine probably does not cover the cost for the additional inspections and oversight of cleanup.

Thursday, April 22, 2010

Well testing offered to residents near drilling site Luzerne County, PA

This is a reprint of a news article.

Well testing offered to residents near drilling site

By Elizabeth Skrapits (Staff Writer)
Published: April 21, 2010

LEHMAN TWP. - Residents near a planned natural gas well site in Lake Township were advised Tuesday to take advantage of an opportunity to have their private wells tested.
Encana Oil & Gas USA Inc., in partnership with WhitMar Exploration Co., has selected the Salansky property on Sholtis Road in Lake Township as the site of the second of three proposed exploratory natural gas wells in Luzerne County.
State regulations require natural gas drilling companies to sample drinking water wells within 1,000 feet of their drilling sites, but Encana is testing within a 1-mile radius of its proposed drilling sites.
The companies plan to start drilling at the Lake Township site in July if they can receive the required permissions, Encana Spokeswoman Wendy Wiedenbeck said. The first site to be drilled will be the Buda property behind the Ricketts Glen Hotel in Fairmount Township, in June. Although the companies have required permits to drill at a third site, the Lansberry property in Lehman Township, Wiedenbeck said she is not sure when drilling will start there.
Encana has retained Lancaster-based RETTEW Associates Inc. as a third-party firm to do the sampling, and King-of-Prussia-based TestAmerica as its independent laboratory to do the tests.
Drilling will not start until the water testing is complete, Wiedenbeck said. The reason for the water testing is to establish a baseline, or show what is in peoples' well water before the drilling starts.
A few residents expressed concern about a similar situation like that in Dimock Township, where 14 families' wells were invaded by methane. The state Department of Environmental Protection fined Cabot Oil & Gas Corp., made the company cap three wells, and put a stop to more drilling within a 9-square-mile radius of the township for at least a year. The problem is believed to have been caused by a faulty well casing.
Encana will follow protocols so as not to repeat the mistakes of the other well operator, according to Wiedenbeck. Differences include two well casings, the first of which will go at least 50 feet below the nearest known water source.

"I don't know if there's anything I can say to erase the concern from another's mistake," Wiedenbeck said. "We will take steps so we do not impact the water."

On questioning, Wiedenbeck admitted Encana may have had an impact to a water source - a stream - while drilling in Colorado, but said state environmental authorities were called immediately and the company implemented a new protocol afterwards.

Although people seem to have a lot of concerns about the hydraulic fracturing process, Wiedenbeck said the biggest concern should be about the well bore instead of 7,000 feet underground: the well bore integrity will prevent fluids and gas from migrating.

If Encana did impact residents' water, the company would be responsible to make sure they had drinkable, usable water the same as before the incident, she said.

"I think they (Encana) danced around some of the questions, but the water testing is a good idea, at least to give us a baseline," Jeffrey Chulick, who lives near the Lake Township site, said after the meeting when asked what he thought. "I'm not sure about the natural gas drilling, though."

After the question-and-answer session with Encana, Wilkes University hydrogeologist Brian Oram gave a presentation on what's underground and in the water in the region.
Oram, who is not involved with the water sampling or acting as a consultant to Encana - "My role isn't to swing somebody either way," as he put it - did advise people to have the water sampling done.
He said in his 20 years of doing baseline water testing in Luzerne County, he found 30 percent to 50 percent of private wells were contaminated. For example, methane was discovered in wells in Tunkhannock and Columbia County even before Marcellus Shale drilling started there, Oram said., 570-821-2072
Reposting of article - My presentation can be found at



Saturday, April 17, 2010

PADEP Takes Action on Cabot Oil and Gas - 240,000 fine

Note: This is not my work - but the work of Jon Hurdle - Great Job !

"By Jon Hurdle

PHILADELPHIA, April 15 (Reuters) - Pennsylvania fined Cabot Oil & Gas Corp $240,000 and ordered it to permanently shut three gas wells in the state's most aggressive action so far to control development of natural gas in the Marcellus Shale.
The state's Department of Environmental Protection said Cabot failed to comply with a November 2009 order to fix defective well casings that discharged natural gas into groundwater, contaminating the drinking water of 14 homes in the rural community of Dimock, northeast Pennsylvania.
The new order directs the company to install permanent water-treatment systems in the homes within 30 days. Cabot must also pay a fine of $30,000 a month until it meets the DEP's requirements.
DEP Secretary John Hanger called the action the "most aggressive" taken by Pennsylvania so far toward any company drilling in the Marcellus Shale and said it should be taken as a warning to others that regulators will not tolerate the law violations.
The DEP also banned Cabot from drilling any new wells in the Dimock area for at least a year and blocked any new drilling statewide until it meets the requirements of the new order.
Cabot is seeking at least 25 additional drilling permits in other areas of the state, said DEP Secretary John Hanger.

Officials are looking at 15 other Cabot gas wells that may also be shut off if they are found to be the source of migrating methane, the statement said.

Recent exploitation of massive shale gas reserves in Pennsylvania and other states offers the United States a potentially abundant source of clean energy that would reduce dependence on imported oil.
But the Marcellus' development may be slowed by regulation as a result of fears about escaping methane and contamination of ground water by the chemicals used in the hydraulic fracturing drilling technique.
Concern about the drilling, also known as "fracking," has so far prevented its use in New York state and prompted a bill in Congress that would require companies to disclose the chemicals.

In November last year, Dimock residents sued Cabot, claiming gas drilling contaminated their water wells with toxic chemicals, caused sickness and reduced property values.

"Gas migration is a serious issue that can have dire consequences to affected communities and we will not allow Pennsylvania's citizens to be put in harm's way by companies that chose not to follow the law," said Hanger, in a statement.

Cabot agreed to provide potable water to the 14 households, and to pay the fines.

"This modified order does not impact the number of wells scheduled to be drilled under Cabot's 2010 drilling effort, nor will it impact our production guidance," Cabot chief executive Dan Dinges said in a statement.
DEP spokesman Tom Rathbun said the gas migration appears to have resulted from Cabot drilling through the shallow Devonian rock formation to reach gas in the deeper Marcellus reserve.
Hanger said Cabot has established the worst record in the industry.

"I'm glad to say that Cabot has so far been in a class by itself," Hanger told Reuters."

My comment -

Excellent - I think it is critical that Cabot pay the fines, the cost of clean-up, cost to fully understand the problem,  and deal with citizens/community.  I think they should NOT be able to drill until they can prove they can install these wells properly. 

Also, there bonding rates should be higher.  I would hope a report is produced that outlines the specific causes for the problems so the industry and PADEP can take action to prevent this from happening.  I would hope this report is made public in a timely manner - so we can learn from their mistakes.
If they, i.e., Cabot, can not drill safely and install the wells in bedrock that is near horizontal - what is going to happen when the rock is slightly folded?

Water Monitoring supplies and equipment

Wednesday, April 14, 2010

Marcellus Shale Baseline water testing or Water Testing for Informational Purposes

What I have to test my water?

For the past 20 years, I have stressed the importance of water testing for private wells. 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.

 Now - it is even more critical to get your water tested. 
Water Testing Options-

Option 1- Testing Provided or Conducted by Gas Company.
Option 2- Legal Baseline Assessment
Option 3 - Informational Water Testing- not a legal baseline.

Option 1 - Gas Company Baseline Testing- Marcellus Shale
The gas companies may be required to collect baseline water quality samples from wells and possibly surfacewater features (springs) within a 1000 feet of the well.  They should be using third party contractors - hired professionals that are experience or trained and not empolyees of the Company.  Since there is no certification as a water sampler, the individuals should be working directly under the supervision of a PA licensed professional with expertise in groundwater systems/wells/ water treatment,  a certified water or wastewater operator, or an agent of a certified laboratory.  The Gas company should give you a copy of the results, on laboratory letterhead, and you should get a copy of the chain-of-custody sheet, field notes, and quality control data.

If the gas company collects and pays for the water analysis, the laboratory records will be owned by the gas company and will be maintained by the certified laboratory for up to 5 years. If you rely on this type of testing, it is critical that you maintain multiple copies of your report in a secure location. If you are negotiating a lease to permit the drilling on your property, it is critical that you include the baseline testing and frequency of the testing, i.e., before and post drilling monitoring, as part of your lease.  If possible - include some neighboring properties and surfacewater features.  YOUR COST is Zero.

In some cases, the gas companies are sampling larger areas and proposed changes in the regulations require a large radius.  This type of testing may not include all the parameters that may be critical to you.  If you had baseline tesitng completed and you want someone to review the results (NO Charge) - you can contact us (PA Residents - Others)

Option 2 - The Legal Baseline Assessment  - If you are outside of this 1000 foot zone or want to conduct your own baseline.

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, provide a specific listing 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 sample must be collected to document the water quality in the aquifer and not the well.  Therefore, it may be necessary to purge the well by running the water for 30 minutes or more. The proper purging process is discussed in our new booklet. 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's 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.


Regarding the baseline water testing - it is recommended that the water testing be conducted for the parameters recommended by the PADEP, plus VOC's, MTBE, and surfactants. If your budget permits, it may be advisable to test for select semi-volatile organics (SOC's) and radionuclieds (Note Working on a Follow-up article). By using this process, the data that is collected should withstand cross-examination and be supportive of any legal action.  If you have other commercial or agricultural development in your area, it may be necessary to expand the baseline analysis to cover potential pollutants from these land uses and past practices.   Need some help or questions

Comment on Third Party Water Samplers

There are 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 professional  license, an individual working under the direct supervision of a PA licensed professional, 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.

Option 3 Informational Water Testing
Under this protocol, you are not trying to establish a legal baseline, but you are trying to check or monitor the status or condition of your water.  There are a number of laboratories that offer affordable water informational testing kits.  In some cases, you can purchase a mail order kit that cost less than $ 250.00 that provides the equivalent testing as a $ 1500.00 certified test kit.  For a partial listing of informational water testing services, please go

If you are looking for monitoring equipment or standards for your watershed group or organization - Visit the Water Quality Store.  There are some relatively inexpensive water testing kits and monitors for home use.

Thanks and Good Luck
Mr. Brian Oram, PG

New Links
Drinking Water Helpguide - If you have a problem - there is an answer for FREE !
Some of Our Case Studies

Sunday, April 11, 2010

Pennsylvania Free Radon Air Test Kit Program

The American Lung Association of the Mid-Atlantic has obtained a supply of radon test kits from a laboratory certified by the Pennsylvania Department of Environmental Protection. These radon kits are available only to residents of Pennsylvania. Each radon test is designed to work as an initial screening test. You should use it in the lowest lived-in level of your home. Directions are included. The test should be exposed to the air in your home for four to seven days before being returned promptly to the testing laboratory for analysis and report preparation. Postage, analysis, and a report of the results are all part of the no-fee package.
To receive your free radon kit, visit the website below. Only one radon kit is available per household. If multiple kits are requested from a single computer, only the first request will be fulfilled. Radon kits are distributed based on regional location. The regional map can be seen above at the right. Each region has a different number of kits available based on numerous factors including population and available statistics. If kits are not currently available in your area, please check back as additional kits may become available. Test Kits are available only to PA Residents. Please allow four to eight weeks for delivery.

Because supplies are limited, do not request a Test Kit unless you are sure you will actually use it. Also, if you have already tested, we ask that you leave the available test kits for others. We thank you for your cooperation.  Please visit the following website and enter your zip code to see if a free radon kit is available.

Tuesday, April 6, 2010

Pennsyvlania SB 777- Comments related to Sourcewater Protection, Wellhead Protection, and Landuse

Comments related to Pennsyvlania SB 777 - For a description of the bill 

The primary concerns with this proposed bill is the following:

1. The proposed bill - converts a guidance document for developing sourcewater protection plan and converts it to law.
2. In the process of creating SB 777 - a number of key items were excluded from the proposed legislation that are included in the guidance document.
3. If a map was generated for PA that used the 1250 foot distance from a stream channel, I believe this map would show that the extent of this proposed legislation is significant.  The actual guidance document uses a travel time of 5 hours to delineate Zone A for surfacewater reservoirs - the use of the 25 mile term in the proposed law is very misleading.   The goal of sourcewater protection is to identify critical areas, evaluate existing development and uses in the zone that may pose an impact, and developing control measures. 
4. This legislation attempts to expand local control of land beyond the zoning ordinance.  Since many of the water companies sold off their watershed lands in the mid to late 1980s- this legislation could potentially restrict the usage of the land by the landowner.
5. Wellhead Protection Plans and Sourcewater Protection Plans should be developed by the individual water companies, well or system owners, or municipalities that control the water system.  The control of the wellhead protection zone or source water protection zone should be based on control through ownership or the installation of specific engineering controls developed by the owner of the system and property.
6. The legislation is over reaching and unrealistic and because wellhead protection zones and sourcewater protection zones overlap municipal boundaries - the establishment of local ordinances to control activity and uses within these zones are not realistic.
7.The wording of the legislation is very vague - uses words like "could cause contamination".
8.Water Companies should be encouraged to develop Wellhead Protection Plans and Source Water Protection Plans and make recommendations regarding the need for developing specific standards or engineering controls for key areas within the watershed.
9. Rather than putting this legislation in place - lets do the following:

a. Funded Community Based Wellhead Protection Zone Delineations and Developing Sourcewater Protection Plans.
b. Identify "critical" areas where existing developments exist  or activities exist that has an impact or pose a impact and fund improving existing infrastructure to mitigate the existing impacts or fund the relocation of activities.
c. Fund education on non-point source pollution.

d. Purchase the development rights to key recharge areas or other areas within the watershed to protect the long-term reliability of the source.  In 1980, the water companies should not have sold the watershed land.

e. Conduct one or more pilot projects that use the sourcewater protection guidance manual to complete an assessment, develop a plan, and implement the plan through improvements and other requirements.  For example, it is my understanding the Virgin Island regulate the selection of the type of septic system based on the location of the site to the recharge area.  Therefore, it may be possible to identify zones that would reguire the use of additional engineering controls.

f. Install signage within the watershed to educate the public.

g. A bigger problem in PA is the lack of private well construction standards and the existing wells that are poorly constucted and causing groundwater contamination.

10. Lets not convert a guidance document into a regulation that will be difficult to enforce, regulate, and may be considered a taking.

11. Legislation is currently not in line with the existing Wellhead Protection Standards used for community water supplies.

12. The implementation of this legislation would have a significant impact on rural areas - where large urban areas use surfacewater reservoirs or groundwater withdrawals as a drinking water source - and would significantly impact small cities such as Wilkes Barre and Scranton - where large cities downgradient use the river as a drinking water source.

Just my thoughts

Brian Oram

Monday, April 5, 2010

Widener University School of Law’s Environmental Help Line

This is not my work !

"Widener University School of Law’s Environmental Help Line. Operated by Widener’s Environmental and Natural Resources Law Clinic—thanks to a grant from the Pennsylvania chapter of the Sierra Club—the Help Line seeks to empower Pennsylvania citizens by helping them respond to environmental problems or issues confronting them. In many cases, the Help Line will provide legal knowledge and guidance so that citizens (or groups of citizens) can advocate for themselves. In other cases, the Clinic will represent the citizens and/or their group in pursuing appropriate legal recourse. In addition, the Help Line seeks to create over time an archive of non-privileged legal analyses provided to other Help Line users so that legal information and analysis can be leveraged for even greater effect.
How Does The Help Line Work?
The Help Line allows Pennsylvania citizens to seek the Clinic’s help by contacting the Clinic in one of two ways:
* A Toll Free telephone line: 1-888-953-685
In either case, the citizen will provide basic contact information (name, phone number, avaulable times) for Clinic follow up on the environmental problem for which the citizen seeks assistance.
Within two business days, a Student Attorney or other representative of the Clinic will contact the citizen by phone and conduct an interview to get a more detailed description of the citizen’s problem. The types of information sought through this interview are the information necessary for the Clinic to make a reasoned judgment as to whether it can provide assistance to the citizen, such as
* The nature of the environmental problem (to help assess whether the matter meets Clinic criteria for suitable representations)
* The persons and governmental agencies involved (to help assess whether the Clinic might have a conflict of interest preventing it from taking on the representation);
* The timing of when action is needed (to help assess whether the Clinic would have sufficient time to provide meaningful assistance);
* The factual details of the citizen’s particular problem; and
* What the citizen seeks as a resolution to the problem and from the Clinic.
NOTE: These interviews will be treated as privileged and kept confidential by the Clinic whether or not the Clinic ultimately agrees to represent the citizen
After the interview, the Clinic will make an assessment about whether it will agree to represent the citizen and take on the matter. THE CLINIC DOES NOT REPRESENT THE CLIENT UNLESS AND UNTIL IT AGREES TO ACCEPT THE REPRESENTATION. The Clinic will make that decision and inform the client within five business days of the interview.
The Clinic’s work on a Help Line project will fall into one of two categories: Advice and Preparation for Self-Representation or Direct Representation.
Advice and Preparation for Self-Representation

This category of work envisions the Clinic providing assistance to a citizen who will ultimately advocate for himself or herself in an upcoming proceeding. Such a citizen might need an understanding of basic legal principles that might apply to his or her issue or what legal options may be available. In this category, the Clinic will research and provide legal guidance to assist the citizen in preparing for his or her own advocacy. The typical goal (subject to discussion and mutual agreement between the Clinic and the citizen) is to generate a written legal analysis for the citizen-client
Direct Representation
This category of work envisions the Clinic providing direct representation of the citizen in a legal proceeding (whether it is a hearing, administrative appeal, or court proceeding). In this situation, the Clinic would act as the citizen’s attorney via a pro bono representation, appearing and advocating directly for the citizen in the proceedings.

Whether in the Advice and Preparation or Direct Representation category, all Clinic representations arising out of the Help Line will involve regular communication and guidance to clients as appropriate to the case or situation. Finally, when appropriate and agreed to by the Client, non-privileged summaries of the legal analyses used will be placed in the Help Line Archive so that other citizens can utilize them in other situations, thereby leveraging the Help Line’s impact on environmental issues in Pennsylvania.

Need Help? Call 1-888-953-6853 or fill out a Request for Help Form today.
Questions? Explore the Clinic’s other pages on this website or contact Clinic Director Ken Kristl (302-477-2053 or to learn more."  (Source - Website for College)

Wind Energy Training and Assessment Program - Is Live

We are announcing our wind energy apprentice and assessment programs. 

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Wind energy companies are growing exponentially to meet America's demand for clean, renewable, and domestic energy. This entry level Wind Energy Apprentice course prepares you for a career in the wind energy industry. Students will learn the basics of wind energy principles including wind technology, wind energy anatomy, wind farm design, wind business, and characteristics of energy sources. This course covers the fundamentals of hydraulics and basic theory and practice of electrical circuits, including calculations as applied to alternating and direct currents.   Over 240 hours of training

Wind Energy Assessments
A wind resource assessment program is similar to other technical projects. It requires planning and coordination and is constrained by budget and schedule limitations. It demands a clear set of objectives so the best assessment approach is selected. Its ultimate success rests on the quality of the program's assembled assets—sound siting and measurement techniques, trained staff, quality equipment, and thorough data analysis techniques.  (Online Training Course - you can complete in 1 day)

Wind Energy Information and Systems
This three-hour course is a review of how wind energy power systems work and the components that constitute a wind energy system. This course discusses the types of wind energy systems, their characteristics, the methods used to classify and analyze wind resources, and the impacts of wind energy systems on electric power systems as well as their impact on the environment.  (Online Training Course - you can complete in 1/2 a day)

For more courses - go to our Main Portal

Radon Testing and Training Program - Goes Online

Radon Measurement
Our New 16-hour - Radon Inspection Testing and Measurement Course is live.  This course is especially important if you are working in the following professions: Home Inspector, Professional Engineer, Engineering Technician, Radiation Technologist, Energy Auditor, Environmental Consultant, Building Contractor, HVAC Contractor. This course covers Radon principles, how radon enters buildings, radon testing equipment, QA/QC programs, and preparation for the NEHA certification test. Each student will download, by unit, a complete 200 plus page manual.

For details go to Our "Green Building Training Program"

PA House Bill 2213 Oil and Gas Legislation Pennsylvania

The following are my comments related to PA House Bill 2213 - the full text of the regulations can be found at the following website.

1.I like the provisions for inspections - but does the PADEP field staff have the training they need and do they have the tools and equipment to really inspect a cement seal that is 2000 feet down?  Therefore, the bill should require certification by the driller and a third party inspection service- paid by the Gas Company.

2. Fees should cover the cost of inspections, additional water testing, responding to complaints, etc - the full cost of the program.

3. I am ok with the 2500 foot from the drilling pad, but there are no provisions for the horizontal leg of the well and the 6 month time frame is inadequate. Point groundwater moves slowing - less than 0.1 ft per year to 3 ft per day - I would recommend at least 1 year to 2 years may be better.

For the horizontal leg, the gas companies can create fractures out 100 to 400 feet from the horizontal leg. Therefore, the testing zone should be 2500 foot, plus at least 100 foot on either side of the horizontal leg of the well. This could be adjusted based on the final report for the well when the company reports the extent of the horizontal fracturing.

4. Section 4 - if the specific chemical composition can not be disclosed the trade name should be released, MSDS sheet, and volume of the chemical used. All this information should be disclosed in the permit application and in a well completion report that is submitted for each well in a timely manner.

This information should also be available at the municipality were the well is located- so the public has access.

5. Bonding requirements seem better. Also - I support that no blanket bonds be issued for the Marcellus Shale and each well not drilling pad should be considered as a well.   Therefore, a drilling pad with 6 wells should be six bonds.

6. Local ordinances should be permitted to control or prevent installation of well, temporary structures, or permanant structures in floodplains. Plus local agency should control nuisance issues, road bonding, road use and access, and the accessory development that will likely occur, such as field offices, temporary septic permits, holding tanks, etc.

7. Regulations should apply to Marcellus Shale and other other formations where the development technique is depolyed.

Thanks Brian Oram, PG B.F. Environmental Consultants Inc. 15 Hillcrest Drive Dallas, PA 18612 Thanks for your leadership

Saturday, April 3, 2010

DEP to require companies to list chemicals used at each gas well

DEP to require companies to list chemicals used at each gas well
Direct Url -

(Note this is not my work)
by laura legere (staff writer)
Published: April 2, 2010

CLARKS SUMMIT - Gas drilling companies operating in Pennsylvania will have to provide the names of chemicals used at each well site under regulations proposed by the state's environmental oversight agency.

The requirement, which was added last week to the most recent draft of proposed well construction regulations, was discussed by the head of the Department of Environmental Protection's Bureau of Oil and Gas Management at a meeting of the Abington Council of Governments Thursday night.

The new proposal would require each company to include a list of the names and the total volume of chemicals used to hydraulically fracture each well as part of a report the drillers submit once each well is completed.

The regulations, if approved, will give a well-by-well picture of the chemicals that are mixed with water and sand and injected underground to break apart gas-bearing rock formations including the Marcellus Shale.

Scott Perry, who was appointed director of the bureau in mid-January, said the requirement was just added now to the suite of regulations first proposed in September "because we heard what the concerns of the public were."

Although drillers provide the department with Material Safety Data Sheets that outline what chemicals the companies plan to use at a well site, Mr. Perry said that prior to the new completion report requirements "we didn't ask for what chemicals were used to frack a well.""It's important for transparency, for people to be able to see what's going on," he said. The list will not include the volumes of individual chemicals used at a well site, he said.

He also insisted that even though the department is proposing to strengthen its disclosure requirements, hydraulic fracturing is not a threat to water supplies.

"There has never been any evidence of fracking ever causing direct contamination of fresh groundwater in Pennsylvania or anywhere else," he said.

"If I honestly thought that fracking was causing a direct communication with groundwater resources, I wouldn't be talking about how we have a chemical list. That is the ultimate half-measure. I would be saying, 'This cannot occur.' "

The proposed regulations will be presented at a meeting of the Environmental Quality Board on May 19, Mr. Perry said.

Contact the writer:
This was part of my comments to the proposed legistation - I still believe it does not require the release of proprietory data - but it is important to note the MSDS sheets and information have always been included as part of the permitting process.  Also - this report will be generated after completion to document what was actually used.

Looking for environmental or water quality monitoring equipment for field work.