HW-6 Dimock Data EPA barium, copper, methane, nickel, thermogenic

Comment

1. Without predrilling data, it is not possible to comment on the cause for any water quality problems.

2. Where possible, I have noted situations where elevated levels of a water quality parameter exists in Pennsylvania.

3. If duplicate analysis provided, I attempted to use the highest reported value.

4. New Document - http://water.epa.gov/action/advisories/drinking/upload/dwstandards2011.pdf

5. This is not about cause and effect; it is about a review of the data.

6. A Well by Well - Review of the Data for Dimock, PA collected by EPA

Well – HW-6

With the exception of the following parameters, the remaining values were reported as NOT Detected (U)

Barium – 0.254 mg/L – the primary drinking water standard for barium is 2.0 mg/L –– this does not suggest any specific impact and barium is typically detectable in non-saline impacted water at a level of less than 1 mg/L. (OK)

Calcium- 35.3 mg/L (Total)– no specific drinking water standard drinking water standard is available.  (OK)

Chloride – 7.47 mg/L (OK) – drinking water standard is <  250 mg/L – this does not suggest any specific impact.

Copper – 0.0025 mg/L (OK)- the secondary drinking water standard is 1.0 mg/L and the primary drinking water standard is 1.3 mg/L. (OK)

Ethane –0.011 mg/L  – No specific drinking water standard (OK)

Methane – 2.0 mg/L  – No specific drinking water standard. (OK).

The well water is not above the new action limit of 7 mg/L, but the well should be fitted with a basic vented well cap, but the level of methane is at a level were passive venting is recommended.   For more details, go to http://www.water-research.net/methanegas.htm

The methane/ethane ratio is (2.0/ 0.011) – 181  (Suggests biogenic, but isotopic analysis is needed)

Iron – 0.620 mg/L - Iron is regulated as a secondary drinking water standard in Pennsylvania and the action limit is 0.3 mg/L.  Therefore, the total iron content exceeds the secondary drinking water standard.  Elevated level of iron is a common water quality problem in Northeastern Pennsylvania.  Action is Recommended, because of an aesthetic issue.    Check for MIC and Nuisance Bacteria.

Magnesium- 6.82 mg/L (Total)– no specific drinking water standard drinking water standard is available.  (OK)

Manganese– 0.0316 mg/L (Total)– Manganese is regulated as a secondary drinking water standard in Pennsylvania and the action limit is 0.05 mg/L.  Therefore, the total manganese content does not exceed the secondary drinking water standard.   (OK)

Nickel - 0.0012 mg/L (Total) – no specific drinking water standard drinking water standard is available, but the EPA has suggest a MCL of 0.1 mg/L.   (OK)

http://www.epa.gov/ogwdw/pdfs/factsheets/ioc/tech/nickel.pdf

Nitrate+Nitrite- N – 0.699 mg/L, this is well below the EPA / PADEP drinking water limit of 10mg N/L for nitrate-N and would also be below the limit of 1.0 mg N/L for nitrite-N. (OK)

Sodium –13.2 (Total) – no specific drinking water standard drinking water standard is available, but the EPA has added it to the Candidate List to provide more analysis.  The EPA’s initial value of 20 mg/L has been clearly identified as not realistic.  When chloride (salt is sodium chloride) is present at a concentration of over 250 mg/L, the water can have an “off” taste. At 400+ mg/L chloride, the water will taste definitely salty. (Source- Dr. Brian Redmond, Professional Geologist). (OK)

Strontium – 0.720 mg/L (Total)  – no specific drinking water standard drinking water standard is available, but it is on the EPA Candidate List.  The EPA recommends that drinking water levels of nonradioactive strontium should not be more than 4 mg/L.  The report limit is consistent with background levels in Northeastern Pennsylvania.  If the background level was above 4 mg/L, it would be advisable to test for radiological parameters, especially alpha/beta.  (OK)

Sulfate – 10.6 mg/L (OK) – drinking water standard is <  250 mg/L – this does not suggest any specific impact.

Total Dissolved Solids  – 25 mg/L   – Total Dissolved Solids is regulated as a secondary drinking water standard by the PADEP in Pennsylvania and the action limit is 500 mg/L.  (Question – this value seems inaccurate or a typo – This should be redone.)

Uranium – 0.0045 mg/L (Total) – Uranium is regulated as a primary drinking water standard by the EPA and PADEP in Pennsylvania and the action limit is 0.030 mg/L.  (OK)

Zinc  – 0.0055 mg/L (Total) – Zinc is regulated as a secondary drinking water standard by the PADEP in Pennsylvania and the action limit is 5.0 mg/L.  (OK)

  

Ethylene glycol –  the reported value is < 10 mg/L – there is no standard, but the EPA has a guidance limit of < 7 mg/L.  Other states have lower and higher standards:

New Jersey 0.300 mg/L (300 ppb)

Arizona 5.5 mg/L (5500 ppb)

New Hampshire 7.0 mg/L (7000 ppb)

Florida, Massachusetts, and Minnesota14.0 mg/L (14,000 ppb)

Minnesota

At a minimum, I would recommend retesting for ethylene glycol other other glycol compounds using a method that is more sensitive or conducting some type of standard additions analysis.

No major problems

1. No major problem.

2. Iron is elevated and exceeds a secondary drinking water standard.

3. Methane/Ethane Ratio would suggest that isotopic analysis is advisable.

origin and the level of methane is well below the action level of 7 mg/L, but at the action level of 2 mg/L were passive venting is recommended.

Go to: http://www.water-research.net/methanegas.htm

4.Total Dissolved Solids results seem inaccurate or there is a typo in the draft report.

5. Retesting for glycols using a more sensitive technique is recommended.

Document can not be copied in whole or part without the expressed written permission of Mr. Brian Oram, B.F. Environmental Consultants Inc. http://www.bfenvironmental.com

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HW-19 Dimock Data Review - EPA Findings - barium, chloride, phthalates

Comment

1. Without predrilling data, it is not possible to comment on the cause for any water quality problems.

2. Where possible, I have noted situations where elevated levels of a water quality parameter exists in Pennsylvania.

3. If duplicate analysis provided, I attempted to use the highest reported value.

4. New Document - http://water.epa.gov/action/advisories/drinking/upload/dwstandards2011.pdf

5. This is not about cause and effect; it is about a review of the data.

6. A Well by Well - Review of the Data for Dimock, PA collected by EPA

Well – HW-19

With the exception of the following parameters, the remaining values were reported as NOT Detected (U)

Anionic Surfactants – 0.014mg/L – the secondary drinking water standard for foaming agents is 0.5 mg/L.  (OK)

http://www.chemetrics.com/products/pdf/detergents.pdf

Barium – 0.229 mg/L – the primary drinking water standard for barium is 2.0 mg/L –– this does not suggest any specific impact and barium is typically detectable in non-saline impacted water at a level of less than 1 mg/L. (OK)

Calcium- 37.6 mg/L (Total)– no specific drinking water standard drinking water standard is available.  (OK)

Chloride – 18.7 mg/L (OK) – drinking water standard is <  250 mg/L – this does not suggest any specific impact.

Chromium- 0.0032 mg/L (D) and the EPA/ PADEP primary drinking water standard is < 0.100 mg/L (OK).

Copper – 0.0074 mg/L (OK)- the secondary drinking water standard is 1.0 mg/L and the primary drinking water standard is 1.3 mg/L. (OK)

Ethane – < 0.0012 mg/L  – No specific drinking water standard (OK)

Methane –  < 0.002 mg/L  – No specific drinking water standard. (OK).

The well water is not above the new action limit of 7 mg/L.   For more details, go to http://www.water-research.net/methanegas.htm

Magnesium- 7.72 mg/L (D)– no specific drinking water standard drinking water standard is available.  (OK)

Manganese– 0.0082 mg/L (Total)– Manganese is regulated as a secondary drinking water standard in Pennsylvania and the action limit is 0.05 mg/L.  Therefore, the total manganese content does not exceed the secondary drinking water standard.   (OK)

Nickel - 0.0017 mg/L (D) – no specific drinking water standard drinking water standard is available, but the EPA has suggest a MCL of 0.1 mg/L.   (OK)

http://www.epa.gov/ogwdw/pdfs/factsheets/ioc/tech/nickel.pdf

Nitrate+Nitrite- N – 2.39 mg/L, this is well below the EPA / PADEP drinking water limit of 10mg N/L for nitrate-N. (OK)- Recommend testing for nitrite-N.   Total nitrogen- 2.61 mg/L.

diethyl-phthalate – 0.000029 mg/L , the EPA/PADEP drinking water limit is 0.006 mg/L.  The reported value is less than the drinking water limit.   (OK)

The data in the Citizens Groundwater and Surfacewater database suggests that up to 8 % of private wells may have a level of phthalates that exceed the drinking water limit.

“It is commonly used to make plastics more flexible. Because diethyl phthalate is not a part of the chain of chemicals (polymers) which makes up the plastics, it can be released fairly easily from these products. These plastics are found in products such as toothbrushes, automobile parts, tools, toys, and food packaging. Diethyl phthalate is also used in cosmetics, insecticides, and aspirin”.http://www.atsdr.cdc.gov/phs/phs.asp?id=601&tid=112

Sodium –10.0 mg/L  (D) – no specific drinking water standard drinking water standard is available, but the EPA has added it to the Candidate List to provide more analysis.  The EPA’s initial value of 20 mg/L has been clearly identified as not realistic.  When chloride (salt is sodium chloride) is present at a concentration of over 250 mg/L, the water can have an “off” taste. At 400+ mg/L chloride, the water will taste definitely salty. (Source- Dr. Brian Redmond, Professional Geologist). (OK)

Sulfate – 18.2 mg/L (OK) – drinking water standard is <  250 mg/L – this does not suggest any specific impact.

Total Dissolved Solids  – 148 mg/L   – Total Dissolved Solids is regulated as a secondary drinking water standard by the PADEP in Pennsylvania and the action limit is 500 mg/L. 

Uranium – 0.0037 mg/L (Total) – Uranium is regulated as a primary drinking water standard by the EPA and PADEP in Pennsylvania and the action limit is 0.030 mg/L.  (OK)

Zinc  – 0.0069 mg/L (Total) – Zinc is regulated as a secondary drinking water standard by the PADEP in Pennsylvania and the action limit is 5.0 mg/L.  (OK)

Ethylene glycol –  the reported value is < 10 mg/L – there is no standard, but the EPA has a guidance limit of < 7 mg/L.  Other states have lower and higher standards:

New Jersey 0.300 mg/L (300 ppb)

Arizona 5.5 mg/L (5500 ppb)

New Hampshire 7.0 mg/L (7000 ppb)

Florida, Massachusetts, and Minnesota14.0 mg/L (14,000 ppb)

Minnesota

At a minimum, I would recommend retesting for ethylene glycol other other glycol compounds using a method that is more sensitive or conducting some type of standard additions analysis.

No major problems

1. No major problem, but recommend testing for nitrite-N.  The drinking water standard for nitrite-N is 1 mg/L.  Since the concentration for total nitrate and nitrite is over 2 mg/L, it is possible that the level of nitrite-N is over 1 mg/L.

2. Retesting for glycols using a more sensitive technique is recommended.

3. The detection of the plasticizer is not atypical or a red flag for the region.  The data in the Citizens Groundwater and Surfacewater database suggests that up to 8 % of private wells may have a level of phthalates that exceed the drinking water limit.  Support the citizen groundwater surfacewater database - its Free !

Document can not be copied in whole or part without the expressed written permission of Mr. Brian Oram, B.F. Environmental Consultants Inc. http://www.bfenvironmental.com

Do you want to make a positive change in PA - that will cost you NO Money?
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Well – HW-12 Dimock 1/26/2012 A Review

Comment

1. Without predrilling data, it is not possible to comment on the cause for any water quality problems.

2. Where possible, I have noted situations where elevated levels of a water quality parameter exists in Pennsylvania.  This is based on my professional experience and other published data.

3. Where appropriate I made recommendations.

Well – HW-12

With the exception of the following parameters, the remaining values were reported as NOT Detected (U)

Chloride – 3.64 mg/L (OK) – drinking water standard is <  250 mg/L – this does not suggest any specific impact.

Sulfate – 5.20 mg/L (OK) – drinking water standard is <  250 mg/L – this does not suggest any specific impact.

Arsenic – 0.006 mg/L (Total) and 0.0058 mg/L (D) – drinking water standard is <  0.010 mg/L – this does not suggest any specific impact and arsenic is a common problem in NEPA – about 6 % of private wells have arsenic above 0.010 mg/L.  It would be advisable to monitor the arsenic level of the well on an annual basis.

Barium - 0.707mg/L (Total) and 0.716 mg/L (D) – drinking water standard is <  2 mg/L – this does not suggest any specific impact and barium is typically detectable in non-saline impacted water at a level of less than 1 mg/L. (OK)

Boron – 0.0538 mg/L (Total) and 0.0522 mg/L (D) – no specific drinking water standard drinking water standard is available. EPA appears to have a long-term health advisory of 2.0 mg/L, but other states have limits that range from 0.6 to 1 mg/L.   Minnesota is the state with the lowest standard of 0.600 mg/L.  Therefore, this does not appear to suggest any form of impact.  (OK)

Source: http://www.epa.gov/ogwdw/ccl/pdfs/reg_determine2/healthadvisory_ccl2-reg2_boron_summary.pdf

Calcium- 28.5 mg/L (Total) and 28.1 mg/L (D) – no specific drinking water standard drinking water standard is available.  (OK)

Iron – 1.24 mg/L (Total) and < 0.1 mg/L (D) – Iron is regulated as a secondary drinking water standard in Pennsylvania and the action limit is 0.3 mg/L.  Therefore, the total iron content exceeds the secondary drinking water standard.  Since the total value exceeds the limit and not the dissolved, this suggests that the primary recommendation would be to install a water treatment system to filter the iron colloids or particles from the water.  The water probably has a reddish or brown appearance. Elevated level of iron is a common water quality problem in Northeastern Pennsylvania.  Action is Recommended, because of an aesthetic issue. 

Magnesium- 4.77 mg/L (Total) and 4.67 mg/L (D) – no specific drinking water standard drinking water standard is available.  (OK)

Manganese– 0.12 mg/L (Total) and 0.139 mg/L (D) – Manganese is regulated as a secondary drinking water standard in Pennsylvania and the action limit is 0.05 mg/L.  Therefore, the total manganese content exceeds the secondary drinking water standard.  Since the manganese is in a dissolved form, the water could become browner in color over time.  Because the water coming out of the well has dissolved manganese, the water treatment system would require either chemical oxidation or some type of ion exchange system. Elevated level of manganese is a common water quality problem in Northeastern Pennsylvania.  Action is Recommended, because of an aesthetic issue. 

Nickel - 0.0012 mg/L (Total) and 0.001 mg/L (D) – – no specific drinking water standard drinking water standard is available, but the EPA has suggest a MCL of 0.1 mg/L.   (OK)

http://www.epa.gov/ogwdw/pdfs/factsheets/ioc/tech/nickel.pdf

Sodium – 19.3 mg/L (Total) and 19.3 mg/L (D) – – no specific drinking water standard drinking water standard is available, but the EPA has added it to the Candidate List to provide more analysis.  The EPA’s initial value of 20 mg/L has been clearly identified as not realistic.  When chloride (salt is sodium chloride) is present at a concentration of over 250 mg/L, the water can have an “off” taste. At 400+ mg/L chloride, the water will taste definitely salty. (Source- Dr. Brian Redmond, Professional Geologist). (OK)

Strontium – 0.629 mg/L (Total) and 0.618 mg/L (D)  – no specific drinking water standard drinking water standard is available, but it is on the EPA Candidate List.  The EPA recommends that drinking water levels of nonradioactive strontium should not be more than 4 mg/L.  The report limit is consistent with background levels in Northeastern Pennsylvania.  If the background level was above 4 mg/L, it would be advisable to test for radiological parameters, especially alpha/beta.  (OK)

Uranium – 0.0018 mg/L (Total) and 0.0016 mg/L (D)  – Uranium is regulated as a primary drinking water standard by the EPA and PADEP in Pennsylvania and the action limit is 0.030 mg/L.  (OK)

Zinc  – 0.0054  mg/L (Total) and < 0.002 mg/L (D)  – Zinc is regulated as a secondary drinking water standard by the PADEP in Pennsylvania and the action limit is 5.0 mg/L.  (OK)

Ethane – 2.00  mg/L  – No specific drinking water standard (OK)

Methane – 52  mg/L  – No specific drinking water standard, but the level indicates supersaturated conditions.  This means the well pump is pulling in water that is not in equilibrium with the atmosphere.  The well is above the new action limit of 7 mg/L and methane gas mitigation measures should be employed.  These measures not only include venting the well, but also potentially modifying the well, installing treatment, or taking other action.  For more details, go to http://www.water-research.net/methanegas.htm

There are places in PA were baseline levels of methane gas are at or above 7 mg/L. In general, I would estimate that 1 to 3 % of private wells may have elevated levels of methane.  In addition to modifying the well, it would be advisable to conduct isotopic analysis.

Based on the ratio of methane to ethane, the ratio is 26.  Since a ratio of methane to ethane of over 1000 typically suggests a biogenic source and a value of under 100 suggests a thermogenic source, the available information would suggest a thermogenic source for the gas.  As a guide, it may be possible to use a ratio to suggest the source of the gas- “ if the ratio of methane to ethane is 25, the source is thermogenic, but if the ratio is over 2500, then it is biogenic" (Mr. Bob Pirkle, President of Microseeps, Inc.), but between 25 and 2500 this is where isotopic analysis is critical.  

No specific health concern, but a health risk associated with the potential for a flammable environment.  


Action needed to properly vent gas from the well, perhaps modifying the well, water treatment to reduce methane level in the water to < 7 mg/L or more,  and isotopic analysis recommended.

May be advisable to check the level of other gases, such as propane.

Total Dissolved Solids  – 67  mg/L   – Total Dissolved Solids is regulated as a secondary drinking water standard by the PADEP in Pennsylvania and the action limit is 500 mg/L.  (OK)

Chloroethane – 0.0002 mg/L – there does not appear to be a drinking water standard and the primary route of entry into the body is inhalation.  Chloroethane can be smelled at a level of 0.02 mg/L in water.  “In groundwater, chloroethane changes slowly to ethanol and a chloride salt as a result of reaction with water and chloroethane can be formed through chlorination.”    There does not appear to be an aesthetic issue, but Additional Monitoring Would be Advisable.  No specific health concern, but monitoring recommended.

http://www.atsdr.cdc.gov/PHS/PHS.asp?id=825&tid=161

Methyl Chloride (Chloromethane)– 0.0006 mg/L – there does not appear to be a drinking water standard that is regulated by the EPA or PADEP.  It appears that water companies throughout the country have reported detection of chloromethane in the water. It appears the EPA has provided a recommended lifetime health based exposure risk non-cancer for chloromethane of 0.030 mg/L.  “ Most (99%) of the chloromethane in the environment comes from natural sources.” (OK)

http://www.ewg.org/tap-water/whatsinyourwater/2210/MN//Chloromethane/

http://www.atsdr.cdc.gov/toxprofiles/tp106-c1-b.pdf

Bromide – In freshwater, bromide is typically less than 0.05 mg/L. Therefore, it would be advisable to retest using a method with a lower detection limit. If an ozone-based water treatment system is proposed, it may be best to have the bromide level of less than 0.0063 mg/L to prevent the formation of bromates.    Additional Sampling at a lower detection limit – no health concern (OK).

Additional Comments
Lithium - was reported at < 200 ppb or 0.2 mg/L.  There are no current federal standards for lithium in drinking water. To protect human health, EPA estimated that a lithium concentration in a potable water supply should not exceed 700 μg/l or 0.7 mg/L.

Methane gas appears to have a thermogenic origin.

Other References

http://www.cdph.ca.gov/certlic/drinkingwater/Pages/MCLReview2012.aspx
http://water.epa.gov/scitech/drinkingwater/dws/ccl/ccl3.cfm#chemical
http://www.water-research.net/pdf/lithium.pdf  (1997)

Document can not be copied in whole or part without the expressed written permission of Mr. Brian Oram, B.F. Environmental Consultants Inc. http://www.bfenvironmental.com

Do you want to make a positive change in PA - that will cost you NO Money?
Help Support the Citizens Groundwater and Surfacewater Database and Submit Your Baseline Data !

Issue of Chloride in discharge Permits

"State rule targets chloride levels
By Robert Swift (Harrisburg Bureau Chief)
Published: July 17, 2010
HARRISBURG - A proposed state rule to limit the concentration in waterways of a salt compound produced by the Marcellus Shale drilling process is under challenge.
The proposal by the Department of Environmental Protection would align the state standard for allowable chloride levels with national criteria used to protect freshwater plant and animal species. The existing state chloride standard was developed mainly to protect water supplies
Fish and aquatic life can't survive when high levels of chloride are present. Chloride can corrode metals and affect the taste of food products.
The rule is being considered by the Environmental Quality Board as environmentalists warn that increased drilling for natural gas in the Marcellus Shale formation will produce wastewater contributing to high levels of chloride to streams and groundwater.

Chloride occurs naturally in ancient rock formations that once formed seabeds and are reached by the drilling for deep gas pockets.
But chloride can also contaminate waterways through agricultural runoff and discharges from industries and wastewater treatment plants.
The chloride rule is a separate issue from a broader rule to limit pollution in wastewater from natural gas drilling in the final stages of regulatory action. The rule gives drillers several options to treat wastewater.
Under the chloride rule, the DEP would follow toxicity data on the impact of chlorides on plant aquatic life set by the federal Environmental Protection Agency in a 1988 study.
Both environmental and industry groups argue the 1988 data is outdated.
A coalition of environmental groups, including Clean Water Action and the Delaware Riverkeeper Network, note that DEP has the authority to adopt standards more stringent than federal criteria. They want new studies on chloride contamination that focus on aquatic life in Pennsylvania.
The Pennsylvania Coal Association suggests other industries are adversely affected by the focus on Marcellus Shale drilling.
"The proposed regulation does have the potential to again sweep in a wide range of many other Pennsylvania industries, including the mining industry, who to date have not been generally required, to sample for, or treat, chloride in their wastewater discharges," the association said.

This week the state Independent Regulatory Review Commission urged DEP to rewrite the proposal.

"We agree that basing the new criteria on outdated data when more recent data is available is not reasonable," the commissioners said.

rswift@timesshamrock.com"


This is not my work,but here are my comments:
1. I have commented on NPDES Discharge Permits - I think it is critical we take a hard look at the permit limits we set for parameters such as chloride and sulfate.

2. We should be concerned with applying this very conservative limit to all industries - for example it could be very difficult to treat mine drainage if this standard had to be meet.

3. If this standard was applied to all NPDES permits - it may be a challenge to manage stormwater runoff and may require us to change how we deal with snow.

4. I would strongly recommend we take into consider the side effects of regulation.

5. If the concern is in-stream levels of contamination - we should also target and be concerned about urban runoff and the increasing the amount of groundwater recharge that sustains stream baseflows

My thoughts

PS: I will approve only comments that are constructive - so if you want to just vent - post on your own blog

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.