Comments on: Is Our Drinking Water At Risk? http://carbonwaters.org/2010/02/is-our-drinking-water-at-risk/ Wed, 01 Feb 2012 19:22:33 +0000 hourly 1 http://wordpress.org/?v=3.0.1 By: Brian Oram http://carbonwaters.org/2010/02/is-our-drinking-water-at-risk/comment-page-1/#comment-98 Brian Oram Thu, 18 Feb 2010 18:22:12 +0000 http://carbonwaters.org/?p=5364#comment-98 The following is my opinion: 1. The drilling standards and guideance must put in place a construction that protects waters with a total dissolved solids of < 10,000 mg/L. 2. Natural gas well construction must use wells that are completely cased and cemented and not an open borehole approach. 3. The standard well should have multiple cemented casings to properly seal off the shallow freshwater aquifer, confined freshwater aquifer, and completely separate the fresh and saline aquifers. This needs to be based on data and not a quess. 4.SInce there is probably not enough regulators to oversee construction, it should be a requirement that third party inspectors licensed in Pennsylvania certify the well construction. This way the person or company license and liability is on the line. 5. Permitting should include real restoration plans, emergency response planning, and the baseline water quality data must be available to the community. 6. Regarding fracing - lined ponds should not hold any flow back water and this should all be returned to a tank and the develop should recycle as much as possible and use a gradle to grave tracking approach. 7. Chemicals - the chemicals are disclosed in the permit - but the MSDS Sheets and copy of permit application should be on-file at the local level. 8. Roads should be properly bonded. 9. State should consider increasing permit fees and plugging fees to cover the real cost of plugging these deep wells. 10 Personally - I am very concerned about the initial leases that provide very little control by the landowner, potential for deep well injection of brines and hauling of contaminated fluids and materials. Just my personal thoughts My Blog is http://pennsylvania-solutions.blogspot.com/ Many of the points are better described. Also The EPA TIp Line Natural Gas Drilling Tip Line EPA's Mid-Atlantic Region has a natural gas drilling tip line for reporting dumping and other illegal or suspicious hauling and/or disposal activities. Tip line number (toll free): 1-877-919-4372 (877-919-4EPA) URL: http://www.epa.gov/region03/marcellus_shale/tipline.html Tip email address: eyesondrilling@epa.gov Tip mailing address: EPA Region 3 1650 Arch Street (3CEOO) Philadelphia, PA 19103-2029 The following is my opinion:

1. The drilling standards and guideance must put in place a construction that protects waters with a total dissolved solids of < 10,000 mg/L.

2. Natural gas well construction must use wells that are completely cased and cemented and not an open borehole approach.

3. The standard well should have multiple cemented casings to properly seal off the shallow freshwater aquifer, confined freshwater aquifer, and completely separate the fresh and saline aquifers. This needs to be based on data and not a quess.

4.SInce there is probably not enough regulators to oversee construction, it should be a requirement that third party inspectors licensed in Pennsylvania certify the well construction. This way the person or company license and liability is on the line.

5. Permitting should include real restoration plans, emergency response planning, and the baseline water quality data must be available to the community.

6. Regarding fracing – lined ponds should not hold any flow back water and this should all be returned to a tank and the develop should recycle as much as possible and use a gradle to grave tracking approach.

7. Chemicals – the chemicals are disclosed in the permit – but the MSDS Sheets and copy of permit application should be on-file at the local level.

8. Roads should be properly bonded.

9. State should consider increasing permit fees and plugging fees to cover the real cost of plugging these deep wells.

10 Personally – I am very concerned about the initial leases that provide very little control by the landowner, potential for deep well injection of brines and hauling of contaminated fluids and materials.

Just my personal thoughts

My Blog is
http://pennsylvania-solutions.blogspot.com/

Many of the points are better described.

Also The EPA TIp Line
Natural Gas Drilling Tip Line

EPA's Mid-Atlantic Region has a natural gas drilling tip line for reporting dumping and other illegal or suspicious hauling and/or disposal activities.
Tip line number (toll free): 1-877-919-4372 (877-919-4EPA)
URL: http://www.epa.gov/region03/marcellus_shale/tipline.html
Tip email address: eyesondrilling@epa.gov
Tip mailing address:

EPA Region 3

1650 Arch Street (3CEOO)

Philadelphia, PA 19103-2029

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