Comment

Comment by daniel cohen on March 3, 2010 at 12:16pm

Brian speaks of the need to have water properly tested, and of the importance of the chain of evidence. He also speaks to participating in the development of a regional database of water quality data 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.

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, specific the list 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 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 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. Because the records are owned by the client, it is strongly recommend that the private well owner or water supply owner contract with the laboratory rather than relying on a company or corporation to pay to conduct this background analysis. If you rely on a company or corporation to pay or contact with the laboratory, it would be in your best interest to have the company agree to provide you a copy of the results within a timely manner and you should be given the right to directly request copies of the results from the laboratory. By using this process, the data that is collected should withstand cross-examination and be supportive of any legal action.

There is 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 profession license, 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. If you would like more information on drinking water quality in Pennsylvania, I would recommend you visit the http://www.water-research.net- Center for Environmental Quality at Wilkes University

Regarding baseline sampling, it is best if this testing is conducted prior to major construction or exploration activity, but even after activity may have started this information will provide a baseline for documenting the existing conditions of the water supply. In addition to documenting water quality and appearance, it may be advisable to document the static and dynamic water level in the well and yield of the well."

If you are interested in participating in the development of a regional database of water quality data for private wells, please contact Mr Brian Oram at Wilkes University- brian.oram@wilkes.edu. If you would like more information on background water quality analysis and laboratory testing or would like someone to meet with you or your group, please contact B.F. Environmental Consultants at http://www.bfenvironmental.com

Respectfully submitted


Mr. Brian Oram, PG

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