Floodplain well permit violation

Muncy Creek floodplain, north of Tivoli, flooded on January 25th.

By February 21st,  XTO had a well in full operation.

Last spring, under pressure from the gas industry to speed up the permitting process, DEP took the permitting for land disturbance and run off away from the county conservation districts.  It is quite doubtful if the county’s conservation district would have permitted this site.

Although DEP took over this function they didn’t have the man power to actually do it. To compensate, any disturbance less than 5 acres can receive a permit, sight unseen, by the developer submitting plans from their own engineers.  Most well pads are less than 5 acres.

When this well is fracked, 18,000 to 20,000 gallons of toxic concentrated chemicals, (hydrochloric acid, biocides, petroleum distillates, methanol, a variety of alcohols, ethylene glycol and much more) will be brought on to this floodplain and mixed. Any spillage will end up in the creek.  Do spills happen? Ask the 17 cows in Louisiana who died horribly last spring after drinking chemicals that spilled into their pasture from an adjacent well.

Below is an excerpt from a joint letter from Trout Unlimited and the Chesapeake Bay Foundation decrying the situation.

Chesapeake Bay Foundation and Trout Unlimited

Call for Ban on Marcellus Gas Wells in Floodplains

Hydrofracking in floodplains is an environmental disaster waiting to happen

(HARRISBURG, PA)  —  In the rush to develop the Marcellus shale formation in Pennsylvania, natural gas wells are being permitted and drilled in floodplains. Two such wells, one operated by Stone Energy along Wyalusing Creek in Rush Township, Susquehanna County, and one operated by XTO along Muncy Creek in Shrewsbury Township, Lycoming County already experienced flooding events.  The Chesapeake Bay Foundation (CBF) and Trout Unlimited (TU) call upon the Pennsylvania Department of Environmental Protection (DEP) to remedy this clear environmental and public health hazard.

“The handling of fracking chemicals and highly contaminated drilling wastewater in floodplains is an environmental disaster waiting to happen.  It has to stop,” said Matt Ehrhart, executive director of CBF’s Pennsylvania Office.  “Permitting well pads in floodplains causes a very serious threat of pollution.  We call upon DEP to use its authority under the Clean Streams Law to order the companies operating these wells to permanently cap and abandon them, and then reclaim the sites to their natural condition.” (excerpt RDA)

http://www.cbf.org/Page.aspx?pid=1651

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DEP Issues Industrial Wastewater Discharge Permit to Williamsport’s TerrAqua Resource Management

First New Permit for Treating Drilling Wastewater to Be Issued in West Branch Susquehanna River Watershed.

WILLIAMSPORT — The Department of Environmental Protection today issued a system industrial wastewater discharge permit to TerrAqua Resource Management LLC of Williamsport that allows the company to treat and discharge 400,000 gallons per day of gas well drilling wastewater.

“This is the first new permit issued in the West Branch Susquehanna River watershed for treating gas well drilling wastewater,” said DEP Northcentral Regional Director Robert Yowell. “The monitoring requirements and stringent limits on total dissolved solids, chlorides and sulfates in this permit will protect the water quality of the West Branch Susquehanna River.”

The National Pollutant Discharge Elimination permit requires TerrAqua to meet the proposed new regulatory standards of 500 parts per million for total dissolved solids and 250 parts per million for chlorides and sulfates. These standards will be required statewide effective Jan. 1, 2011.

TerrAqua has indicated that it will pursue a thermal treatment process capable of reducing total dissolved solid levels to less than 500 parts per million at all times.

The discharge permit also requires TerrAqua to monitor for radioactivity, a large number of metals, including barium, strontium, iron, manganese and aluminum, as well as organics such as toluene, benzene, phenols, ethylene glycol and surfactants.

The company’s application for the permit, which was submitted in August 2008, went through an extensive public participation process. More than 150 people attended a DEP public meeting held in July 2009 to discuss the permit and ask questions.

“The department received nearly 200 public comments regarding this permit application and have responded to and addressed all relevant questions and concerns raised in those comments,” Yowell said.

(NOTE: MANY RDA MEMBERS WERE AMONG THOSE WHO RAISED CONCERNS, URGING DEP TO DENY THIS PERMIT IN ITS ORIGINAL FORM. WE ARE GLAD THAT TERRAQUA HAS AGREED TO ADHERE TO THE  1-1-11 TDS PROPOSED REGULATIONS.

WE WILL FOLLOW THIS APPLICATION INTO ITS NEXT PHASE WHERE THE ACTUAL TECHNOLOGY WILL BE DEFINED.

ALSO OF CONCERN ARE AIR QUALITY ISSUES. WE WILL GET A BETTER IDEA ABOUT THESE AS THE APPLICATION PROGRESSES. )

TerrAqua now must submit a water quality management permit application to DEP for the treatment plant’s design and technology. This permit is required to construct and operate the plant.

The company has also applied for a general permit from DEP’s waste management program to process, recycle and reuse this wastewater for subsequent fracking operations.

The DEP Northcentral Regional Office has nine additional permit applications under review for proposed gas well drilling wastewater treatment plants in Bradford, Centre, Clearfield, Clinton, Lycoming, and Tioga counties. Proposed discharge points include the Susquehanna, Chemung, and Tioga rivers as well as several streams.

For more information, call 570-327-3659 or visit www.depweb.state.pa.us.

Well permit fees rise in PA for the first time in 25 years

Hey, if they can hire more staff with this money maybe we’ll actually get a water specialist in north central PA within the next 5 years!
October 28th, 2009 by the gantdaily.com

DEP Announces New Oil and Gas Well Permit Application Fees Will Cover Cost of Permitting, Enforcement

First Fee Increase since 1984 Affects All New, Non-Marcellus Shale Wells

HARRISBURG– The Department of Environmental Protection has begun collecting higher permit application fees for all traditional vertical non-Marcellus Shale oil and natural gas wells drilled in Pennsylvania to cover the cost of the agency’s permitting and enforcement work.

According to Secretary John Hanger, the new fees based on well length and type replace a flat $100 fee established in 1984.

Under the new structure, which went into effect Oct. 26, vertical wells with a bore length up to 2,000 feet will now have a base permit cost of $250 with an additional $50 applied for each additional 500 feet of length.

“We have seen record growth in the number of oil and natural gas drilling permit applications over the past six years, and with the rapid development of the Marcellus Shale formation, we needed to establish a permit fee structure that will support the cost of permitting and inspecting both types of drilling operations,” Hanger said.

“The money generated from the new permit fees is allowing us to hire new staff at our Pittsburgh, Meadville and Williamsport offices to better manage and monitor the drilling industry as it expands into new areas of the state.”

The new fee structure for traditional vertical wells follows new fees the department imposed for Marcellus Shale wells in April. Marcellus Shale wells employ a horizontal drilling technology and, as such, are not considered vertical wells.

Marcellus Shale and non-vertical wells have a base permit cost of $900 for the first 1,500 feet of bore, with an additional cost of $100 for every 500 feet beyond that length.

Through Oct. 23, DEP issued 5,333 oil and natural gas drilling permits this year—1,516 of which are for the Marcellus Shale formation.

Of the 1,944 wells drilled in 2009, 403 are Marcellus Shale wells. The department has performed 10,365 inspections of drilling sites during that period.

Since 2005, DEP has issued 2,112 Marcellus Shale permits and there have been a total of 660 Marcellus Shale wells drilled.

DEP Revokes Erosion and Sedimentation Control Permits for Two Gas Companies

 

http://www.ahs2.dep.state.pa.us/newsreleases/default.asp?ID=5710&varQueryType=Detail

Three erosion and sediment permits have been revoked by the DEP in Tioga and Potter Counties. Above is the information at DEP’s website and it gives details about which companies and which sites are having these problems and why. The good part here is that the DEP was finally able to do something about these permits. The sad part is that they are permits that went into effect a couple of months ago and it has taken this long for lawyer Matt Royer from the Chesapeake Bay Foundation to acquire the ability to do something about it. This is truly a huge problem and could have been avoided had the ability of the local conservation districts to review permits not been taken out of their job descriptions! I am happy that they are finally able to do something about it. I know the local folks in the DEP here have been very frustrated by this.

Here are a few more links about this issue from various newpapers.

http://www.thedailyreview.com/news/dep_revokes_three_permits_issued_to_ultra_resources_and_fortuna_energy

http://www.stargazette.com/article/20091028/NEWS01/91028017/Pa.+agency+revokes+erosion+permits+for+Fortuna+Energy++Ultra+Resources+

NCRO Weekly Report

NORTHCENTRAL REGIONAL OFFICE-WILLIAMSPORT

WEEK OF OCTOBER 26-30, 2009

Issues Requiring the Governor’s (or Governor’s staff) ACTION

 

Nothing new to report

 

Issues Requiring the Governor’s (or Governor’s staff) ATTENTION

 

Nothing new to report

 

Management and Productivity

 

Nothing new to report

Recovery Activities

 

DEP ARRA Grants Workshop, City of Williamsport, Lycoming County: Office of Energy and Technology Deployment Manager Dave Shimmel was invited by the Larson Design Group to present an overview of DEP grants funded by ARRA and the commonwealth.  On Oct. 27, Shimmel provided a PowerPoint overview and distributed handouts of the various DEP and DCED energy grant programs to more than 60 persons.  The audience consisted of contractors, local government officials, equipment vendors and technical consultants. A representative from PPL was also present to give a presentation on the company’s Act 129 plan.  (Dave Shimmel 570-327-3568)

 

What’s Hot/Major Actions

Ultra Resources Inc. and Fortuna Energy Inc. Permit Revocations, Gains, Elk, Jackson and Ward Townships, Tioga County and Pike and Abbott Townships, Potter County: On Oct. 28, the Oil and Gas program revoked three erosion and sedimentation control permits previously issued to Ultra Resources Inc. and Fortuna Energy Inc. due to technical deficiencies. The program also sent notice of violation letters to the three licensed professionals who prepared the applications. The permit revocations mean that the two gas exploration companies must immediately halt all earth disturbance activities at the sites except those necessary to install or maintain erosion and sediment control or post-construction and site restoration best management practices. Neither company is eligible to re-submit notices of intent requesting the expedited permit process for those locations. These three permits were appealed to the Environmental Hearing Board by the Chesapeake Bay Foundation in August and September, prompting DEP to re-examine the permits to determine if they met the Chapter 102 requirements.  In its letter to the three licensed professionals, DEP advises them that additional enforcement action may be taken against them, including possible referral to the Department of State, Bureau of Professional and Occupational Affairs for disciplinary action.  (Jennifer Means 570-321-6557)

Chesapeake Appalachia LLC, Oregon Township, Wayne County: On Sept. 23, the Oil and Gas program received aerial photos depicting an area of leafless trees extending down gradient from the corner of a gas well pad located in Oregon Township.  The Robson well pad is operated by Chesapeake Appalachia LLC.  The well is drilled and shut in.  On Sept. 24, Oil and Gas program staff initially inspected the Robson well pad and the associated area of concern.  Based on this initial visual inspection, there was no evidence of a surface impact to the area with leafless trees, but the DEP inspector indicated the need for additional subsurface sampling.  DEP staff re-inspected the location on Oct. 15, collected soil samples that had a UV-IR analysis.  This analysis tests for the presence of petroleum products.  During this inspection, a faint petroleum odor could be detected in the soil where the DEP inspector disturbed the subsurface.  Sample results received on Oct. 22 confirmed the presence of a weathered petroleum product in these soil samples.  Chesapeake has been notified of the DEP sample results and the company has initiated an ongoing investigation at the well pad location.  DEP and Chesapeake have scheduled a meeting to discuss this issue on Oct. 29.  (John Ryder 570-327-0533)

 

Chief Oil & Gas LLC, Penn Township, Lycoming County: On Oct. 21, the Oil and Gas program finalized a $2,100 civil penalty with Chief Oil & Gas for past violations at the company’s Bower Unit 1H natural gas well site located in Penn Township.  On May 7, DEP conducted an inspection of the well site in response to a citizen complaint of a potential spill onto an adjacent farm field.  A Chief employee informed DEP that a subcontractor working at the well site had caused a spill while pumping drilling mud from one tank to another.  The spill of the drilling mud onto the ground was reported to Chief by the subcontractor to be insignificant and cleaned up.  Chief never reported this spill to DEP.  Chief submitted analytical results on June 12 of barium and chloride testing conducted on four soil samples, three from inside the spill site, and one from outside the spill site.  The analytical results indicated the barium and chloride levels to be within acceptable levels.  (Jennifer Means 570-321-6557)

Potential Problems/Potential Major Actions

 

Nothing new to report

 

Good News/Major Accomplishments

 

Fred Carson Disposal Services Inc., College Township, Centre County: On Oct. 28, the Waste Management program received a $2,000 civil penalty from Fred Carson Disposal Service Inc. for waste transporter violations.  A waste vehicle inspection was conducted at the Dale Summit Transfer Station in College Township, Centre County, on Sept. 9.  Carson owned two vehicles–a packer truck that did not have an operational record and a roll-off container truck that had a leaking load.  (James E. Miller 570-327-3431)

 

Gerald Lane, Troy Township, Bradford County: On Oct. 21, the Waste Management program received a $2,113 civil penalty from Gerald Lane for violations of the Pa. Solid Waste Management Act.  In June, Waste Management staff observed a large plume of smoke from a distance and responded to a fire at Lane’s property in Troy Township.  At the time of the investigation, Lane was burning a barn that contained household waste, waste tires, a mattress, a propane tank and construction/demolition waste.  Lane was attempting to extinguish the fire but he was not making adequate progress and the Troy Fire Department responded to extinguish the fire.  Lane disposed of more than five tons of solid waste at the Bradford County Landfill from the clean up of the ash residue and remaining waste from the fire.  (James E. Miller 570-327-3431)

 

Outreach/Upcoming Events

 

Act 537 Meeting, Centre Region Council of Governments, Centre County: On Oct. 26, Robert Everett, Daniel Thetford, and Robert Boos of the Water Management program’s Sewage Facilities Planning section, met with the planners of the Centre Region Council of Governments (COG).  The COG represents State College Borough, and College, Ferguson, Halfmoon, Harris, and Patton townships.  The COG has undergone some turnover in staff over the last few years as has the Sewage Facilities Planning section.  The purpose of the meeting was for new faces to meet and to have discussion on the historical, current and possible future developments in sewage facilities planning.  Topics of discussion included special protection waters/anti-degradation requirements; Chesapeake Bay Strategy requirements; review of sewage planning modules and their acceptable uses; Act 537 base plans and updates; current and alternate technologies in on-lot sewage disposal; soil and geology of the Centre Region; and the role of municipalities in the sewage planning process, among others.  The meeting was productive and appreciated by the COG. (Robert Boos 570-327-3399)

Central Pennsylvania Bankers Annual Roundtable Meeting, University Park, Centre County: Office of Energy and Technology Deployment Manager Dave Shimmel was invited by the Pa. Small Business Development Center to provide a PowerPoint overview of state energy programs to a regional banking group.  Shimmel highlighted those energy grant programs that would likely benefit from loan support and participation by these central Pennsylvania banking entities.  Twenty six persons were in attendance at the Oct. 23 session held at the Centre County Visitors Center.  (Dave Shimmel 570-327-3568)

Benton Area School District Biomass Project, Benton Borough, Columbia County: On Oct. 26, the Benton Area School District took one of the final steps in closing out its Pa. Energy Development Authority grants with a preview of its recently completed biomass boiler. The biomass unit is located in a renovated central heating plant that supplies hot water to both the junior/senior high school and the Appleman Elementary School.  The two PEDA grants totaled $700,000 towards an overall project value of just under $2 million. The project will save 45,000 gallons per year of No.2 fuel oil with projected savings of more than $90,000 even using the most expensive biomass fuel.  The system has the capability of firing a variety of biomass fuels such as wood chips, switchgrass or corn.  Office of Energy and Technology Deployment Manager and project advisor Dave Shimmel used the occasion to conduct a final site visit in conjunction with the eventual grant close out.  More than 40 persons attended the event.  (Dave Shimmel 570-327-3568)

Recertification Inspection, Milesburg Borough, Centre County: On Oct. 27, Emergency Response Manager Gerald McKernan participated with the PEMA Act 165 Hazmat Team recertification inspection for Eagle Towing and Recovery. Eagle’s Hazmat Team is contracted to Centre, Clearfield and Clinton counties in the Northcentral Region and several counties in Southcentral Region.  McKernan was tasked with reviewing their air monitoring instrumentation, calibrations records for each instrument, along with a demonstration of operation and data interpretation.  (Gerald McKernan 570-327-3722)

 

Act 2

Basalla Property Act 2 Site, Snowshoe Township, Centre County: On Oct. 23, the Environmental Cleanup program approved an Act 2 Final Report that demonstrated attainment of the Statewide Health Standards (SHS) for soil and groundwater.  On Dec. 18, 2008, 250 gallons of kerosene was released when a valve on an aboveground storage tank was inadvertently knocked open during a fuel delivery by Lucas Oil Company.  Soil downslope and in the former septic leach field were contaminated by the release.  About 120 gallons of kerosene flowed to an unused septic tank that was located downslope of the storage tank.  About 124 tons of contaminated soil was excavated in late December 2008 and early January.  Soil samples were collected and demonstrated attainment of the SHS.  Water with kerosene pooled on top was encountered in the excavation closest to the storage tank.  The kerosene/water mixture from the excavation and unused septic tank was removed and properly disposed.  Groundwater characterization was conducted by installing one monitoring well within the former excavation.  All results were below the SHS.  (Randy Farmerie 570-327-3716)

Bailey Property Act 2 Site, Mt. Carmel Township, Northumberland County: On Oct. 23, the Environmental Cleanup program approved an Act 2 Final Report for the Bailey Property located in Mount Carmel Township.  During a delivery of home heating oil by Duke Oil, a seam ruptured on a 275-gallon aboveground storage tank releasing about 160 gallons.  Minuteman Spill Response, Response Environmental Inc., and Marshall Miller & Associates conducted the remedial activities at the site as well as the submission of the Final Report.  About 60 tons of contaminated soil was excavated and 22 soil samples collected as part of the cleanup activities.  Post-excavation soil sample results indicated that the diesel fuel compounds of concern were below DEP’s Residential Statewide Health Standards for soil, and the site received an Act 2 relief of liability.

(Randy Farmerie 570-327-3716)

Costy’s Used Truck and Auto Parts Act 2 Site, Richmond Township, Tioga County:  On Oct. 20, the Environmental Cleanup program approved the Act 2 Final Report for the Costy’s Used Truck and Auto Parts property along old Route 15 just south of Mansfield.  The final report demonstrated that the Site-Specific Standard had been attained for soil and groundwater on the 30-acre site.  On July 25, 2003, DEP had previously approved an Act 2 Final Report for a 7-acre portion of the auto salvage yard, also for the Site-Specific Standard.   Lowe’s Home Centers Inc. purchased six tax parcels and will retain 26 acres with two lots being subdivided for other commercial development.  The site will be developed into a Lowe’s Home Center retail store and will include a new public water line to service the store.  An environmental covenant was established for the deeds of the affected properties that restricts the use of groundwater and limits the use of the properties to non-residential purposes.  (Larry Newcomer 570-327-3418)

NPDES Majors Backlog Status

 

Number of Overdue Permits-0

Number of Permits Issued This Week-0

Number of Permits Newly Expired This Week-0

(Chad Miller 570-327-3639)

 

Items for the DEP Planning Calendar

 

Nothing new to report

DEP issues $3,000 fine to Dunn’s Tank Service for illegal transfer station in Wysox; Company was storing gas well drilling wastewater without permit

I just want to point out two things here.

1. There is something very wrong with the fact that we have a lot of wastewater sitting around in various places, permitted or not permitted, and no place or way to dispose of it. If this industry was new to the planet then I might cut it and the state agencies a little bit of slack, but it’s not new! They have been drilling out west at this rushed rate long enough to know that they are going to have waste water and it’s going to have to go somewhere. Heck, most local residents I have spoken with can figure this out and most of them are not that familiar with the gas industry. I want to know why this problem was not solved prior to the drilling. My suspicions are as follows. The DEP and the state of PA are new to this. On some level they might claim that they didn’t know what to expect. That really doesn’t get them off the hook though. It’s their job to protect and keep themselves informed and up to date on what transpires on the state lands and waterways, so they should have made sure that somebody in the DEP knew what was to come and then made sure the regulations were in place to take care of preconceived problems, such as waste water disposal. My other suspicions are purely political and I will not get into that here, especially since they are suspicions.

2. I find it to be either extremely short sighted and poor management for Dunn’s Tank Service to not know the laws that relate to their industry or to have made no effort to find out what they are. To me that basically says, ” We don’t really care and were not really that competent.” And they’re the ones responsible for transporting toxic wastewater around the state? Wonderful.

BY JAMES LOEWENSTEIN

The Department of Environmental Protection announced Tuesday that it has fined Dunn’s Tank Service Inc. of Towanda $3,000 for operating a waste transfer station without a permit last July in Wysox Township.

“Dunn’s was storing gas well drilling wastewater in tanker trailers and you must have a waste transfer station permit from the DEP to do that,” said DEP Northcentral Regional Director Robert Yowell. “DEP will take similar enforcement action against any other such illegal facility in this region.”

DEP inspectors investigated a citizen complaint in late July and discovered two tanker trailers at the Dunn site holding about 10,000 to 12,000 gallons of gas well drilling wastewater, the DEP said in a press release that it issued on Tuesday.

A Dunn’s employee told DEP inspectors that his company was transporting the wastewater to the tanker trailers for temporary storage when disposal facilities were unable to accept it, the press release said.

The DEP sent Dunn’s a notice of violation letter containing requirements that all wastewater be removed from the site and that no additional wastewater be transported there, the release said.

A DEP inspection in August confirmed that the company had complied with those orders, the release said.

The fine was paid to the Solid Waste Abatement Fund that pays for cleanups across the state, the environmental agency said.

Todd Dunn, owner of Dunn’s Tank Service, said his company did not know the storage of the wastewater required a permit.

“We’re from Oklahoma,” he said. “It was ignorance on our part on not knowing the law.”

He said the wastewater was actually stored at the site in two steel “frac” tanks.

In Oklahoma and Texas, storage of wastewater in the frac tanks would not have required a permit, he said.

He also said the wastewater that was stored was not hazardous. “It was basically fresh water,” Dunn said.

“There was no danger,” he said. “There was no contamination or anything like that.”

“I was shocked that they didn’t give us a warning,” rather than issue a fine, he said.

Dunn said that since the fine was imposed, Dunn’s Tank Service has held a workshop for its supervisors to make sure they know the DEP rules and regulations that would pertain to the company, he said.

Dunn’s Tank Service, which is headquartered in Oklahoma, has an office in Towanda.

James Loewenstein can be reached at (570) 265-1633; or e-mail: jloewenstein@thedailyreview.com.

Two Days Remaining….

Please make sure your voice is heard by Wednesday! This is a very well written letter by Don Williams and I encourage you all to write your own or contact me for a template you can use.

At midnight on Wednesday, October 7th, the period for public comment on a permit request to dump treated gas well waste water into the Susquehanna River will close. Last week, about 60 residents gathered at the local DEP office to speak out against this permit. It is my sincere hope that you might also be willing to send an email to DEP expressing your concern over this planned toxic waste discharge into the river. Your message need not be long. Two or three sentences are sufficient. It is necessary to include your full name and mailing address in the text of the message. Please state clearly that you are opposed to allowing TerrAqua to dump treated water into the river. Addresses and a sample message appears at the bottom of this FreshMail.

At last week’s public hearing, those in attendance spontaneously broke into applause at the close of Don Williams’ prepared statement. Perhaps his views (below, in italic) will give you some food for thought as to what you might say to DEP officials.

Gas well drilling is here to stay. It is my belief that the industry’s presence here is a greater threat to public health than anything I have ever seen in my lifetime. All the organic food and vitamins in the world cannot counter balance the toxins we will all be exposed to. If you live in Pennsylvania, you will be impacted. Please be willing to stay informed and take action whenever the opportunity arises. Begin now. Thank you.

Barb Jarmoska

Good evening. I’m Don Williams of Harleysville, PA, and I appreciate the opportunity to speak tonight. I am a native and citizen of the commonwealth of Pennsylvania, and my ongoing education includes a bachelor’s degree in earth and environmental sciences from Wilkes College. In 2005, I partnered with the Chesapeake Bay Foundation and American Rivers to name the Susquehanna River as the most endangered river in the nation. It appears we may be soon approaching that point again.

As an environmentalist who witnessed and participated in the first earth day, I continue to marvel at the infinite wisdom of Rachel Carson’s choice of three simple words – web of life – to describe all of nature. Almost 40 year after the first earth day – we are now at a point where this commonwealth’s commitment to protecting the environment is – in truth – heading toward where it was 40 years prior to 1970. In the present day Marcellus Shale frenzy, we are once again striking a Faustian bargain at the expense of our natural resources, jeopardizing the quality of our land and our waters in exchange for the false promise of jobs and fleeting economic prosperity for a limited few.

A detailed DEP study done earlier this year concluded that about 980,000 pounds per day of assimilative capacity remains for total dissolved solids on the West Branch. TerrAqua’s draft discharge permit allows between 54,412 and 522,245 pounds per day of total dissolved solids to be discharged to the river.

Let’s crunch these numbers a little further. This equates to 15.7 million pounds of solids – containing far too many unknowns – being dumped into the west branch of the Susquehanna every month. That’s about 95 tons per year. And that’s from one treatment plant. If we continue to accept frackwater in a growing number of new treatment plants on the north branch as well, what will our watershed, and our waters, look like next year…or 5 years from now, and what will we leave as our legacy for future generations?  Where is the tipping point of assimilative capacity? I certainly don’t know, however, having studied numerous detailed environmental modeling failures over the past three decades, I truly do not believe the DEP knows either.

In May 1971, just about one year after the first earth day, the following amendment was added to the Constitution of this commonwealth:

“The people have a right to clean air, pure water, and to the preservation of the natural, scenic, historic and esthetic values of the environment. Pennsylvania’s public natural resources are the common property of all the people, including generations yet to come. As trustee of these resources, the Commonwealth shall conserve and maintain them for the benefit of all the people.”

Webster’s defines pure as: “unmixed with any other matter” and conserve as: “avoid wasteful or destructive use of”. So far, from my perspective, it appears that many of our state and federal agencies have differing views on exactly what these words mean.

I am fully opposed to the further degradation of the Susquehanna River by any action or from any source. Further, until there is a complete disclosure of any and all chemicals used in the horizontal hydro fracturing process, I am requesting that any action on any/all frackwater treatment plant applications be suspended indefinitely.

As a citizen of the commonwealth of Pennsylvania, and per our Constitution, I believe these are our lands these are our waters. What is happening throughout the Susquehanna and Delaware and Ohio watersheds today, and how we react to it, will be our legacy to those generations yet to come. I believe that the “state of independence” is much, much more than a tourism slogan. From Dimock to Dunkard Creek, from Lake Otsego to the Chesapeake Bay, and from Harrisburg to Washington, we must do all that is necessary to ensure our gift to the future includes cleaner waters, cleaner air, and a Penn’s Woods we will be proud to leave behind. Thank you.