I support the positions proposed. It is clear that episodic monitoring for a few days at a time is unlikely to identify emissions from "upsets" or fracking events and other activities that occur commonly during well completion. Thus, while the EPA monitoring is a step in the right direction, it is neither sufficient nor conclusive enough to allay community concerns. Question as simple as "What was happening at the site during the monitoring?" and "Which way was the wind blowing that day?" have not been answered, so anyone with concerns about air pollution is likely to remain concerned.
Continuous emissions monitoring is needed at the site, and ambient monitors at an upwind and a downwind location are needed to verify that off-site concentrations do not cause health or environmental impacts. Appropriate technology is available to significantly reduce emissions, and regulations in some states require these. But until the WV Legislature passes a Marcellus bill with stringent air pollution requirements, WV-DEP adopts rules to implement that legislation, and the needed inspectors and enforcement programs are in place to assure compliance, Morgantown's air remains at risk, and no one is watching.
Jim Kotcon
Duane330@aol.com 10/24/2011 3:47 PM >>>
To: Participants and Friends of Mon Valley Clean Air Coalition.
MVCAC is an advocate for prohibiting drilling and fracking in the
Mon Valley. We have also advocated testing if drilling and fracking
do occur. Now that drilling and fracking have occurred and EPA has
done tests at the Skyview Elementary School, let me propose a current
position for MVCAC.
1. MVCAC approves of the testing thus far and recognizes that the air was not impacted at the Skyview Elementary School on the three dates tested.
2. We recognize that this school is within about 6,000 feet of the well pad. We wonder why testing and protective measures against air pollution have not been performed at any of the thirty or so businesses that are within 200 feet to 3,000 feet from well pad. Has monitoring been offerred to any of these locations? We think not.
3. We recognize that the air pollution from Marcellus drilling and fracking operations occurs in rather rapid episodes, and any human exposures at the well site, at the adjacent businesses, at the schools and at the residences in the Monongahela valley will be nearly impossible to measure without continuous monitors that are located at these listed sites.
4. Continuous methane monitoring is recommended near the well pad because methane is easy to detect, because it will be present in higher concentrations than the other pollutants, and because it serves as an indicator that many other hazardous or toxic substances are present.
5. Given that fracking was not completed on one of the wells at the Morgantown Industrial Park and given that much more work will be involved there before these two Marcellus wells are actually connected to gathering and transmission pipelines, it is highly recommended that continuous methane monitoring be instituted as soon as possible, with daily (or continuous) reporting of the data to the public, for the protection of all the residents and workers in the vicinity of the wells as well as in the greater Mon valley.
YOUR COMMENTS ARE SOLICITED ON THE ABOUT POINTS, TO BE PRESENTED TO THE MORGANTOWN CITY COUNCIL TOMORROW, TUESDAY, OCTOBER 25, 2011. WE CAN ALSO SUBMIT OUR STATEMENT, ONCE FINALIZED TO THE WV-DEP AND TO THE U.S. EPA, THE AGENCY THAT DID THE THREE TESTS (AT THE REQUEST OF THE WV-DEP).
Duane Nichols, _duane330@aol.com_ (mailto:duane330@aol.com) , 304-216-5535