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


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