MON VALLEY CLEAN AIR COALITION, October 25, 2011.

The US EPA performed limited air monitoring at the Skyview Elementary School on three separate days. Such monitoring is unlikely to identify emissions from "upsets" or fracking events and other activities that occur commonly during Marcellus well operations.The EPA monitoring is a step in the right direction but it is neither sufficient nor conclusive enough to remove community concerns. MVCAC is an advocate for prohibiting drilling and fracking in the Mon Valley. We also advocate continuous air monitoring and testing if drilling and fracking do occur. We now advocate the following conditions:

1. Skyview Elementary and two other schools are within about 6,000 feet of the well pad. Closer still are thirty or so businesses that are within 200 feet to 3,000 feet from the well pad. Continuous monitoring should be in place for all three schools and for these business locations.

2. We recognize that the air pollution from Marcellus drilling and fracking operations occurs in rather rapid releases, 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 near these sites.

3. Continuous methane (or combustible gas) 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.

4. 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 recommended that continuous methane monitoring be established 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.

5. We are concerned about the future, not only of these two wells but of the many more wells that will be coming into our County without adequate protection for the public health and welfare.

In summary, continuous emission monitoring is needed at the site, and ambient monitors at upwind and downwind locations are needed to verify that off-site concentrations do not cause health or environmental impacts. Appropriate control technology is available to significantly reduce emissions, and regulations in some states already require these. But until the WV Legislature passes a Marcellus bill with stringent air pollution requirements, until WV-DEP adopts rules to implement that legislation, and until the needed inspectors and enforcement programs are in place to assure compliance, the air in Monongalia County remains at risk, and no one is watching. City Council should retain the current ban and contact the Legislature and the Governor to support Marcellus regulations.

Contacts: Duane Nichols and Linda Shuster, Board of Directors, Mon Valley Clean Air Coalition. Phone: 304-599-8040. _www.monvalleycleanair.org_ (http://www.monvalleycleanair.org)

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