Brockway Area Sewage Authority 

70 Industrial Park Drive 

Brockway, PA 15824 

p 814-265-0830 

F 814-265-0830 

E basa@brockwaytv.com 

March 31,2011 

Mr. Ronald C. Furlan, PE 

Pennsylvania Department of Environmental Protection 

Bureau of Water Standards and Facility Regulation 

Rachel Carson State Office Building, PO Box 8774 

Harrisburg, PA 17105-8774 

RE: Request for Information- Permit ID: PA0028428 

Brockway Area Sewerage Authority, Jefferson and Elk County 

Dear Mt. Furlan, 

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We are in receipt of your request letter dated March 18,2011. Please be advise1f~ follows concerning this letter. 

First, it is our understanding that our facility is not receiving any wastewater related to 

Marcellus shale gas drilling operations. The brine wastewaters treated and discharged by 

our facility under contract to Dannie Energy are reported to be from standard gas 

production wells only. 

You should also note that our NPDES permit is currently in the process of renewal and 

that we have objected to some of the monitoring and effluent requirements proposed by 

the Department. 

Going to your specific requests, we currently check our effluent for pH and conductivity 

(as a stand-in for total dissolved solids). We have no problem accepting the additional 

sampling for total alkalinity, chloride, sulfate, and bromide, and having a certified 

laboratory start running total dissolved solids, as our contract with Dannie Energy 

provides that they must pay for all additional testing resulting from our acceptance of 

their wastewater. This additional monitoring will be undertaken if it is made a permit 

condition on our pending NPDES permit. 

We strongly object to any requirements for radiation monitoring as to date there has been 

no study showing that such pollutants are present in brine wastewaters. In fact, the only 

definite study we have seen to date, presented by Bucknell University at the "Science of 

Marcellus Shale", Lycoming College, Williamsport, January 29, 2010, found no radiation 

problems with Marcellus shale wastewaters. 

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Burt Waite, PG, of Moody and Associates, Inc., has informed us that his review and study 

of Marcellus brine wastewaters shows no problem with the levels of naturally occurring 

radioactives present in these wastewaters. This study included concentration of such 

materials in wastewater treatment processes, where he found that even when concentrated 

in sludges, there have been no reported cases where relevant standards for solid waste 

disposal were exceeded. This was a personal communication following the March 29, 

2011, Toby Creek Watershed Association sponsored public meeting on Marcellus 

activities in the Little Toby Creek watershed. 

Does the Department have any information which shows that such pollutants may be a 

problem in brine wastewaters? 

We appreciate your consideration of our position on what to date appears to be costly 

additional monitoring that cannot be justified on the facts. 

Sincerely, 

Timothy Keister 

Timothy Keister, CWT 

Board Chairman 

Brockway Area Sewerage Authority 

cc: D. Sinclair, Dannie Energy 

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