### 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 ofEnvironmental Protection Bureau ofWater Standards and Facility Regulation Rachel Carson State Office Building, PO Box 8774 Harrisburg, PA 17105-8774 RE: Request for Information- Permit ID: PA0028428 BrockwayArea Sewerage Authority, Jefferson and Elk County Dear Mt. Furlan,**~.-.:** -);**~**

## ..... r-I'TJ 

### :::;::e -<(/) 

### :u;;;l ITl;,c ot:::**C:::t>~** 

# !;:2; ::!rn 0 We are in receipt ofyour request letter dated March 18,2011. Please be

## advise1f~ follows concerning this letter. First, itis 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 ourNPDES permit is currently inthe process ofrenewal and that wehave objected to some ofthe 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 theymust pay for all additional testing resulting from our acceptance of their wastewater. This additional monitoring will beundertaken ifit 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 showingthat such pollutants are present inbrine wastewaters. In fact, the only definite study wehave seen to date, presented byBucknell University at the "Science of Marcellus Shale", Lycoming College, Williamsport, January 29, 2010, found no radiation problems with Marcellus shale wastewaters. 

# - - :z.,. 

# , :::0 I 

### c.n 3ao 

### :::r '!?**~** 

### c.n

1 .::0 

# ....**~** < i;;JBurtWaite, PG, ofMoody and Associates, Inc., has informed us that his review and study ofMarcellus brine wastewaters shows no problem with the levels ofnaturally occurring radioactives present inthese wastewaters. This study included concentration ofsuch materials inwastewater treatmentprocesses, where he found that even when concentrated in sludges, there have beenno 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 maybe a problem inbrine wastewaters? We appreciate your consideration ofourposition onwhat to date appears to be costly additional monitoring that cannotbejustified on the facts. Sincerely, 

# Timothy Keister TimothyKeister, CWT Board Chairman Brockway Area Sewerage Authority

cc: D. Sinclair, Dannie Energy

2