Writer wrong about lab
This is in response to several incorrect statements in Jason Bell’s letter to the editor of Dec. 28, “Marcellus report flawed,” dealing with drilling in Connoquenessing Township.
Environmental Service Laboratories, Inc. (ESL) is an independent, third-party sampling firm and Pennsylvania-accredited drinking water laboratory headquartered in Indiana, Pa. ESL’s three locations in this state are accredited by the state Department of Environmental Protection through its Bureau of Laboratories’ Chapter 252 Laboratory Accreditation Program.
The purpose of this accreditation program “is to protect public health, safety, welfare and the environment by ensuring accuracy, precision and reliability of data generated by environmental laboratories” and requires an unbiased quality system, accurate and legally defensible reporting of results, qualified and educated personnel, regular audits by the DEP Bureau of Laboratories, and yearly “blind” proficiency testing in order to provide accredited laboratory test results.
Furthermore, ESL often participates in voluntary audits by outside auditing firms and maintains a voluntary quality certification via ISO 17025, a program designed to ensure testing, calibration and sampling competency. This ISO certification is used by laboratories in developing their management systems for quality, administrative and technical operations. It is routinely used by regulatory agencies and accreditation bodies to confirm and recognize laboratory competency.
Bell’s statement indicating that samples were taken and completed without oversight by the DEP is preposterous. ESL operates seven days a week, 365 days a year under DEP oversight. At any given moment, DEP has the authority to arrive at ESL unannounced and inspect its operations, audit its data collection and reporting procedures, review raw data and analytical techniques, and scrutinize sampling practices.
Deviations are recognized with immediate required change, loss of accreditation, civil penalties, or even jail time.
Likewise, the DEP requires copies of every predrill water survey within 10 business days of operator receipt, if the operator elects to use them as defense against false claims of pre-existing contamination.
Did AMEC, a Sewickley engineering consultancy firm contracted by State College-based Rex Energy, verify calibration of the test equipment? It didn’t have to, as ESL could not report data that didn’t pass all quality control and calibration criteria without required disclosures. All data went through ESL’s internal three-tiered review process before any reports were issued.
Browsing past the home page on ESL’s website (www.environ-mentalservicelab.com) would have led Bell to view other associations besides the Marcellus Shale Coalition (MSC) that ESL maintains membership in, including the Pennsylvania Association of Accredited Environmental Laboratories (PAAEL). ESL joined MSC to provide technical guidance achieved through 24 consecutive years of collecting and analyzing thousands of predrill water samples.
No other laboratory in Pennsylvania has this experience.
Chapter 78.52 of Pennsylvania’s Oil and Gas Act specifies that predrill water surveys “shall be conducted by an independent certified laboratory. A person independent of the well owner or well operator, other than an employee of the certified laboratory, may collect the sample and document the condition of the water supply, if the certified laboratory affirms that the sampling and documentation is performed in accordance with the laboratory’s approved sample collection, preservation and handling procedure and chain of custody.”
Rex Energy conformed to this regulation by contracting independent and certified ESL personnel to collect the predrill water samples in their planned operating areas, including Connoquenessing Township.
