UNITED STATES ENVIRONMENTAL PROTECTION … - four penn center

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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION III
Four Penn Center
1600 John F Kennedy Blvd
Philadelphia, Pennsylvania 19103-2852
STATEMENT OF BASIS
U.S. EPA UNDERGROUND INJECTION CONTROL (UIC)
DRAFT CLASS II-D PERMIT PAS2D702BALL
FOR
PENNECO ENVIRONMENTAL SOLUTIONS, LLC
6608 ROUTE 22
DELMONT, PA 15626
FOR
A project consisting of one Class II-D commercial disposal injection well, for the purpose of injecting
fluids produced solely in association with oil and gas production, located in:
Plum Borough
Allegheny County, Pennsylvania
On July 23, 2021, Penneco Environmental Solutions, LLC ("Penneco" or "the Permittee")
submitted a UIC permit application to the U.S. Environmental Protection Agency ("EPA" or the
"Agency"), Region 3, for the issuance of a permit that would allow for the conversion and operation of a
Class II-D commercial disposal injection well, Sedat #4A, API # 37-003-21644, (hereinafter, "Injection
Well", "Sedat #4A", or the "Facility"), located in Plum Borough in Allegheny County, Pennsylvania.
The coordinates for the Injection Well are: Latitude 40? 31' 36.897'' Longitude -79? 42' 39.6972". The
application was officially deemed complete on August 5, 2021. The Permittee's July 23, 2021 submittal
with all accompanying attachments is hereinafter referred to in this Statement of Basis as the "Permit
Application".
Pursuant to the federal Safe Drinking Water Act, 42 U.S.C. ?? 300f et. seq., and its
implementing regulations, 40 C.F.R. Parts 144 -146, and 40 C.F.R. ?? 147.2350 - 2352, the EPA has
developed a federal UIC Program and, through the issuance of permits, is responsible for regulating the
construction, operation, monitoring and closure of injection wells that place fluids underground for
disposal or enhanced recovery in oil and gas production. Today's draft permit specifies conditions for
Injection Well construction, operation, monitoring, reporting, and plugging and abandonment which are
designed to protect and prevent the movement of fluids into Underground Sources of Drinking Water
("USDW"). The Permittee's UIC project and the draft permit conditions specific to the project are
described below:
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Area of Review: Pursuant to the applicable regulations, 40 C.F.R. ?? 144.3 and 146.6(b), the "Area of
Review" is an area surrounding the Injection Well for which the applicant must first research, and then
develop, a program for corrective action to address any wells that penetrate the injection zone and which
may provide conduits for fluid migration during the injection operation at the Facility. Penneco
proposed a fixed radius Area of Review of one-quarter mile, which EPA has determined to be
acceptable. In support of using a fixed radius Area of Review, EPA has considered the following
information provided by the Permittee: survey by Fox and Fox, Inc., conversation with surface
landowners, research of Pennsylvania Bureau of Oil and Gas Management's well records, research of
Pennsylvania Geological Survey publications covering the Area of Review, research of United States
Geological Survey publications covering the Area of Review, master theses from West Virginia
University, and a series of reservoir tests by HFrac Consulting Services. Penneco used the results from
the aforementioned research along with topographic and tax maps displaying surface features (such as
buildings and streams) to prepare the maps of the Area of Review that are included with the permit
application. The Sedat #4A Area of Review is located in the Pittsburgh Low Plateau Section of the
Appalachian Plateau physiographic province. Underlying rock types are shale, siltstone, sandstone,
limestone, and coal. The Permittee indicated that there are six (6) wells within the Area of Review that
penetrate the injection zone, which includes the proposed injection well, Sedat #4A, and the EPA-
permitted Sedat #3A injection well Of the other four (4) wells within the Area of Review, three (3) are
active production wells and one (1) well (API # 37-003-00674) has been plugged in accordance with
Pennsylvania Department of Environmental Protection regulations. The Sedat #2A well (API #37-003-
21222) will be converted into a monitoring well. There are 14 wells within the ? mile Area of Review
that penetrate the Murrysville sandstone. All the wells were cased and cemented through the Murrysville
sandstone. If any unplugged/abandoned wells that penetrate the injection zone are found within the Area
of Review at a later date, the draft permit requires the Permittee to perform corrective action.
Underground Sources of Drinking Water (USDW): A USDW is defined by the UIC regulations as an
aquifer or its portion which, among other things, contains a sufficient quantity of ground water to supply
a public water system and which also contains fewer than 10,000 mg/L (milligrams per liter) Total
Dissolved Solids, and which is also not an exempted aquifer. Aquifers in the Area of Review are mainly
sandstones of the Conemaugh Group and the Allegheny Group. The thickness of the section from the
Conemaugh Group through the Allegheny Group runs in the range of 800 feet below ground surface
depending on surface elevation. The Permittee notes that Pennsylvania Geological Survey Water
Resource Reports #35 and #37 state water quality is extremely poor beyond 500 feet in depth below
ground surface because of moderate to high mineralization of the waters due to high dissolved solids and
brine. The established lowermost USDW for the nearby Sedat #3A well (PAS2D701BALL) is
approximately 450 feet below ground surface. Taking the elevation difference between Sedat #3A and
Sedat #4A into account (-38 feet), EPA has determined that the lowermost USDW at Sedat #4A is
calculated at approximately 412 feet below ground surface. Construction of the Injection Well requires
the Permittee to install surface casing to a depth of approximately 564 feet and to cement that entire
length of casing back to the surface. The Permittee must, among other requirements, also install
intermediate casing from the ground surface to an approximate depth of 1,906 feet and cement that
intermediate casing back to the surface, and install long string casing from the ground surface to a depth
of approximately 1,680 feet and cement that long string casing back to the surface. The Permittee must
install in the Injection Well, and inject fluids through, a tubing string which is set on a packer and placed
above the injection zone interval at approximately 1,650 feet below ground surface. Both the surface
casing and the intermediate casing are required to protect ground-water.
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Injection and Confining Zones: Injection of fluids for disposal is limited by the draft permit to the
Murrysville sandstone formation in the subsurface perforated interval between approximately 1,740 feet
to 1,800 feet below ground surface.
The Murrysville sandstone is approximately 94 feet thick and lies at a depth of 1,706 feet to 1,800 feet
below ground surface in the Sedat #4A Area of Review. The lowermost USDW is separated from the
injection zone by approximately 1,328 feet. The Sedat #4A well had an original total depth of 3,886 feet
below ground surface and will be plugged back to 1,850 feet (approximately 50 feet below the injection
zone). Fluid will be injected into a 60 foot section of the Murrysville sandstone through a 2 7/8 inch
injection string set on a packer at approximately 1,650 feet in 4 ? inch casing cemented to surface and
into perforations in the 7 inch casing from 1,740 feet to 1,800 feet below ground surface. The confining
zones are the Riddlesburg Shale (Sunbury Equivalent) which overlays the Murrysville sandstone with
the Riceville-Oswayo Shale lying underneath as the lower confining zone. The Riddlesburg Shale,
serving as the upper confining zone, is composed of laminated shale and siltstone with occasional
sandstone and limestone beds. The Riddlesburg Shale is between 80 to 90 feet thick in the Sedat #4A
Area of Review. Because of the Murrysville sandstone's thickness, high porosity, and permeability, the
formation serves as a gas storage reservoir to the south of the Sedat lease. The Riceville-Oswayo Shale,
serving as the lower confining zone, is composed of shale and siltstones. The Riceville-Oswayo Shale is
about 30 feet thick in the Sedat #4A Area of Review.
Injection Fluid: The draft permit limits the injection fluids in this well to produced fluids obtained
solely in association with oil and gas production. The draft permit also establishes a maximum daily
injection volume of 54,000 barrels per month. One barrel of fluid is equal to 42 gallons.
The Permit Application includes analyses of the injection fluid that corresponds to the requirements
stated in Paragraph II.C.3. in the draft permit. The parameters chosen for sampling reflect not only some
of the typical constituents found in the injection fluid, but also in shallow ground water. Should a ground
water contamination event occur during the operation of the Injection Well, EPA will be able to
compare samples collected from groundwater with the injection fluid analysis to help determine whether
operation of the Injection Well may be the cause of the contamination.
Maximum Injection Pressure: To determine the Maximum Allowable Injection Pressure (MAIP), the
Permittee shall conduct formation testing and shall submit in writing to the Director the following
information prior to commencing injection: Instantaneous Shut-In Pressure (ISIP) data and the range of
specific gravity of the injection fluid that the Permitee expects to encounter during normal operation of
the well. The MAIP determined by the formation testing will be reviewed and must be approved by the
Director before authorization to inject is granted.
Potential for Seismicity: The SDWA regulations for Class II injection wells do not require
consideration of the seismicity of the region, unlike the SDWA regulations for Class I injection wells for
the injection of hazardous wastes. See regulations for Class I hazardous injection wells at 40 C.F.R. ??
146.62(b)(1) and 146.68(f). Nonetheless, because of public concerns about injection-induced seismicity,
EPA evaluated factors relevant to seismic activity as discussed below and addressed more fully in
Region 3 framework for evaluating seismic potential associated with UIC Class II permits. The final
permit will provide that the Permittee shall only inject produced fluids through the Injection Well and
into a formation which is overlain by a confining zone free of known open faults or fractures within the
Area of Review, as required pursuant to 40 C.F.R. ? 146.22.
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