Comments on Permit for an Underground Injection Control well in Plum Borough, PA
July 26, 2017
U.S. Environmental Protection Agency - Region III
Ground Water & Enforcement Branch (3WP22)
Re: Penneco Environmental Solutions, LLC - Permit No. PAS2D701BALL
Dear Mr. Scavello,
On behalf of Clean Water Action’s over 15,000 members in Allegheny County, I am submitting comments regarding the permit for an Underground Injection Control (UIC) well to dispose of oil and gas waste that EPA is proposing to issue to Penneco Environmental Solutions in Plum Borough, PA.
In addition, Clean Water Action is requesting that EPA extend the public comment period for an additional 30 days in order to ensure that Allegheny County residents are able to fully inspect documents relevant to the proposed permit. As this is the first UIC disposal well proposed in Allegheny County, residents are not familiar with either the nature or process through which EPA undertakes in permitting proposed UIC disposal wells.
Clean Water Action urges EPA to deny the proposed UIC permit for Penneco Environmental Solutions for a number of reasons. First, EPA has failed to identify all the underground sources of drinking water (USDWs) that could be endangered by the injection site that meet the standard of containing 10,000 mg/L or less of Total Dissolved Solids (TDS). EPA’s Statement of Basis provides a vague declaration that groundwater quality below 500 feet is ‘poor’ without quantifying the known water quality data, or providing an exact source. Given the shallow nature of the injection zone (1,900 feet) and that the well casing only runs to 643 feet, the exact location of USDWs that could be contaminated is critical to EPA’s determination.
Second, EPA should examine in far greater detail the problem of other gas wells, operating, plugged, or abandoned, that penetrate the injection layer and could provide a pathway for contamination. Pennsylvania DEP records indicate at least 40 gas wells exist currently in Plum Borough, including the five identified by EPA as within 1,000 feet of the injection site. EPA has noted in the Statement of Basis (p. 4) that there is significant oil and gas production near the injection site.
EPA needs to analyze at a minimum the potential threat to USDWs from the possible interaction between the UIC well and the other gas wells. Examining any well integrity issues from these wells, compliance reports, hydraulic fracturing that has already occurred or is planned in the future are all needed in order to determine if an existing or future contamination pathway could be created once the UIC well begins operating. Simply identifying other nearby wells is not sufficient.
Clean Water Action would also like to see EPA present more detailed evidence to their assertion that the potential for seismic activity from the injection well is low. Although Region III’s framework document is referenced, it is not clear to what extent it is relevant to the conclusion. In addition, as Pennsylvania DEP has already documented earthquakes in western Pennsylvania that have been triggered by hydraulic fracturing, EPA should analyze why this is unlikely with an injection well which creates far greater stress than a one time fracturing.
Further, Clean Water Action requests that EPA consider the compliance record of the applicant in determining if they are capable of complying with the proposed permit limits which is critical to preventing contamination. A review of Pennsylvania DEP records finds that Penneco has committed over 50 violations in operating oil and gas wells in Pennsylvania. Some of these violations are significant and include failing to properly control and dispose of industrial and residual wastes resulting in water contamination. Some of these violations occurred in Plum Borough previously. We have attached a list from DEP’s records of these violations.
Finally, Clean Water Action is concerned with the overall threat that a UIC facility in an urban metropolitan area poses to human health and quality of life. We urge EPA to carefully consider the issues involved in permitting such a facility with the proposed operator in the proposed location.
I appreciate your attention to these comments and we look forward to your reply.