EPA’s Underground Injection Control Program Brine Disposal Well Regulation in Pennsylvania Stephen Platt, UIC National Expert

UIC Program History Regulations authorized under the Safe Drinking Water Act National concerns regarding unregulated injection Protects USDWs from all types of injection UIC program regulations promulgated in July, 1980 EPA begins direct implementation of the Pennsylvania program June, 1985

UIC Well Classification Class I – Industrial and Municipal (including hazardous waste) Class II – Oil and Gas (including enhanced recovery and brine disposal) Class III – Mining related (e.g. salt solution mining) Class IV – Shallow hazardous waste injection, banned Class V – All other wells

EPA UIC Permitting Mandate to protect underground sources of drinking water (USDWs) USDWS defined as having less than 10,000 mg/l Total Dissolved Solids Current and future use protected Permitting is performance based Hydraulic fracturing not regulated under UIC Program

EPA UIC Permitting (cont.) Major Permitting requirements: Defining Area of Review/Zone of Endangering Influence Injection well construction (Depth of surface casing critical) Well operation (Maximum Injection Pressure and Injection Rates critical) Mechanical integrity testing Plugging and abandonment Financial Responsibility

Area of Review

Permit Issuance Process No application fee One stop shopping: Permit issued for construction, operation, monitoring and reporting Processing generally takes between 3-6 months Public notification and opportunity for public hearing required.

Brine Disposal in Pennsylvania Facility Name County Injection Formation Injection Pressure Injection Volume (Bbls/M) Columbia Gas Beaver Huntersville/Oriskany 1300 21,000 EXCO-North Coast Clearfield Oriskany 3240 4260 CNX Gas Greene Mine Void 0 150,000 Range Resources* Erie Gatesburg 1570 20,000 XTO Energy # Indiana Balltown 1930 3600 Cottonwood Somerset Oriskany 3250 27,000 EXCO-North Coast Clearfield Oriskany 1450 4200 Dominion Somerset Huntersville/Oriskany 3218 30,000 *Only commercial facility # Recently Plugged

Disposal Horizons Wells typically converted from unproductive or depleted gas production wells More research on other potential saline disposal zones needed Most reservoir data obtained from past drilling history or injectivity testing

Injectivity Testing Requirements Letter of Authorization from EPA Short term testing (no more than 30 days) Volume limitation imposed Maximum injection pressure limitation imposed Well must be protective of USDWs Continuous monitoring required PADEP regional offices notified

Injectivity Testing (cont.) As of mid-August, 13 injectivity testing applications approved Approximately half have been completed Requests concentrated in the Northeastern and Southwestern, PA

Questions? Steve Platt (215) 814-5464 Dave Rectenwald (814) 449-9577