An environmental group has released a study criticizing the U.S. Environmental Protection Agency for a "minimal review" that led to the recent permitting of two injection wells in Warren County.
"EPA Region III has conducted a minimal review of the potential for problems with these waste disposal wells. Given the highly toxic nature of gas drilling wastewater, we expect EPA to thoroughly investigate these permits which can put the public health and environment at risk," Clean Water Action State Director Myron Arnowitt said in a press release. "We already have leaking waste disposal wells in Pennsylvania - EPA should be giving this type of disposal more scrutiny, not less."
Clean Water Action released "Bittinger Injection Well Permits Technical Review", a study prepared for the University of Pittsburgh School of Law Environmental Law Clinic by Philip R. Grant, senior geologist with Terra Dynamics Inc. of Austin, Texas.
The review studied publicly available documents related to the injection well permits issued by the EPA to Bear Lake Properties and was completed on Aug. 14.
Bear Lake Properties, the owner of the wells in Columbus Township, was issued final permits on Nov. 29 to inject wastewater from drilling into a depleted gas zone within the Medina Formation at depth between 4,200 and 4,300 feet.
Grant's review states the EPA did not address issues raised in the permitting process such as mechanical integrity testing, operating requirements, well construction, calculated injection pressure, calculated area of review, injection zone monitoring, plugging and abandonment of the wells, subsurface geology and earthquake hazards.
"These issues may at some point all be addressed adequately to the satisfaction of the petitioners, USEPA, and applicant, and well operations begin at the Bittinger wells in a safe and environmentally protective manner. However, until these issues are addressed in a satisfactory and complete manner, it would be prudent for the USEPA to reconsider the permit applications and proposed permits," the review states.
"To our understanding EPA has not addressed any issues with these wells," Arnowitt said. "We haven't seen EPA really address the issues, whether it's about lack of monitoring or really looking at the geology of these specific wells."
According to the review, "The operating and workover histories of the two Bittinger wells are not provided in the permit applications. During their 25-plus years of operation, numerous well workovers are likely to have been performed, providing useful information related to any recurring mechanical integrity failures, general well failures, or other operational issues."
Tetra Tech, Bear Lake Properties' contractor for the application for construction used "overly lenient" methodology in "determining the permitted maximum surface injection pressure" and the formula used by the contractors "does not utilize the methodology typically employed in the industry," the review says.
The study also finds the EPA should consider requiring mechanical integrity tests to be available for public review before issuing final permits.
"The USEPA has permitted these injection wells without the applicant having provided any publicly reviewable documentation that these wells have or can pass mechanical integrity testing required by the permits," the review states. "Once permitted, the mechanical integrity testing results will, according to the terms of the permits, only have to be reviewed and approved by the USEPA staff, thus preventing any opportunity for public review and comment prior to the well operator beginning injection operations."
Further documents were not made publicly available including the calculations used by the EPA to determine the area of review around the wells "to verify the applicant's calculations, and found the calculations acceptable."
"None of the USEPA calculations have been provided for public comment or review, which brings into question the independent nature of the USEPA review," the review states.
The EPA has taken the permit applications at "face value", Arnowitt said, and "has not done a serious review of its contents to impose meaningful safety measures in the Bittinger permits."
The review further states no information is given to the monitoring of water levels in shut-in and depleted natural gas wells within the area of review around the wells.
"Semi-annual monitoring of these offset wells' fluid levels may not be at the frequency to provide adequate safeguards relative to pressure increases which might occur in the injection reservoir, potentially endangering USDWs (underground sources of drinking water)," the review states. "Any incorrectly plugged undocumented boreholes or natural transmissive conduits (faults, fractures) could endanger shallow USDWs before the proposed monitoring program results would initiate cessation of the injection well operations."
"Exposing sensitive groups, like pregnant women or small infants, to toxic wastewater contamination for up to six months is not acceptable," Arnowitt said. "Companies that discharge this same wastewater into rivers have to report every month. Injection well operators should be no different."
The EPA and the state Department of Environmental Protection will hold a public meeting on the two wastewater disposal wells in Columbus Township at 6 p.m. Wednesday, Dec. 12, at the Columbus Township Volunteer Fire Department, 7 W. Main St.
Officials from both agencies will answer questions and discuss their roles in the permitting in the Underground Injection Control process.
"This is an opportunity for area residents to talk to both our staff and EPA about the roles we each play in the process," DEP Northwest Regional Director Kelly Burch said in a press release. "The people of Bear Lake asked for an opportunity to meet with us to get answers to their questions, and we want to ensure the process is transparent."