CLEARFIELD – The Clearfield County Commissioners are submitting a letter requesting reconsideration of the federal Environmental Protection Agency’s (EPA) decision to approve the construction of a disposal injection well in Brady Township.
Two-and-a-half years ago, Windfall Oil & Gas of Falls Creek proposed a frack/brine fluid disposal injection well to be located on Highland Street Extension in Brady Township. Frank Zelman is the landowner and lease holder with Windfall Oil & Gas.
In Pennsylvania, a Class 2 disposal injection well requires an EPA Underground Injection Control permit. It also requires a state Department of Environmental Protection (DEP) well drilling permit.
On Feb. 14, the EPA issued Windfall Oil & Gas its UIC permit for its proposed disposal injection well. However, Windfall Oil & Gas still cannot begin drilling until the EPA finalizes the UIC permit after an appeals period and it also receives its DEP drilling permit.
The commissioners requested further review of the permit decision and a denial based upon evidence submitted to them by citizens.
In their letter, the commissioners cited EPA requirements that all Class 2 disposal injection wells shall inject into a formation, which is separated by a confining zone that is free of known open faults or fractures within the area of review.
The EPA further requires that well injection will not result in the movement of fluids into the underground source of drinking water so as to create a significant risk to the health of persons.
According to the commissioners’ letter, well logs show another deep gas well into the same formation as the permit application request. The well logs with the permit application show they have been fractured and reside along the edge of the quarter-mile area of review. However, Windfall Oil & Gas stated that there isn’t any fracture data available in the area of the confining zones.
“Proving fractures into the quarter-mile area of review should be sufficient data to provide basis to deny this permit,” stated the commissioners in the letter.
Further looking at the response summary, the commissioners also pointed out that the EPA stated five Oriskany wells were farther away, locating them at least one-half mile to one mile from the proposed disposal injection well. This, the commissioners stated, is inaccurate as they are right outside the one-quarter mile area of review and just feet from the line shown on the maps provided in the permit application.
The commissioners also pointed out that the EPA incorrectly stated that there isn’t any drinking water wells located within the one-quarter mile area of review. The commissioners stated that residents have provided information showing 17 water sources in the one-quarter mile area of review and the permit application included a map showing 14 private drinking water sources.
Residents, the commissioners stated, requested the area of review to be extended due to the five Oriskany gas wells outside the quarter-mile area of review and all of the private drinking water sources. Resident Darlene Marshall provided the EPA with a list of water sources in a one-mile area and addressed both of the aforementioned concerns.
The commissioners stated that at the public hearing, resident Rick Atkinson provided a zone of endangering influence calculation, demonstrating that the assumed non-trans missive faults would change the zone of endangering influence and make it larger. Atkinson, the commissioners stated, wanted the area of review extended as a result.
The commissioners stated that both Marshall and Atkinson wanted the Carlson gas well considered, as it’s in the same formation as the injection zone. The Carlson gas well, the commissioners stated, is a source of concern for neighbors because the casing is suspect due to fumes it emits.
The commissioners found it questionable that a fault block exists since it isn’t shown on the permit application map. Another inaccurate statement, the commissioners stated, involved showing faults in relation to the gas wells, which mentioned plugged wells not producing outside the fault block.
According to the commissioners’ letter, Atkinson’s property well was never plugged and has been used until recently. His property well is located on the permit application maps on the other side of a fault. Since it’s has neither been proven a fault block nor explained as to the depths of the fault, it may or may not be transferring fluids.
“In conclusion, we would stress our opposition to the EPA’s approval of this permit and ask for a comprehensive review of any appeals submitted regarding this permit,” the commissioners stated.
