CLEARFIELD – The Clearfield County Commissioners have submitted a letter requesting that the federal Environmental Protection Agency (EPA) reconsider its decision to approve a permit to Windfall Oil & Gas Inc. for the construction of a disposal injection well in Brady Township.
The commissioners requested further review of the Underground Injection Control (UIC) permit decision and a denial of the permit based upon evidence submitted by citizens who reside near the proposed well site.
According to the commissioners’ letter, all new Class II wells must be sited to inject into a formation, which is separated from any USDW by a confining zone that is free of known open faults or fractures within the area of review. Also, well injection must not result in the movement of fluids into an underground source of drinking water so as to create a significant risk to the health of persons.
The EPA form for the UIC permit application instructs to submit a topographical map, extending one mile beyond the property boundaries. The EPA response summary is inaccurate in stating that the one-mile topographical map was included and is on file at the library. The library still has the maps and none meet the EPA permit application standards, states the commissioners’ letter.
In the letter, the commissioners also pointed out that the gas well logs, which are found at the library in the permit application, 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 right on the edge of the quarter-mile area of review. “Yet, Windfall stated on the permit application … that ‘no fracture data is available in the area of the confining zones,’” stated the commissioners.
“Proving fractures into the quarter-mile area of review should be sufficient data to provide basis to deny this permit.”
Upon further review of the EPA response summary, the commissioners found it stated that Oriskany wells were further away, locating them at least a half-mile to one-mile from the proposed disposal injection well. This, the commissioners stated, is inaccurate because they are right outside of the quarter-mile area of review, just feet from the line as shown on the maps provided with the permit application.
According to the commissioners’ letter, there is drinking water wells located within the quarter-mile area of review. “Residents state that 17 water sources were identified in the quarter-mile radius of review and the permit application included a map with the EPA permit showing 14 private drinking water sources,” stated the commissioners.
Residents requested that the area of review be expanded due to the Oriskany wells outside of the quarter-mile area of review and the private drinking water sources, stated the commissioners. The commissioners noted that resident Darlene Marshall provided the EPA a list of water sources that are within a one-mile area along with comments on both of these concerns.
Also, during a public hearing, the commissioners stated that resident Rick Atkinson provided a zone of endangering influence calculation. This calculation, the commissioners stated, demonstrated that assumed non-transmissive faults would change the zone of endangering influence and in turn make it larger. For that reason, the commissioners stated that Atkinson wanted an expansion of the area of review.
“Both of these commenters stated that the Carlson gas well should be considered, as it is in the same formation as the injection zone and is a source of concern for neighbors as mentioned in testimony because the casing is suspect due to fumes it emits,” the commissioners stated.
The commissioners also believed it was questionable that a fault block exists, even though the EPA response summary mentions fault blocks, since it isn’t shown on the permit application map. “Another inaccurate statement seems to exist based on the map information showing faults in relation to the gas wells, which mentions plugged wells not producing outside the fault block,” stated the commissioners.
“This is an inaccurate statement because Atkinson’s property well was never plugged and has been used until recently. It is located on the permit application maps on the other side of the fault. Since they didn’t prove a fault block or explain the depths of the faults, they may or may not be transferring fluids. With no way to prove if faults are non-transmissive, we request the permit be denied.”
The commissioners closed, stating they wanted to submit the letter to the EPA in support of Brady Township citizens who are appealing the decision to approve the UIC permit for Windfall’s proposed disposal injection well.