DEP To Submit Letter Of Intent To EPA As Early As This Week For Primacy To Regulate Underground Injection Wells
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On March 13, Kurt Klapkowski, Acting Deputy for Oil and Gas Management, told the Oil and Gas Technical Advisory Board, DEP expects to submit a letter of intent as early as this week to the U.S. Environmental Protection Agency to apply for primary to regulate underground injection wells.

“It's not an easy process or straightforward process, but we're probably going to be submitting a letter of intent to the EPA this week indicating that we are interested in pursuing that primacy application,” said Klapkowski.

“We're looking very hard right now at a primacy application, at least for the Class VI wells, if not for all injection control wells in the Commonwealth,” said Klapkowski.  “The other big classes that we see are the Class 2D, which are disposal of oil and gas waste wells and the Class 2R, which are oil and gas recovery wells.

“Then the third category or the fourth category I guess that you would say is under the injection control program that we're thinking about are Class V wells, which are a broad category, but would include geothermal wells.

‘“We've had a few inquiries or proposals to try to convert some old abandoned oil and gas wells into geothermal wells as part of the [federal Bipartisan] Infrastructure Act. Attention is being paid to that issue in Pennsylvania,” said Klapkowski.

“There is some funding to secure Class VI primacy for states in the Infrastructure Act. The EPA has about $50 million that they have available to assist states to walk through that process,” explained Klapkowski.

Klapkowski pointed out EPA has primary authority now to regulate underground injection wells, but DEP also requires a permit since they are considered conventional wells under the state’s Oil and Gas Act.

He said if DEP achieves primacy, it would eliminate this double permitting and the ability to appeal permits at both the federal and state levels.

Klapkowski’s comments came after a presentation by Kristin Carter, DCNR Assistant State Geologist, on carbon capture and hydrogen storage and development before the Advisory Board.

Klapkowski has said in previous discussions it would be important for Pennsylvania to obtain primary because of the potential for geologic sequestration of carbon dioxide and for potential storage of hydrogen or combinations of methane and hydrogen.

Carter said, “The point is that Pennsylvania's subsurface is going to be used for storage, it's not going away. If anything, storage applications are going to be more common than we see now.”

She noted hydrogen storage could be related to one of the three pending hydrogen hub applications in Western Pennsylvania and West Virginia.

Click Here for Carter’s presentation.

For more information and available handouts, visit DEP’s Oil and Gas Technical Advisory Board.  Questions should be directed to Todd Wallace twallace@pa.gov or 717-783-6395.

Business Groups Support Injection Well Application

On March 15, the Pennsylvania Chamber of Business and Industry joined seven business groups representing a diverse cross-section of industry in Pennsylvania, West Virginia, Illinois, Texas, and New Mexico in sending a letter to the U.S. Environmental Protection Agency calling for the expeditious approval of state primacy applications for Class VI injection wells.  Read more here.

(Photo: Injection well facility, Plum Borough, Allegheny County.)

Related Articles - Injection Wells:

-- PA Business Groups Urge EPA To Speed Up Approval Of State Primacy Applications For Injection Well Regulation [PaEN]

-- PA Environmental Council, Environmental Defense Fund Express Concerns About Legislation Requiring DEP To Apply For Injection Well Primary For Carbon Dioxide Storage  [PaEN]

PA Oil & Gas Public Notice Dashboards:

-- Pennsylvania Oil & Gas Weekly Compliance Dashboard - March 11 to 17; Fracking 2 Wells Interfered With Another Shale Gas Well In Westmoreland County  [PaEN]

-- PA Oil & Gas Industrial Facilities: Permit Notices/Opportunities To Comment - March 18 [PaEN]

-- DEP Posts 62 Pages Of Permit-Related Notices In March 18 PA Bulletin  [PaEN]

PA Oil & Gas Compliance Reports

-- Feature: 60 Years Of Fracking, 20 Years Of Shale Gas: Pennsylvania’s Oil & Gas Industrial Infrastructure Is Hiding In Plain Sight [PaEN]

-- Conventional Oil & Gas Well Owners Failed To File Annual Production/Waste Generation Reports For 61,655 Wells; Attorney General Continues Investigation Of Road Dumping Wastewater  [PaEN]

-- DEP Issued 754 Notices Of Violation For Defective Oil & Gas Well Casing, Cementing, The Fundamental Protection Needed To Prevent Gas Migration, Groundwater & Air Contamination, Explosions  [PaEN]

-- DEP Report Finds: Conventional Oil & Gas Drillers Routinely Abandon Wells; Fail To Report How Millions Of Gallons Of Waste Is Disposed; And Non-Compliance Is An ‘Acceptable Norm’  [PaEN]

-- DEP 2021 Oil & Gas Program Annual Report Shows Conventional Oil & Gas Operators Received A Record 610 Notices Of Violation For Abandoning Wells Without Plugging Them  [PaEN]

-- PA Oil & Gas Industry Has Record Year: Cost, Criminal Convictions Up; $3.1 Million In Penalties Collected; Record Number Of Violations Issued; Major Compliance Issues Uncovered; Evidence Of Health Impacts Mounts  [PaEN]

Related Articles This Week:

-- PA Capital-Star Guest Essay: Why Your Electric/Natural Gas Utility Bill Has Gone Up And What You Can Do About It - By Patrick Cicero, Consumer Advocate Of PA, Terrance Fitzpatrick, Energy Assn. Of PA [Natural Gas Prices Tripled]

-- Wall Street Journal: Why Natural Gas Bills Are Going Crazy, With No End In Sight

-- Marcellus Drilling News: New Fortress Energy Reapplying For Wyalusing LNG Natural Gas Plant Permits In Bradford County  [PaEN]

-- U.S. DOT Misses Deadline To Suspend Rule Allowing Shipping LNG Natural Gas By Rail, Including A Proposal In PA  [PaEN]

-- Federal Court Rules Challenge To DEP Air Quality Permit For Adelphia Natural Gas Pipeline' Quakertown Compressor Station May Go Forward  [PaEN]

-- Environmental Groups Appeal DEP Permits For Transco Regional Energy Access Expansion Natural Gas Pipeline In Luzerne, Monroe Counties  [PaEN]

-- DEP To Submit Letter Of Intent To EPA As Early As This Week For Primacy To Regulate Underground Injection Wells  [PaEN]

-- PA Business Groups Urge EPA To Speed Up Approval Of State Primacy Applications For Injection Well Regulation [PaEN]

-- Equitrans/DEP In Discussions To Resolve EHB Appeal Of DEP’s Order To Fix Cambria County Underground Natural Gas Storage Area Conventional Access Wells  [PaEN]

-- Shell Petrochemical Plant Had 3-Hour Emergency Flaring Event To Burn Off Flammable Gases In Beaver County  [PaEN]

-- Commonwealth Court Rules PUC Is ‘Obligated’ To Conduct An Environmental Review Of Projects By The Environmental Rights Amendment In Case Involving A PECO Natural Gas Pumping Station In Delaware County  [PaEN]

-- Environmental Health Project: 75% Of Hazardous Waste Accepted At MAX Environmental Yukon Facility In Westmoreland County Comes From Shale Gas Industry; Sludge Proposed To Be Delisted As Hazardous Waste  [PaEN]

-- Marcellus Drilling News/Wellsboro Gazette: Pine Creek Headwaters Protection Group Objects To Location Of Mt. Nessmuk Shale Gas Drill Pad In Tioga State Forest  [PaEN]

-- Susquehanna River Basin Commission Approves 6 Natural Gas Drilling Water Withdrawal Renewals For 7.1 Million Gallons/Day  [PaEN]

-- Environmental Defense Fund, Clean Air Council, Environmental Health Project Sponsor Ad Campaign To Finalize Strong EPA Oil & Gas Methane Emission Limits To Protect PA's Health & Climate  [PaEN]

-- March 29 Southeastern PA Town Hall Meeting In Chester County To Focus On Health, Environmental Impacts Of Fossil Fuels  [PaEN]

-- Pennsylvania's Clean Energy Economy Grew To Over 92,700 Jobs Since COVID Economic Crisis  [PaEN]

[Posted: March 13, 2023]


3/20/2023

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