No Injection Wells for Shale Gas Waste Water

The US EPA is accepting public comment on the proposal to issue final UIC permits for injection wells for shale gas wastewater. Creating injection wells for shale gas waste water disposal threatens fresh water aquifers, and surface water from migration of the waste through abandoned, unplugged wells in the area. Injection wells in other areas of the country have caused earthquakes and their use has been recently banned.

Tell the EPA not to issue injection well permits for waste water in Pennsylvania!

Subject:

Your Letter:

EPA Region III
Ground Water and Enforcement Branch
Office of Drinking Water and Source Water Protection
1650 Arch Street 
Philadelphia, Pennsylvania 19103

Via Electronic Mail

Attn: Stephen Platt

Re:  Public Comment on UIC Permit Nos.: PAS2D215BWAR and PAS2D216BWAR, Bear Lakes Properties, LLC

Dear EPA Regional Administrator:

I submit the following comments and incorporates by reference the comments submitted by the Pennsylvania Chapter of the Sierra Club, The Brokenstraw Watershed Council, and the Allegheny Defense Project on the proposed underground injection wells planned for Warren County, PA. Drilling injection wells for hazardous substances is a very bad idea in the region. The substances in waste-water from unconventional shale gas drilling (as well as from other conventional types of drilling) contain carcinogens, high concentrations of sodium, chloride, bromide, arsenic, barium, other heavy metals, and radionuclides (Radium 226).

Pennsylvania’s geology and the legacy of the Industrial Revolution in PA have made injection wells in our state utterly high risk. We have geologic fissures and fissures created by explosions and hydraulic fracturing.  Pennsylvania has “swiss cheese” geologic formations from abandoned, out of production, existing, and new oil and gas wells and hydraulic fracturing. Pennsylvania also has abandoned and existing coal mines, which allow migration of pollutants into the aquifers.

Our aquifers are in danger of being contaminated.

Therefore the proposed Bear Lakes Properties, LLC injection wells pose an unacceptable, eminent danger to drinking water supplies and cannot be permitted until a major regional survey of all out of production and abandoned wells in the region are located, GPS mapped, and properly plugged.  That will require an enormous financial commitment from the EPA, PA DEP and permittee Bear Lakes Properties LLC,  intensive research of historic documents, extensive field work, identification of mineral right ownership to require the owners to pay for the plugging of out of production, abandoned and historically lost wells prior to any permits being approved.

This EPA permitting scheme for injection wells in the oil and gas patch is a half-baked attempt permit a potential environmental disaster, which will pollute drinking water aquifers - the public's resource - for clean, safe drinking water.

Because of the industrial legacy of drilling in the region proposed for the Bittinger #1 and Bittinger #4, it is inappropriate to use the area for injection wells. Further, there is a necessity to survey for abandoned oil and gas wells in the region. Due to the deterioration or lack of casings in abandoned wells, and the failure of the PA DEP to survey locate and properly plug these abandoned wells, there is a free interchange of gases, liquids, and minerals between geologic layers.

Bear Lakes Properties has not submitted a detailed examination of the geology of the site.

The monitoring wells are inadequate.

The applicant states that 3 monitoring wells are being proposed. One is Bittinger 4, which is also being proposed as an injection well by the applicant.  In essence, two monitoring wells are being proposed.  There is no indication whether these wells are down gradient of Bittinger 1 and Bittinger 4.  At least 3 monitoring wells are needed to establish groundwater gradient; this should be known prior to any disposal activities are initiated.

Bear Lakes Properties has not surveyed drinking water wells in New York State and the data used for local water wells is outdated.

Bear Lakes Properties’ consultant reports on underground sources of drinking water covers only wells in Pennsylvania.  No references were cited for underground sources of drinking water in adjacent New York State areas, within the one-mile radius of the well sites.  In particular, the Bittinger 4 documents do not show New York drinking water wells within ¼ mile of the well.

Bear Lakes Properties’ well casing standards do not meet current Pennsylvania Department of Environmental Protection requirements.

Surface casing 50’ below fresh water is inadequate to protect drinking water supplies.

Mechanical integrity tests must be conducted quarterly.

BLP has not demonstrated the financial resources to remedy major environmental contamination, should well failure occur.

Injection wells in other areas of the country have caused earthquakes and their use has been recently banned.

For all these reasons related to the protection of safe drinking water, EPA should not issue these permits.

Respectfully submitted,

Steve Platt

EPA
Ground Water and Enforcement Branch (3WP22), Office of Drinking
U.S. EPA Region III, 1650 Arch Street
Philadelphia, PA 19103
US