Underground Injection Control
(UIC) Program
Karen Johnson, Chief Ground Water &
Enforcement Branch
Philadelphia Regional Office
Presentation Overview
 Overview
of the Underground Injection
Control (UIC) Program
 UIC Program Implementation in PA
 Current Oil and Gas wells in PA
What is the Underground
Injection Control Program?
 The



UIC Program:
Protects Underground Sources of Drinking
Water (USDWs) from Contamination
Regulates Subsurface Emplacement of Fluids
into a bored, drilled or driven “Well”
Implemented by EPA, States and Tribes
UIC Well Classification





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Class I – Industrial and Municipal (including
hazardous waste)
Class II – Oil and Gas (including enhanced
recovery and brine disposal)
Class III – Mining related (e.g. salt solution
mining)
Class IV – Shallow hazardous waste injection,
banned
Class V – All other wells
Class VI- Carbon Sequestration wells
Current Active PA Inventory
 Class
I- 0
 Class IIR (enhanced recovery) - 1,500+
 Class IID (brine disposal) - 11
 Class III- 0
 Class IV- All closed
 Class V- 14,000+
 Class VI- none proposed
Key Definitions - USDW

Underground Source of Drinking Water (USDW):




Either Contains less than 10,000 mg/L Total Dissolved Solids
(TDS) or
An Aquifer or Portion of an Aquifer Which Supplies Any Public
Water System or Contains a Quantity of Ground Water Sufficient
to Supply a Public Water System, and
Is Not an Exempted Aquifer
UIC Program prohibits the injection of fluids or the
movement of fluids that may pose a “potential
endangerment” to a USDW. Endangerment is when any
contaminant may exceed drinking water standards.
And
Useable Quality Water (3,000-10,000 TDS)
Brine - Salt Water (>10,000 TDS)
USDW
Underground Source of Drinking Water Includes:
Drinkable Quality Water (<3,000 TDS)
BRINE
DRY
WET - AQUIFER
WATER TABLE
The UIC Program does not include:

Hydraulic fracturing is specifically exempted
from the SDWA and the UIC program unless
diesel is used

Storage of natural gas, must be liquid

Does not regulate surface features (buildings,
roads, well placement, tanks, ponds, pipelines,
etc. associated with the injection wells.
Energy Policy Act 2005
Congress revisited SDWA definition of “underground injection” and
exempted hydraulic fracturing except when diesel fuel is used (Section
1421(d)(1)(B)):
In February 2014 EPA released an interpretive memorandum and Technical
Guidance containing recommendations for EPA permit writers to consider in
implementing these UIC Class II requirements
Purpose of the memorandum and technical guidance:
-To explain that any owner or operator who injects diesel fuels in HF for oil or
gas extraction must obtain a UIC Class II permit before injection;
-To explain the agency’s interpretation of the SDWA statutory term “diesel
fuels” for permitting purposes; and,
-To describe existing UIC Class II program requirements for permitting
underground injection of diesel fuels in HF and to provide recommendations
for the EPA’s permit writers to consider in implementing these requirements
to ensure protection of underground sources of drinking water (USDWs).
UIC Program History in PA

UIC program regulations promulgated in July,
1980
 EPA began direct implementation of
Pennsylvania program June,1985
 PA Specific technical requirements 40
C.F.R.147.1950- 1955 include:


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Aquifer exemptions
Injection pressure limitation
Casing and cementing criteria
EPA UIC Permitting
 Major
Permitting requirements:
Defining Area of Review/Zone of Endangering Influence
- Injection well construction (Depth of surface casing
critical)
- Well operation (Maximum Injection Pressure and
Injection Rates)
- Mechanical integrity testing
- Plugging and abandonment
- Financial Responsibility
-
Area of Review
Well Construction
Step Testing and Fracture Logs
Permit Issuance Process

No application fee
 One stop shopping: Permit issued for
construction, operation, monitoring and reporting
 Processing generally takes between 3-6 months
for review and public notice
 Public notification and opportunity for public
hearing required, if a hearing is held and/or
permit appealed, processes is extended
Current Inventory of Brine Disposal Wells in
PA
Surface Injection
Pressure
Injection
Volume
BBLs/M
Facility ID
Facility Name
County
Injection Formation
PAS2D041BBEA
Columbia Gas
Beaver
Huntersville/Oriskany
1300
21,000
PAS2D205BCLE
EXCO Resources PA
Clearfield
Oriskany
3240
27,000
PAS2D010BVEN
Stonehaven Energy
Venango
Speechley
1358
4,500
PAS2D561BSOM
Cottonwood
Somerset
Oriskany
3250
27,000
PAS2D902BCLE
EXCO Resources PA
Clearfield
Oriskany
1450
4200
PAS2D912BSOM
CNX Gas Company
Somerset
Huntersville/Oriskany
3218
30,000
PAS2D215BWAR
PAS2D216BWAR
PAS2D217BWAR
Bear Lake Properties
Bear Lake Properties
Bear Lake Properties
Warren
Warren
Warren
Medina
Medina
Medina
1726
1696
30,000
30,000
30,000
PAS2D025BELK
PAS2D013BIND
Seneca Resources
PA General Energy
Elk
Indiana
Elk 3 Sand
Huntersville Chert
1416
2933
45,000
30,000
Proposed: 5 additional
permits in review
Disposal Horizons
 Wells
typically converted from
unproductive or depleted gas production
wells
 Little
research on other potential saline
disposal zones
 Most
reservoir data obtained from past
drilling history or injectivity testing
Major Issues for Future
Development
1. Water Management
-Drilling and Well Development
-Reuse
-Disposal
2. Research
-Other Saline Reservoirs
-Reservoir Capacity
UIC Increased Enforcement Activity
 Three
cases of Unpermitted Brine
Disposal



Swamp Angel
• Unauthorized disposal into old well and injection outside the
scope of approved injectivity test.
• Found operators guilty under criminal case, Administrative
Penalty case for penalty and plugging of unpermitted well
Titusville Oil
• Unpermitted brine disposal. Administrative Penalty for $10K
Tunnelton Liquids
• NPDES permitted discharge of brine with AMD, potentially
endangering to USDW and without UIC authorization. Facility
closed
Questions?