1. EPA’s Underground Injection Control Program
Brine Disposal Well Regulation in Pennsylvania
Stephen Platt, UIC National Expert

2. UIC Program History
Regulations authorized under the Safe Drinking Water Act
National concerns regarding unregulated injection
Protects USDWs from all types of injection
UIC program regulations promulgated in July, 1980
EPA begins direct implementation of the Pennsylvania program June, 1985

3. UIC Well Classification
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

4. EPA UIC Permitting
Mandate to protect underground sources of drinking water (USDWs)
USDWS defined as having less than 10,000 mg/l Total Dissolved Solids
Current and future use protected
Permitting is performance based
Hydraulic fracturing not regulated under UIC Program

5. EPA UIC Permitting (cont.)
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 critical)
Mechanical integrity testing
Plugging and abandonment
Financial Responsibility

6. Area of Review

8. Permit Issuance Process
No application fee
One stop shopping: Permit issued for construction, operation, monitoring and reporting
Processing generally takes between 3-6 months
Public notification and opportunity for public hearing required.

9. Brine Disposal in Pennsylvania
Facility Name County Injection Formation Injection Pressure Injection Volume (Bbls/M)
Columbia Gas Beaver Huntersville/Oriskany ,000
EXCO-North Coast Clearfield Oriskany
CNX Gas Greene Mine Void ,000
Range Resources* Erie Gatesburg ,000
XTO Energy # Indiana Balltown
Cottonwood Somerset Oriskany ,000
EXCO-North Coast Clearfield Oriskany
Dominion Somerset Huntersville/Oriskany ,000
*Only commercial facility
# Recently Plugged

10. Disposal Horizons
Wells typically converted from unproductive or depleted gas production wells
More research on other potential saline disposal zones needed
Most reservoir data obtained from past drilling history or injectivity testing

11. Injectivity Testing Requirements
Letter of Authorization from EPA
Short term testing (no more than 30 days)
Volume limitation imposed
Maximum injection pressure limitation imposed
Well must be protective of USDWs
Continuous monitoring required
PADEP regional offices notified

12. Injectivity Testing (cont.)
As of mid-August, 13 injectivity testing applications approved
Approximately half have been completed
Requests concentrated in the Northeastern and Southwestern, PA

13. Questions?
Steve Platt (215)
Dave Rectenwald (814)