“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]
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[Posted: March 13, 2023] PA Environment Digest
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