On October 29, the Department of Environmental Protection announced it has executed a Consent Order and Agreement with Equitrans Midstream Corporation for violations regarding the operator’s Swarts gas storage reservoir located in Greene County.
Gas storage fields are comprised of subsurface geological formations into which natural gas is pumped and stored under pressure.
“Throughout modern history, Greene County has been an epicenter of all manner of energy development, and that activity means that operators’ adherence to Pennsylvania’s laws and regulations is imperative from both an environmental and safety perspective,” said DEP Secretary Patrick McDonnell.
The COA provides a schedule for Equitrans to complete the location and identification of oil and gas wells, and to submit a verified statement for the entire Swarts Field and protective area that is overlain by the Harvey Mine’s B District. The mine is operated by Consol Coal Resources, L.P. (CONSOL).
Equitrans must also perform necessary well plugging or reconditioning. Importantly, the COA details specific information that should be provided in a verified statement.
This critical provision in Pennsylvania’s laws ensures that gas storage operators have used every reasonable mechanism to identify wells and address them in advance of underground coal mining, thus ensuring miner and public safety.
DEP intends to use this template in a forthcoming technical guidance document for all storage reservoir operators with assets in areas of underground coal mining. Equitrans has also agreed to pay a $650,000 civil penalty to DEP.
The Oil and Gas Act of 2012 outlines obligations pertaining to storage field operators and contains specific provisions that apply to operators whose storage fields are proximal to an operating underground coal mine.
Under the Oil and Gas Act, storage field operators are required to locate and, in certain instances, plug or recondition wells, that have been or may have been drilled into or through the storage stratum to prevent the escape of gas from the storage field.
These wells may include storage (withdrawal/injection), observation, production, plugged, orphan, and/or abandoned wells, many of which may predate permitting and/or registration with DEP and may be unknown to the department.
These requirements protect the public in general, and specifically protect coal mine workers. A release of storage field gas into a mine would pose a risk of asphyxiation or explosion in the mine.
A portion of the Harvey Mine overlies Equitrans’ Swarts Field and Hunter’s Cave storage reservoir and the 2,000-foot protective boundary around each field.
As early as June 2013, Equitrans was made aware by CONSOL that the mine operator planned or had conducted coal extraction activities in the Pittsburgh Coal Seam within 2,000 feet of the Swarts Field.
Equitrans was obligated to submit a verified statement that includes maps, an explanation of the operator’s due diligence in complying with state law, any additional efforts the operator is making and intends to make to locate wells, and any wells it intends to plug or recondition.
While Equitrans provided information to DEP at various times since passage of the Oil and Gas Act, it did not provide a verified statement pursuant to the Oil & Gas Act.
On December 26, 2018, DEP issued an administrative order to Equitrans demanding the required information regarding wells that have or may have been drilled into the Swarts Field’s storage horizon and other information. The order would have required Equitrans to depressurize the field if the requested information was not provided.
Equitrans appealed the order to the Environmental Hearing Board on January 25, 2019. Equitrans has agreed to withdraw its appeal following the execution of this COA.
DEP took steps, some directly under provisions in the Oil & Gas Act, to ensure that Equitrans and CONSOL would gather and to submit to DEP information necessary to protect the safety of miners.
In March 2019, DEP approved a mining plan to protect miners if pressures in the storage field increased above 250 pounds per square inch (psi). CONSOL agreed to notify and train its personnel and implement additional safety precautions for the miners.
CONSOL began active development mining of the Harvey Mine’s 5B panel that overlies the Swarts Field on March 2019.
Since issuance of the order, Equitrans and CONSOL submitted information, jointly and separately, at various times to DEP. However, that information did not fully comply with the order or the Oil & Gas Act.
Equitrans has not completed the final identification and location of wells that may have been drilled into the area overlying the Swarts Field outside the panel currently being mined (5B).
On October 18, 2019, Equitrans submitted a verified statement covering the portion of the Swarts Field overlying the Harvey Mine’s 5B panel and surrounding area, the initial area of mining in the Harvey Mine’s B District.
Click Here for a copy of the Consent Order and Agreement. Click Here for a DEP fact sheet on Underground Gas Storage Fields In Pennsylvania.
Questions should be directed to Lauren Fraley, DEP Southwest Regional Office, by calling 412-442-4203 or send email to: lfraley@pa.gov.
Prior NewsClip:
[Posted: October 29, 2019] www.PaEnvironmentDigest.com
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