EPA Issues Proposed Morris Run Well Order
Washington PA Observer Reporter
6 August 2010
By Bob Niedbala, Staff writer
niedbala@observer-reporter.com
The U.S. Environmental Protection Agency has proposed a final
administrative order for the CNX Gas Co.'s Morris Run injection well in
Wayne Township that will include the plugging of the well.
EPA issued notice of the proposed order Wednesday for alleged
violations in the operation of the well originally cited in a proposed
order issued last August.
Both orders call for the company to pay a $157,500 penalty for
allegedly failing to adequately staff and secure the well site, monitor
the well's cumulative volume and report noncompliance with its permit.
The final order also calls for the company to plug the well within 60
days of its effective date.
A comment period on the proposed order runs until Sept. 20, and if no
significant issues are raised, the final order should be signed shortly
afterward, said Karen Johnson, chief of groundwater and enforcement for
EPA's Region 3.
CNX received a permit for the injection well at the Morris Run Mine
Shaft of Consol Energy's closed Blacksville No. 1 Mine in 2005 for
disposal of waste water, or brine, from the company's coal bed methane
wells.
The company was permitted to dispose up to 150,000 barrels of coal bed
methane waste water a month in the well, a mine pool more than 700 feet
below surface.
The well site was to be locked and the tanker truck tap-in to the well
contained in a locked valve box. The permit also required the site be
adequately staffed and the cumulative volume of the waste water
continuously monitored.
According to the proposed order:
* Between Dec. 23, 2006, and Aug. 20, 2008, no flow meter was
operational at the well to measure cumulative volume. During an
inspection Aug. 7, 2008, EPA found the gate open, no lock on the valves
at the truck offloading area and no flow meter in use. The wire from
the previous flow meter had been cut and no CNX staff or operator was
present at the site, EPA said.
* Between Dec. 23, 2006, and Aug. 20, 2008, the only method of
recording the volume of fluid discharged at the well was a truck log
book kept at the site. Since Sept. 1, 2005, not all truck drivers that
discharged at the site recorded or accurately recorded their discharge
in the log book.
* Company records of sampling results of fluids deposited into well
indicate that between about September 2007 and March 2009 at least 100
truckloads of fluid were disposed of at the site with total dissolved
solid (TDS) levels that "varied significantly" from expected TDS levels
provided in the permit application and eight truckloads of water
contained E coli bacteria, indicating sewage.
The permit allowed the company to dispose of water containing up to
25,000 milligrams per liter TDS. The order also notes CNX used contract
haulers to transport water to the well and some of those hauler also
hauled septic waste.
The injection well became an issue following the fish kill in Dunkard
Creek last September. Questions were raised about what might have been
dumped into the well and whether that water might have migrated
underground into the nearby Blacksville No. 2 Mine.
Investigators determined a toxic bloom of golden algae led to the fish
kill. They also said high levels of TDS originating from the
Blacksville No. 2 mine discharge created conditions for the algae bloom.
EPA, however, doesn't believe there was any connection between the
injection well and fish kill, Johnson said. Chemical characteristics of
the waste water disposed of in the well was different from that found
in the creek, she said.
Tests of water in the well before injection began and after it ended
also showed little change in the water's chemical makeup, she said. The
estimated amount of waste water injected into the well, in addition,
was very small in relation to the volume of water in the mine pool.
Joe Cerenzia, CNX spokesman, said the company corrected problems at the
well when it learned of them in 2008 and later voluntarily ceased
disposed of waste water there.
The company also made the decision to plug the well, he said. The
execution of the final order, Cerenzia said, should bring the matter to
a close.