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of their practical experience over the theoreticians who make wild statements that it is impossible to define pool boundaries.

Then there is the objection that there are many, old abandoned uncharted wells. Here again in the development of a storage pool nothing is left to chance. The actual job of finding all wells in a depleted field under consideration for gas storage may be difficult, but we believe sincerely that it would be rash and imprudent on our part to invest in a storage project if all the wells in the pool were not located properly. Various methods are employed ranging from the use of modern technical apparatus to the accumulation of large amounts of information from old literature and contacting long-time residents of the area. Even in cases where all surface evidence of abandoned wells has disappeared all such wells can be and are discovered and located before starting underground storage operations. With reference to the possibility of either horizontal or vertical leakage of gas into coal mines from storage fields alluded to in the testimony of several of the coal witnesses, I can only reiterate that we are just as vitally concerned with the safe operation of a storage reservoir as any coal operator. Now the only possibility of leakage from a storage pool is from or through well holes, and if the wells in the storage pool are properly plugged or reconditioned, there is very little chance of any hazard being created to the coal mine. However, the coal operator has certain responsibilities to fulfill and his failure to leave sufficient support for the protection of the well or his negligence in cutting into the well are certainly not attributable to the gas company. These two hazards are not by any means limited to storage operations but apply with equal force to active production wells. These potential hazards have been with our industry as long as there has been drilling activity in any area in which both industries have operated together. They are not new potential hazards created by storage.

While on this subject, I would like to mention what I believe to be a common misstatement by coal operators. They are always talking about our man-created conditions in the use of the substrata. I think it should be recognized that coal mining is equally a man-created use of the substrata.

One other objection made by the coal industry to this proposed amendment concerns the operation of storage pools at high pressures. We have recognized from the start that in any storage operation, so long as you operate your pool at pressures not exceeding the original rock pressure on the field that there is absolutely no additional hazard or for that matter any hazard to the coal measure. You are in effect merely restoring to the interstices in the storage sandstone the volume of natural gas that was stored there in its original state. The coal representatives have been unanimous in opposing Federal legislation on the subject under consideration and since their appearance before your committee on April 2, 1954, have submitted a substitute proposal which as I read it would make it impossible to condemn substrata for the storage of gas anywhere in the world. If that is too literal a translation, their proposed amendment would certainly prevent us from exercising the power in the States in which we operate.

There is no objection on our part to reasonable restrictions on the exercise of the power of eminent domain, short of those which would in effect negate the power. Likewise we do not see any objection to the Federal Government conferring this power by amendment to the Federal Natural Gas Act. Such a move seems consistent with the spirit of that act, which as originally passed, was intended to fill a gap not covered by State law. The underground storage of gas is just as much a public necessity as the transportation of gas in interstate commerce. That necessity has been recognized by the legislatures of Kentucky, West Virginia, Michigan, Oklahoma, Kansas, Illinois, and Iowa. Congress has recognized the public purpose of transportation of natural gas in interstate commerce; it should now complete the job by granting the power of eminent domain for underground storage of natural gas.

Yours very truly,

D. B. BEECHER,
Vice President and General Manager.

CARNEGIE NATURAL GAS Co.
Pittsburgh, Pa., June 1, 1953.

To the Chairman and Members of the Committee on Mines and Mining of the House of Representatives, Harrisburg, Pa.

GENTLEMEN: Your committee held a hearing on May 26, 1953, on House bill No. 1240 relating to the underground storage of gas. One of the witnesses representing the coal industry who made a statement in support of the bill was Charles B. Baton, president, Greensburg-Connellsville Coal & Coke Co., which operates the Hubbard mine located in Allegheny County, Pa.

In the course of his statement Mr. Baton made remarks which, in the absence of a full explanation, amount to a contention that the explosion in the Hubbard mine on January 2, 1939, was occasioned by the underground storage of gas by the Carnegie Natural Gas Co.

However, the facts are to the contrary. The aforementioned theory of Mr. Baton was thoroughly examined in 1939 by two independent sources, to wit: the coroner's jury of Allegheny County holding an inquisition upon the death of two employees killed in the explosion, and a special commission to investigate the explosion appointed by the secretary of the Pennsylvania Department of Mines. I enclose copies of the reports of these two investigations so that your committee may have full knowledge of the facts. It is interesting to note that the coroner's jury included among its members Mr. L. E. Young, who is an experienced consulting mining engineer.

For your further information in studying these reports, please keep in mind that we store only byproduct gas in the gas-storage sands a considerable distance beneath the Hubbard mine; that we have never stored natural gas there; that byproduct gas contains hydrogen while natural gas does not contain hydrogen; and that methane gas is frequently found in coal mines.

Yours very truly,

STATE OF PENNSYLVANIA,

Allegheny County, 88:

D. S. KEENAN, President.

An inquisition, indented, taken at McKeesport and First Ward, Pittsburgh, Pa., in the County of Allegheny, on the 29th January and 23d day of February, A. D. 1939, before me, William D. McClelland, Coroner of the County aforesaid, upon the view of the body of Joseph Bertozzi then and there lying dead, upon the oath and solemn affirmations of six good and lawful men of the County aforesaid who, being sworn and affirmed and charged to inquire, on the part of the Commonwealth, when, where and how, and after what manner, the said Joseph Bertozzi came to his death do say, upon their oath and affirmations aforesaid that the said Joseph Bertozzi, age 41 years, 1 month, 2 days; nationality, American; Social Relation, Married; Occupation, Coal Miner; and residing at 4218 Walnut Street, McKeesport, Pa., came to his death at the McKeesport Hospital, McKeesport, Pa. Sunday, January 29, 1939 at 12:01 a. m. from bronchopneumonia following burns of face and ears received at the Tube City Collieries Co., Versailles Township, Pa., Monday, January 2, 1939 at 7:25 a. m. due to an explosion in mine.

And from the evidence and postmortem examination made the jury finds death was due to the above cause and the same was accidental, and that the direct cause of death of the above-named deceased was an explosion of methane gas, having become ignited by an arc from the trolley wheel of a locomotive, and that the explosion was due to the erection of a door in the main entry, thereby permitting an accumulation of explosive gas.

We, the jury, condemn the erection of this door without having secured the approval and consent of the State Mine Inspector. We, the jury, also condemn the practice of permitting men to enter gaseous mines on any shift, either on working days or idle days, without inspection and reports of fire bosses, as specified in Article 5, Sections 1 and 2, of the law, and we further recommend the strict enforcement of formal opinion No. 249 dated April 20, 1938, from the Department of Justice to the Department of Mines, interpreting Article 5, Section 1, relating to the examination of gaseous mines, before each shift. Therefore, the jury recommends that the authorized State officials shall take proper

action against any individual or individuals responsible for the violation of the mining laws above mentioned.

And so the Jurors aforesaid, upon their oaths and affirmations as aforesaid, say that the aforesaid Joseph Bertozzi for the cause aforesaid in the manner and form aforesaid, came to his death, and not otherwise.

In witness whereof, as well as of the aforesaid Coroner, we, the Jurors, have hereunto put our hands and seals, on the day and year and the place above mentioned.

[SEAL]

J. S. ALDISERT, Deputy Coroner.
FERD J. LEY.

E. E. McCONNELL

ED. E. WHITE.

W. H. KIMBERLAND.

JOHN MCCARTNEY.
L. E. YOUNG.

STATE OF PENNSYLVANIA,

Allegheny County, 88:

I. William D. McClelland, Coroner of Allegheny County, in the State aforesaid, do hereby certify that the above and foregoing is a true and correct copy of the Verdict in the matter of inquest held on the body of Joseph Bertozzi entered on the 23d day of February A. D. 1939 records at my office.

Witness my hand and seal, at Pittsburgh, in said County, this 27th day of May, A. D. 1953. WILLIAM D. MCCLELLAND, Coroner.

[SEAL]

STATE OF PENNSYLVANIA,

Allegheny County, 88:

An inquisition, indented, taken at First Ward, Pittsburgh, Pennsylvania, in the County of Allegheny, on the 3d January and 23d day of February, A. D. 1939, before me. P. J. Henney, Coroner of the County aforesaid, upon the view of the body of Norman Lincoln Williams then and there lying dead, upon the oath and solemn affirmations of six good and lawful men of the County aforesaid who, being sworn and affirmed and charged to inquire, on the part of the Commonwealth, when, where and how, and after what manner, the said Norman Lincoln Williams came to his death do say, upon their oath and affirmations aforesaid that the said Norman Lincoln Williams, age 47 years, 1 month, 24 days, Nationality, American: Social Relation, Married: Occupation. Electrician; and residing at Dunbar, Pennsylvania, came to his death at the Tube City Collieries Company, Versailles Township, Pa., on Monday, January 2, 1939, at 7:30 a. m. from fractured skull received at above place on same day and date at 7: 25 a. m., following explosion in mine.

And from the evidence the jury finds death was due to the above cause, and the same was accidental, and that the direct cause of death of the above-named deceased was an explosion of methane gas, having become ignited by an are from the trolley wheel of a locomotive, and that explosion was due to the erection of a door in the main entry, thereby permitting an accumulation of explosive gas. We, the jury, condemn the erection of this door without having secured the approval and consent of the State Mine Inspector. We, the jury, also condemn the practice of permitting men to enter gaseous mines on any shift, either on working days or idle days, without inspection and reports of fire bosses, as specified in Article 5. Sections 1 and 2, of the law, and we further recommend the strict enforcement of Formal Opinion No. 249. dated April 20. 1938, from the Department of Justice to the Department of Mines, interpreting Article 3, Section 1, relating to the examination of gaseous mines before each shift.

Therefore, the jury recommen is that the authorized State officials shall take proper action against any individual or individuals responsible for the violation of the mining laws above mentioned.

And so the Jurors aforesaid, upon their oaths and affirmations as aforesaid, say that the aforesaid Norman Lincoln Williams, for the cause aforesaid, in the manner and form aforesaid, came to his death, and not otherwise.

In witness whereof, as well as of the aforesaid Coroner, we, the Jurors, have hereunto put our hands and seals, on the day and year and the place above mentioned.

[SEAL]

J. S. ALDISERT,

Deputy Coroner.

FERD J. LEY.

E. E. MCCONNELL.

ED E. WHITE.

W. H. KIMBERLAND.
JOHN MCCARTNEY.

L. E. YOUNG.

STATE OF PENNSYLVANIA,

Allegheny County, ss:

I, William D. McClelland, Coroner of Allegheny County, in the State aforesaid, do hereby certify that the above and foregoing is a true and correct copy of the Verdict in the matter of inquest held on the body of Norman Lincoln Williams, entered on the 23d day of February A. D. 1939, records at my office.

Witness my hand and seal, at Pittsburgh, in said County, this 23d day of March A. D. 1953. WILLIAM D. MCCLELLAND, Coroner.

[SEAL]

PITTSBURGH, PA., May 5, 1939.

Mr. JOHN IRA THOMAS,

Secretary, Pennsylvania Department of Mines,

Harrisburg, Pa.

DEAR SIR: The undersigned members of a commission, appointed by you to investigate and report on the matter of storage of byproduct gas in the abandoned gas wells in the McKeesport gas field and ascertain, if possible, as to whether this byproduct gas or natural gas from the abandoned wells was seeping into the Hubbard mine, which is located in the above-named abandoned natural-gas field, hereby report as follows:

The operator of the Hubbard mine of the Tube City Collieries, Inc., was of the opinion that the methane coming from the strata in the entries in the vicinity of the abandoned wells that were being used by the Carnegie Natural Gas Co. was seepage from the wells caused by pressure pumped into the wells and sands by the gas company, and this opinion of the operator of the mine prompted Inspector Powers to suggest a commission to look into the matter.

Upn receipt of your letter appointing the commission, we met at the Bureau of Mines in Pittsburgh and discussed the matter with Messrs. Grove and Forbes, and Mr. Grove was delegated to assist the commission in any way possible.

It was decided to collect samples of the methane issuing from the roof in the mine entries concerned and have samples analyzed to ascertain, if possible, if the analyses would show properties of byproduct gas.

We collected a number of samples from every point that methane was found generating within the suspected area and at other points in the mine and had them analyzed but none of these samples showed any appreciable difference from what could be found in normal mine methane; but this, in our opinion, is not positive proof that the pressure introduced into the gas sands by the Carnegie Natural Gas Co. does not have something to do with the methane generation.

In addition to routine analyses, special apparatus and methods were used to determine the presence of hydrogen in the samples which, if found, would indicate the presence of byproduct gas. However, none of the samples contained hydrogen. Samples were also collected on the outside of the mine from wells of the Carnegie Gas Co. and from four gas wells which are located in the vicinity of where the explosion occurred. Copies of the analyses and comments from the Bureau chemist in charge of the gas laboratory are attached.

The Commission had a meeting with Mr. George Baton and the other officials of the Tube City Collieries, Inc., and got their views on the matter and a map showing the location of all known abandoned gas wells in the area affected.

We then had a meeting with the president of the Carnegie Natural Gas Co., D. S. Keenan, who gave us full cooperation in supplying data on the storage of the byproduct gas in the wells referred to, including amount of gas pumped into the wells, pressures used, the amount of gas drawn from the wells, and dates of same; he also gave permission to take samples of the byproduct gas being pumped into the wells and the exact wells wherein the gas was being pumped in, and the wells from which the gas was being drawn, samples of which are hereto attached. All 17 of the abandoned wells controlled by the Carnegie Natural Gas Co. are properly plugged; the plugging records of these wells are available at the company's office, and were reviewed by the commission. You will find attached to this report a number of enclosures containing pertinent data concerning the abandoned gas wells in the area, with which we are concerned, such as casing, plugging, active and inactive wells, storage and withdrawal of gas, pressures used, and a log of the various strata in this field.

The commission inspected the portion of the mine affected on March 17, and found methane issuing from "slips" in the roof in 2 intake entries in the vicinity of the area of the recent mine explosion; methane had been found issuing from the roof in the other 2 intake entries.

Since the larger portion of the air ventilating the mine enters by way of an intake air shaft in the interior of the mine, it was not necessary to use all of the above-mentioned entries as intakes, and Inspector Powers had recommended that all of these entries, except one which is the haulage road, be made return airways, so that generations of methane in these entries would go directly to the return shaft; and the commission concurred in Mr. Powers' recommendation, which has been carried out.

The suction effect of the exhaust fan on these changed areas tends toward eliminating any possibility of methane generating in the haulage road, or intake airway, and since this change, methane has not been found on the haulage road. Irrespective of the original source of the generation of methane in these entries, we are of the opinion that the changes made in the ventilation have eliminated any dangers, unless something of an unusual nature takes place.

We want to express our thanks to Mr. Keenan, of the Carnegie Natural Gas Co., for his willingness to cooperate in this matter, and to Messrs. Forbes and Grove, of the Bureau of Mines, for their cooperation and assistance; and to the Bureau of Mines Gas Laboratory for the analyses of samples collected in connection with the investigation.

Mr. ROBERT D. L'HEUREUX,

P. J. CALLAGHAN,

Inspector, 26th Bituminous District.

G. S. MCCAA,

Inspector, 29th Bituminous District.
W. P. POWERS,

Inspector, 22d Bituminous District.

CHICAGO, May 20, 1954.

Counsel, Committee on Interstate and Foreign Commerce,

United States Senate, Washington, D. C.

DEAR MR. L'HEUREUX: Following our telephone conversation today, I called Mr. Wolfe, vice president of the Equitable Gas Co. in Pittsburgh, Pa., and understand that he and Mr. Jacob will endeavor to forward to you, by the first of next week, the memoranda relating to the subject matter of our discussions on April 19.

In the interim, and in response to your letter of April 27, 1954, I offer to you for consideration my comments which are submitted in behalf of Natural Gas Storage Co., of Illinois, Natural Gas Pipeline Company of America, and Texas Illinois Natural Gas Pipeline Co., all natural-gas companies within the meaning of the Natural Gas Act, concerning a proposed amendment to the Dirksen bill, S. 525, which has been submitted to you by a group of persons representing certain coal and labor interests and the Bureau of Mines.

Imprihis, there are two serious and fundamental objections to the amendment as so proposed by the coal interests:

I

The amendment, as so proposed, would deprive the Federal Power Commission of its exclusive authority over the underground storage of natural gas, where the same is in interstate commerce, and in fact vest final authority over such

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