Protecting the Allegheny

ACTION ALERT!

Industry operator targets Clara Township, Potter County, PA as a destination for O&G waste.

The residents of Potter County have been blindsided by news that an oil and gas well operator targeted a depleted oil well in Clara Township as a destination to dispose of O&G wastewater.  Roulette Oil & Gas LLC has applied to the US EPA (United States Environmental Protection Agency) for authorization to convert one of the company’s depleted oil wells into a Class IID Injection well. 

The EPA is currently soliciting comments on a Class II-D draft Underground Injection Well Permit located in Clara Twp., Potter County,Pennsylvania.

PERMIT NUMBER PAS2D050BPOT (visit the links below for more info)

Comments must be received by March 4, 2021.
EPA requests public comment on its findings that the proposed injection activity under the draft permit is unlikely to pose a risk to underground sources of drinking water.  Please email public comments on the draft UIC permit to the attention of: Kevin Rowsey, Source Water & UIC Section, U.S. EPA Region 3

Email: rowsey.kevin@epa.gov

Subject line: PAS2D050BPOT

Read more or see our article on this page to view suggested talking points to include in your comment.

 

The EPA has tentatively scheduled a virtual public hearing on February 2, 2021. An in-person hearing will not take place. The call-in information for the teleconference is listed below:

When: Tuesday February 2, 2021 at 6:00 PM – 8:00 PM Eastern Standard Time!

Call-in Number: (866) 609-3139

There is no need to register in advance for the virtual hearing. You may call 15 minutes in advance of the start time or any time during the session to listen to the hearing. During the hearing, callers will receive instructions on how to join the queue to make a comment. The operator will call on people to deliver their oral comments. The virtual hearing is an audio-only teleconference. Participants who want to supply written or printed materials, should do so via email.

BACKGROUND INFORMATION

See below the details on one of 8 wells operated by Roulette Oil & Gas Co LLC.  These wells are clustered in an area of Hebron and Clara Townships in Potter County, PA and circumstances of all 8 are similar.

Please take the time to visit the links to the DEP database and evaluate the compliance, production and waste reports for all 8.

The issues I will detail surround Permit # 105-20825, Well Name: MATTESON 1 https://www.ahs.dep.pa.gov/eFACTSWeb/searchResults_singleSite.aspx?SiteID=173382 online records indicate the Matteson 1 well has been Inspected 3 times by DEP since the original permit was issued on 8/15/1984.

The last time a DEP inspector set eyes on this well API 105-20825 was on 04/20/1993.

After 27 years of no inspections of the Matteson 1 well the DEP did an armchair inspection, conducted administratively on April 20, 2020.

At the time the inspector explained the reason the inspection was being conducted was for a “change of this wells status from Abandoned to Active.”

On May 8, 2020, eighteen days production reports submitted for the well indicated the well-produced gas during 2019. A previous production report submitted on 2/3/2017 identified this well as plugged.

Over the years this well has changed hands between 4 entities transferred from one to another without being inspected, for twenty seven years. While submitted reports have recorded this well is a gas well, injection well, an inactive well, a plugged well and then back to an ACTIVE PRODUCING WELL on a production report dated 05/08/2020, 18 days after the DEP arm-chair inspection for the purpose of “correcting the status back to active.”

 Voilà with a click of the submit button, the inspector’s note brought these injection wells back into compliance after decades! Just in time for the EPA’s review of the pending injection well application.

In light of all the discrepancies in the DEP records, submitted reports by the (4)operators, and  the lack of adequate regulatory oversight spanning  decades I am requesting the EPA inspect these 8 Roulette Oil & Gas Co., LLC injection wells.  

This seems to be a reasonable request and these need to be inspected whether the pending application is denied or not since the DEP has not demonstrated the ability to do so.

Production reports are available for download from the DEP here: https://www.depgreenport.state.pa.us/ReportExtracts/OG/OilGasWellProdReport

 (Inspection download link: https://www.depgreenport.state.pa.us/eWellDocs/download/DocsZipFile/?P_DER_CODE=9&P_ENTITY_TYPE=2&S=4&P_ID=3021730)

Violation Details for Inspection ID: 684911: https://www.ahs.dep.pa.gov/eFACTSWeb/searchResults_singleViol.aspx?InspectionID=684911

Since this well was spud on 09/28/1984 thirty six years ago, there have been production reports submitted by four operators for only 15 of the past 36 production periods. Of those submitted production reports, records indicate the well status was “abandoned” during the Jan-Dec  1998,1999, 2004,2014, 2015,20016,2017,2018,2019 reporting periods.

Submitted production reports indicate the well was “Active” during the Jan-Dec 2002,2003, 2005,2006,reporting periods and it was reported as “ Inactive” during the Jan-Dec 2010 reporting period.  Records reflect the well only produced for 5 production periods since the well was spud 36 years ago.

These production reports for Permit Number 105-20825 are available online here:

https://www.depgreenport.state.pa.us/ReportExtracts/OG/OilGasWellProdReport

According to this report the “WellType” (Column X of the spreadsheet) identifies the well as an “INJECTION WELL” for all 15 of the years reports were received by the operators.

Operators of this well included Guardian Exploration LLC, Roulette Oil & Gas LLC, JJ Bucher Production Corp and Potter-Mckean Resources, Inc.

The Pennsylvania Department of Environmental Protection is just as provably incapable of maintaining accurate records and providing adequate oversight over the existing injection wells in Roulette Oil and Gas’s inventory as the company’s incapability of complying with Pennsylvania oil and gas well regulations and reporting requirments.

Approving this injection well permit would put Roulette Oil & Gas one step closer to a permitted injection well while evaluation of Roulette Oil and Gas’s records in the DEP’s database reveals severe insufficiencies.

The consistent lack of oversight over oil and gas operations brings into question the Department of Environmental Protection’s commitment to the environment as required by Pennsylvania’s constitution.

Article I, § 27 of the Pennsylvania Constitution guarantees the people have a right to clean air, pure water, and to the preservation of the natural, scenic, historic and esthetic values of the environment.

The following injection wells have similar deficiencies in regulatory oversight and also have similar non-compliance issues.

API 105-20827, Well Name: MATTESON 2 https://www.ahs.dep.pa.gov/eFACTSWeb/searchResults_singleSite.aspx?SiteID=173384 Records indicate Matteson 2 has been Inspected 5 times by DEP since the original permit was issued on 6/13/1994. One of these 3 inspections have been conducted remotely/administratively.

API 105-20834, Well Name: MATTESON 8 https://www.ahs.dep.pa.gov/eFACTSWeb/searchResults_singleSite.aspx?SiteID=173391 Online records indicate Matteson 8 has been Inspected 4 times by DEP since the original permit was issued on 8/29/1984. Three of these inspections were inspected in person by the DEP, the most recent inspection was conducted administratively.

API 105-20829, Well name: MATTESON 16 https://www.ahs.dep.pa.gov/eFACTSWeb/searchResults_singleSite.aspx?SiteID=173386 Online records indicate Matteson 16 has been Inspected 4 times by DEP since the original permit was issued on 8/15/1984. 3 of these inspections were in person and 1, the most recent was conducted administratively.

API 105-20831, Well Name: MATTESON 103, https://www.ahs.dep.pa.gov/eFACTSWeb/searchResults_singleSite.aspx?SiteID=173388 Online records indicate Matteson 103 has been inspected 5 times since the original permit was issued on 8/15/1984. Four of these were in person inspections.

API 105-20832, Well Name: MATTESON 116, Online records indicate Matteson 103 has been inspected 5 times since the original permit was issued on 8/15/1984. Four of these inspection were conducted in person.  

API 105-20833, Well Name: MATTESON 117, Online records indicate Matteson 117 has been inspected 3 times since the original permit was issued on: 8/15/1984

API 105-20830, Well Name: MATTESON 120, https://www.ahs.dep.pa.gov/eFACTSWeb/searchResults_singleSite.aspx?SiteID=173387

 Online records indicate Matteson 129 has been inspected 3 times in the past 36 years since the original permit was issued on 8/15/1984.

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Save The Allegheny is a regional environmental and citizen advocacy organization that formed in response to recent threats posed to the Allegheny River, clean drinking water, air quality, endangered species, wildlife and all of our natural resources.   This is a cause to restore our rights.

Article I, Section 27 of the Pennsylvania Constitution states...

"The people have a right to clean air, pure water, and to the preservation of the natural, scenic, historic and esthetic values of the environment. Pennsylvania’s public natural resources are the common property of all the people, including generations yet to come. As trustee of these resources, the Commonwealth shall conserve and maintain them for the benefit of all the people."

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