ACTION ALERT! 

Plans have been made to hold an informational meeting to discuss a proposal to convert a conventional oil well ( in the photo above) in the Allegheny River watershed into a class II injection well.  Class II injection wells are used to dispose of waste fluids associated with oil and natural gas production. 

The Clara Township supervisors, local residents and members of local environmental advocacy organizations have scheduled a meeting for January 27 at 7:00pm!

(Clara Township Facebook: https://www.facebook.com/pages/Clara-Township-Potter-County-Pennsylvania/104051812965315) (Contact Clara Township 814-698-2268)

They have been gathering information on the proposed waste disposal well. Their hope is to provide the information they gathered to the public and also listen to residents’ concerns so they may convey their concerns to the permitting authorities.  Applications for this project are on file and are pending approval by both the Pennsylvania Department of Environmental Protection and the (federal) Environmental Protection Agency.

Background 

On August 17, 2020 Roulette Oil & Gas LLC applied to the EPA for authorization to convert a conventional well into a Class II injection well in Clara Twp., Potter County, PA. (The authorization form is located here in Google Docs here: https://drive.google.com/file/d/1zgxfMx6_9ObUNdcvHv8Zx1F5lmpHRIBq/view?usp=sharing)

According to the PA Oil and Gas Map the location of the proposed injection well is in the Clara Oil and Gas Field near the Pleasant Valley, Clara Township border at Latitude DD: 41.894586 Longitude DD: -78.148143

You can see the location on Google Maps here: https://goo.gl/maps/GiZXjinNVtKgp12z6

Roulette Oil & Gas LLC Well Inventory

Roulette Oil & Gas Company, LLC, located at 1140 Route 44 South, Shinglehouse, Pennsylvania has an inventory of 437 wells. Of the 437 wells, 276 are located in Potter County. You can view or download the inventory spreadsheet here from Google Docs: https://docs.google.com/spreadsheets/d/1iU76DfRYXl6aNZ8dHE_slctem_OimPPfrizOX9Fym2U/edit?usp=sharing

Or you may download it from the DEP Website here: https://www.depgreenport.state.pa.us/ReportExtracts/OG/OilGasWellInventoryReport

Compliance/Inspection Reports

A search of the DEP database using the above parameters found inspection records for 655 inspections conducted on the 437 ‘Roulette Oil & Gas Wells LLC’. 

The inspection spreadsheet is in Google Drive Here: https://docs.google.com/spreadsheets/d/1jgUJ3KFl_8BoiwrgijIPxAx6NuXGqpVfErM5jJiTQps/edit?usp=sharing  (The inspector included notes on the inspections in the “R” Column.) The inspection reports are also available from the online DEP database here: https://www.depgreenport.state.pa.us/ReportExtracts/OG/OilComplianceReport

According to the information on the ‘Oil and Gas Well Production’ in Google Docs here: https://docs.google.com/spreadsheets/d/1Ox2IKiV0yiDo4UyPcTpvFSNk1gTmTVCSTgcWTL9mFJs/edit?usp=sharing And also available at the DEP online database: data available on the DEP’s online  database The status of Well API 105-21374 is ‘active’.

Roulette Oil & Gas LLC Produced Waste & Disposal Methods

According to the DEP’s Online database the amount of waste produced by well API 105-21374 during the Jan-Dec 2014 reporting period was 20 barrels (or 840 gallons). Disposal plans are also available online. “TEMP ON SITE STORAGE PENDING DISPOSAL OR REUSE.”  

API 105-21374 was drilled in May of 2008 and this database does not offer information on waste amounts or disposal methods for any other reporting periods for this well. 

This spreadsheet is available in Google Docs here: https://docs.google.com/spreadsheets/d/1H1CUiulFAt3C-irysKI8hFSDy6C-1_IMEjsqTeB1AGk/edit?usp=sharing

Or you can download Roulette Oil & Gas LLC’s Oil and Gas Well Waste Reports from the DEP’s database here: https://www.depgreenport.state.pa.us/ReportExtracts/OG/OilGasWellWasteReport

DEP online records identify how waste from Roulette Oil and Gas LLC’s wells is managed.

• 203 submitted reports indicate the method of waste disposal was “ON SITE DISPOSAL PURSUANT TO 25 PA CODE 78.62 OR 78A.62”

• 167 reports indicate the waste management method was REUSE WITHOUT PROCESSING AT A PERMITTED FACILITY (CONVENTIONAL REPORTS ONLY)

• 101 indicate the waste from the Roulette Oil & Gas LLC wells is “TEMP ON SITE STORAGE PENDING DISPOSAL OR REUSE”

• 13 reports indicate waste from Roulette Oil & Gas Wells was sent to FLUID RECOVERY SERVICES which is a waste disposal facility.

Feb. 1, 2021 Public comment period ends! Addendum! The public comment period has been extended until March 3, 2021

EPA is currently soliciting public comments 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: This email address is being protected from spambots. You need JavaScript enabled to view it.
Phone: 215-814-5463
Comments must be received by February 1, 2021.

Feb 2nd, 2021 Tentative Public Hearing 

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:

Call-in Number: (866) 609-3139             6:00 PM – 8:00 PM Eastern Standard Time

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.

Learn more:

https://www.epa.gov/pa/underground-injection-control-uic-program-notice-draft-permit-roulette-oil-and-gas-pas2d050bpot

Request for Public Hearing

EPA is currently accepting requests for the agency to hold a public hearing on the EPA waste injection well application:

Requests to hold a public hearing must be received via email or telephone by EPA by January 25, 2021

When requesting a public hearing, please state the nature of the issues you propose to raise. 

Additional Information and copies of the EPA application is available online here: https://www.epa.gov/uic/public-notice-pas2d050bpot-draft-uic-permit-roulette-oil-gas-company-llc-class-ii-d-injection

 Additional info:

• Public Notice: Draft UIC Permit for Roulette Oil & Gas Company, LLC (PDF)(18 pp, 1 MB) 

• PAS2D050BPOT Draft Statement of Basis (PDF)(5 pp, 221 K, December 31, 2020) 

A document that gives specifics on the proposed injection activity and the reasoning why EPA believes that the proposed activity doesn’t pose a risk to Underground Sources of Drinking Water (USDWs). 

• PAS2D050BPOT Public Notice (PDF)(1 pg, 101 K, December 31, 2020) 

• Administrative Record Index (PDF)(1 pg, 95 K, December 15, 2020) 

A list of all resources that were accessed to help EPA come to a final permit decision. - Permit Renewal Application 

• Permit Application (PDF)(64 pp, 8 MB, October 26, 2020) 

Permit Application submitted to EPA in September 2020 for authorization for the construction and operation of one Class IID injection well, Clara Field #20