Tell The EPA to Deny the Class II-D Underground Injection Well Permit

Tell The EPA to Deny the Class II-D Underground Injection Well Permit

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According to the USGS given enough time, the pressure increase created by injection can migrate substantial horizontal and vertical distances from the injection location. And when injected fluid migrates outside of the intended zone, aquifers, streams and drinking water sources are at risk for contamination.

On February 2, 1987, shortly after eight EPA authorized injection wells were abandoned in Clara and Hebron Townships, Clara Township officials enacted an ordinance which banned injection wells in Clara Twp., unless a company held a “Special Exception Permit” issued by township officials. The eight wells that were abandoned were operated by James W. Reynolds d/b/a Benson & Reynolds Gas Company.

On August 17, 2020 James Reynolds filed an application with the EPA seeking authorization for another injection well permit. This application was signed by James Reynolds as the “managing partner” of Roulette Oil & Gas Co., LLC.

When O&G regulators inspected the 8 injection wells they noted in 1990 & again in 1993 that the wells were left unplugged, abandoned and were leaking natural gas into the atmosphere.

Clara Twp. is populated by many part-time seasonal residents and only 186 full time residents who live in a cellular dead zone, where high speed internet is unavailable. So notice of the pending injection well permit and comment period has spread sporadically.

Seeking permits for injection wells in rural areas where there are relatively few full time residents, almost guarantees opposition to be small. Low population has made bucolic communities like Bear Lake and Clara sitting targets for operators looking for an easy path to injection well permits.

Injection of wastewater into underground wells by oil and natural gas producers have caused earthquakes in Ohio, and recently a magnitude 4.2 earthquake struck in northern Oklahoma.

Property Values decline significantly in areas where injection wells are permitted. According to a recent State Impact report, Judy Burger a resident of Belmont County, Ohio for 25 years described her experience living near injection wells: “It’s beyond description, how horrible it is to feel like you’re stuck. We were told we have no property value,” she said. “Nobody would buy our property.”

EPA says waste from Oil and Gas wells can be toxic and radioactive.

“In recent years, as more injection wells are permitted, there have been problems. In 2019, brine injected into one well in Washington County migrated into producing oil and gas wells five miles away.”

If the EPA injection well permit application is approved, Roulette Oil & Gas would also need authorization from the Pennsylvania Department of Environmental Protection to operate an injection well in Clara Township, Potter County where operating an injection well without a “Special Exception Permit” is contrary to the township’s existing ordinance.

The direction of groundwater flow from the location of the proposed injection well is toward areas not serviced by public water supplies where residents rely on springs and private water wells. These drinking water sources are not routinely monitored for contaminants.  And there’s already significant risk present from the existing O&G wells in the region.

For these reasons we are asking the EPA to rightfully deny Roulette Oil & Gas Co., LLC’s Class II injection well permit application PAS2D050BPOT.

Comments must be received by March 4th, 2021. For more info go to:

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