Comments submitted by Lauren Barr, Save Our Streams PA, on a proposed Roulette Oil & Gas Co. LLC oil and gas wastewater injection well in Clara Township, Potter County show the principals involved in the company have been involved in abandoning eight other injection wells in Clara and Hebron Townships in Potter County.

The comments were made at a July 25 hearing held by the Department of Environmental Protection to gather comments on the injection well application.

Barr’s comments say, in part--

"James W. Reynolds and Robert D. Benson have a long history of abandoning wells, including 8 injection wells, while operating them under authorization of EPA UIC Permit No: PAS2R940BPOT.”

“This has been well documented by the Department of Environmental Resources (DER) and Department of Environmental Protection (DEP) dating back to 1984.”

"Officers of Roulette Oil & Gas Co, LLC have operated wells in Pennsylvania under the business names of the following 4 companies according to records on file with Department of Environmental Resources (DER), Department of Environmental Protection (DEP), Department of Conservation and Natural Resources and Pennsylvania Department of State--

1. Roulette Oil & Gas Co. LLC. (OGO-68607)

2. Benson and Reynolds Gas Co.

3. Potter McKean Resources Inc. (OGO-48045).

4. Potter McKean Resources of Pennsylvania also identified by DEP as Potter McKean Resources of PA.”

“The companies listed above operated wells that have been identified by the DEP’s database as “abandoned.””

“James Reynolds is the managing partner of Roulette Oil & Gas Co.,LLC according to the Oil and Gas Operator Ownership and Control Information form that was filed with the injection well application.”

“While doing business as Benson & Reynolds Gas Co beginning around 1983 the company received permits to operate 8 injection wells located in Clara and Hebron Townships in Potter County.”

“Inspection Reports in DEP files reflect the operators were cited in 1990 and again in 1994 for abandoning the wells. “

“'This well is an abandoned well' is repeated in the inspection notes 8 times.”

“Ownership of the 8 injection wells was transferred to Potter McKean Resources Inc., on June 13, 1994.”

“According to the Pennsylvania Department of State, Potter McKean Resources Inc. was created on 06/01/1994 and the officers according to the Department of State were James W. Reynolds, Robert D. Benson and Peter Metritkas.”

“In addition to being abandoned DEP files reflect that these wells leaked and vented natural gas into the atmosphere for many years.”

“DEP records reflect James W. Reynolds and Robert D. Benson, officers of Potter McKean Resources Inc., currently have one well in the company’s inventory and that well is identified by DEP's online database as “abandoned.””

“Eight injection wells, along with 70 others were transferred from Potter McKean Resources Inc., to Potter-McKean Resources of Pennsylvania (OGO-62770) in 2003.”

“According to the Pennsylvania Department of State, the officers and owners of Potter McKean Resources of Pennsylvania are James W. Reynolds and Robert D. Benson Sr.

James W. Reynolds and Robert D. Benson Sr., owners of Potter- McKean Resources of Pennsylvania, currently have 20 wells listed in their inventory. Among them are 2 wells that are identified by the DEP’s database as “ABANDONED”.”

“For THIRTY YEARS, from 1993 to the present, according to DEP records, the Matteson 7 Well, API 105-20840 and the Matteson 3 Well API 105-20826 have been abandoned.”

“And they were abandoned by the company owned by James W. Reynolds and Robert D. Benson Sr.in Clara Twp., Potter County.”

“Inspection reports and records on file with the Pennsylvania DEP document these operators have operated wells out of compliance with Pennsylvania’s O&G Act since the Oil and Gas Act was first enacted.”

“James Reynold's long history of well abandonment in Clara Township is reason enough for the DEP to deny the pending injection well permit and I based on the long history of well abandonment I am asking the department to deny the injection well permit.”

“These owners/ operators have demonstrated an unwillingness to comply with the Oil and Gas Act.”

“I'm requesting the department staff who are currently reviewing this pending injection well application review the records on file with your department; including compliance reports/ inspection records, production and waste reports for the following operators:

-- Benson & Reynolds Gas Co (officers: James W. Reynolds and Robert Benson)

-- Potter- McKean Resources Inc. (officers: James W. Reynolds, Robert Benson & Peter Metritkas.)

-- Potter- McKean Resources of PA (officers: James W. Reynolds and Robert D. Benson Sr)

--  Potter –McKean Resources of Pennsylvania (officers: James W. Reynolds and Robert D. Benson Sr)”

“It’s important to note the 8 wells that were permitted by EPA as injection wells in 1984 on the Matteson Farm have been transferred from one operating corporation to another 5 times since the original UIC permit was authorized.”

Click Here for a full copy of Larie Barr's comments that includes copies and links to documents referenced in the comments.

The U.S. Environmental Protection Agency already issued an Underground Injection Control Permit (PAS2D050BPOT), effective January 14, 2022, to authorize the operation of the Class II-D Injection Well at this location.  [Read more here]

Visit DEP’s Underground Injection Control Wells webpage for information on a state permit needed for injection wells.

(Photos: Top- Trees growing through liner around storage tanks, wellhead - DEP inspection photos; Bottom- Clara well site - DEP inspection photo; unlicensed and uninspected truck used to haul drilling wastewater.  This is where hundreds of thousands of gallons of drilling wastewater would be deposed of.)

Related Articles - Roulette Injection:

-- Concerned Residents, Advocates Call On DEP For The Opportunity To Comment On Proposed Roulette Oil & Gas Waste Injection Well In Potter County  [PaEN]

-- Local Officials, Residents, Advocacy Groups Call On DEP To Conduct A Robust Public Participation Process For Oil & Gas Waste Injection Well Applications  [PaEN]

PA Oil & Gas Industry Public Notice Dashboards:

-- Pennsylvania Oil & Gas Weekly Compliance Dashboard - July 15 to 22;  8 More New Conventional Well Abandonments  [PaEN]

-- Pennsylvania Oil & Gas Weekly Compliance Dashboard - July 22 to 28  [PaEN] 

-- PA Oil & Gas Industrial Facilities: Permit Notices/Opportunities To Comment - July 29  [PaEN]

-- DEP Posted 47 Pages Of Permit-Related Notices In July 29 PA Bulletin  [PaEN] 

NewsClips This Week:

-- LancasterOnline: Study Finds Radioactive Materials In PA Waterways Near Treatment Plants Linked With Oil & Gas Industry Waste

-- StateImpactPA - Rachel McDevitt: Environmental Quality Board Dismisses Petition To Raise Well Plugging Bond Amounts For Conventional Oil & Gas Drillers

-- The Center Square - Anthony Hennen: Proposed Oil & Gas Waste Injection Well Riles Community In Fayette County

-- Warren Times: Proposed Oil & Gas Waste Injection Well In Fayette County Riles Community

-- TribLive: Olympus Energy Proposes Another Shale Gas Drilling Well Pad, Pipeline In West Deer Township, Allegheny County

-- Pittsburgh Business Times: Allegheny County Health Dept.  Begins Appeal Hearing On Invenergy Natural Gas Power Plant Proposed In Elizabeth Twp.

-- NRDC: PJM Electric Grid Operator Report Confirms Blackout Danger From Poor Maintenance At Natural Gas Power Plants

-- Post-Gazette - Anya Litvak/Jonathan Salant: White House Pushing To Reduce Methane Emissions From Oil & Gas Wells; Methane Accounts For 12% Of All Greenhouse Gas Emissions In PA

-- Beaver County Times Guest Essay: Here’s What’s Happening As A Result Of Shell Petrochemical Plant’s [$5 Million] Fine - By Daniel Rossi-Keen

-- Post-Gazette Guest Essay: Pittsburgh’s Problem With Shell Petrochemical Plant’s Plastic Nurdles - By Jack Doyle

Related Articles This Week:

-- Comments Submitted On Proposed Roulette Oil & Gas Wastewater Injection Well In Potter County By Save Our Streams PA Show Principals Have Been Involved In Abandoning 8 Previous Injection Wells  [PaEN]

-- DEP Signs $660,000 Penalty Agreement With Sunoco To Resolve More Violations During The Construction Of Mariner East Natural Gas Liquids Pipeline In 9 Counties; Penalties Now Total Nearly $31 Million Just From DEP  [PaEN]

-- University Of Pittsburgh School Of Public Health Will Release Results Of Shale Gas Development Health Impact Study On Aug. 15 In Washington County  [PaEN]

-- DCED Gives UGI Utilities A $501,136 Grant For A New Natural Gas Pipeline To Serve Little Leaf Greenhouse In Carbon County  [PaEN]

[Posted: July 27, 2023]

7/31/2023