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Guest Essay: DEP Ignored Abandoned Wells During Oil & Gas Wastewater Injection Well Permitting Process

By Laurie Barr, Save Our Streams PA

According to the Department of Environmental Protection’s (DEP) online database, the statuses of many of the wells surrounding the recently permitted [Catalyst Energy] Cyclone [PA] injection well [in Keating Township, McKean County] are ‘plugged’.

“We plugged the wells with ‘wooden plugs that the local mill produced’ explained Dennis Johnson., a retired oil field worker and area resident. ‘We hammered wooden plugs in and then filled the well with ‘dirt.’”

Modern regulations require placing cement in the wellbore through the water, gas and oil-producing zones. The spaces between the cement plugs are often filled (within the wellbore) with bentonite gel.

Cement plugs are temporary. Cement cracks, shrinks and deteriorates over time, and when cement plugs fail they need replacing.

There have been numerous and well documented cases in Pennsylvania of well plugs failing. See more here.

The Class II-D injection wells require two permits in Pennsylvania, one from the US Environmental Protection Agency and one from the Pennsylvania Department of Environmental Protection.

The EPA approved the Cyclone injection well permit on August 22, 2022.

On May 10, 2023, Catalyst Energy Inc. (Catalyst, or Applicant), submitted an application to the DEP to change the use of the gas well in Cyclone ( API Permit Number 37-083-46237) from a gas well to a Class II-D commercial brine disposal injection well (Injection Well).

During the DEP injection well permitting process, DEP and Catalyst Energy representatives & area residents met to discuss the (then) pending injection well permit.

The residents believed this conference was an opportunity for public comment where their concerns surrounding this project would be heard and addressed.

This was not the case, although Catalyst and DEP listened to the locals, their concerns were never addressed.

This included compelling concerns brought to their attention by local residents who once worked on these very wells in Cyclone, including the recently permitted Catalyst Energy Inc. Class II-D injection well.

And it was during that conference, a local resident, Dennis Johnson, held up a large map from 1937 showing Catalyst and DEP officials the recorded locations of hundreds of historic wells.

This map identifies the locations of a large number of wells that are not included in any of the DEP’s databases, online oil and gas well map or the injection well application.

And clearly, many of these wells are in relative close proximity of the Catalyst Energy injection well.

“There used to be a pump-jack two feet away from my garage,” said Jeffrey Eshbaugh, a Cyclone resident.

According to the historic map and DEP’s database hundreds of wells are scattered throughout Cyclone.

DEP records indicate only a few wells situated near the injection well site have been inspected by regulators during the injection well permitting process.

During the September 26th, 2023 conference regulators didn’t ask for a copy of the map.

Despite the fact a staggeringly large number of historic, area wells remain unknown to DEP, EPA and Catalyst Energy, the injection well permit was authorized by DEP on January 11, 2024. [Read more here]

“If the DEP had records of these wells, they may never have approved the permit for this project,” said Dan Tomkinson of Save Our Streams America, an organization working to raise awareness and promote the plugging of abandoned oil and gas wells. “It’s hard to believe they didn’t ask for a copy of the map. It’s almost like they didn’t want to know these wells are there.”

An inspection of the permitted [Catalyst Energy] Cyclone injection well was conducted by regulators [DEP] on January 26, 2024.

At the time of the inspection it was noted that bubbling was observed outside of the injection well’s casing.

This begs the question, if the DEP was willing to ignore the abandoned wells on the map; will DEP ignore the bubbling too?*

During a Pennsylvania Crude Development Advisory Council meeting, held on the May 25, 2023, Kurt Klapkowski, the Acting Deputy Secretary for the Pennsylvania Department of Environmental Protection’s Office of Oil and Gas Management explained that Pennsylvania recently submitted a letter to start the process of pursuing Class VI primacy of underground injection control (UIC) wells to pursue Carbon Capture, Utilization, and Storage (CCUS).

He explained, beyond Class VI UIC permitting, DEP is considering if it makes sense for them to obtain primacy from EPA for the remaining five classes of Underground Injection Control wells.

Is Cyclone an example of how injection well permitting in Pennsylvania will go if DEP succeeds in gaining primacy?

Click Here for a copy of Laurie Barr's guest essay.

Feb. 10 Town Hall Meeting

Residents of the town of Cyclone are having a town meeting Saturday, February 10 to discuss the process for appealing the DEP decision to grant the Catalyst Energy, Inc. injection well permit to the Environmental Hearing Board. Read more here.

*Note: On February 6, 2024, DEP did a follow-up inspection of the Catalyst Energy Inc. Lot 580 580-1 conventional well in Keating Township, McKean County that was found to be leaking as during a January 26, 2024 inspection.

The well was issued a permit by DEP on January 11 to be used as an oil and gas wastewater injection well. Read more here.

DEP’s most recent inspection report says a contractor was on site removing old well equipment and working to deal with the venting of gas which was continuing to leak.

The contractor identified “open hole [no casing] from 3,427 to 2,504 [feet down the well] which is the probable source of gas.”

DEP’s inspection report said after leaving a valve open for several minutes on the well, “no gas was noticed.” No follow-up actions were recommended in the report.

On February 7, 2024, DEP did another follow-up inspection of Lot 580 580-1 and found no one was on site. DEP inspection report offered no comments on the site visit.

On February 8, 2024, DEP did another inspection of Lot 580 580-1 and found the access road and well site stable and vegetated. DEP inspection report.

On February 9, 2024, DEP did another follow-up inspection of Lot 580 580-1 and found equipment onsite trying to “kill” to prevent gas from leaking.

DEP’s inspection report notes the operator pumped 4,200 gallons of water into the well while operations were underway to pull rods and tubing from the well.

The plan is to shut in the well and pull the tubing Monday.

(Maps: DEP’s map of abandoned conventional wells; 1937 map of abandoned conventional wells.)

Related Articles - Injection Wells:

-- Marcellus Drilling News: DEP Approves Catalyst Energy Oil & Gas Wastewater Injection Well In McKean County [Jan. 26 Inspection Found Gas Bubbling From Well] [PaEN]

-- Republican Rep. Krupa Introduces HB 1656 To Ban Oil, Gas Wastewater Injection Wells To Protect The Public From Radioactive, Toxic Materials [PaEN]

-- Marcellus Drilling News: DEP Approves Catalyst Energy Oil & Gas Wastewater Injection Well In McKean County [Jan. 26 Inspection Found Gas Bubbling From Well] [PaEN]

-- Roulette Oil & Gas LLC Withdraws Oil & Gas Wastewater Injection Well Application In Potter County [PaEN]

-- 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]

-- PA General Energy Announced It Will Plug Proposed Oil & Gas Waste Injection Well In Grant Twp., Indiana County [PaEN]

-- EPA: G2 STEM LLC Withdraws Application For Oil/Gas Wastewater Underground Injection Well Permit In Fayette County [PaEN]

-- EPA Approves Permit For Oil, Gas Wastewater Injection Well In Plum Boro, Allegheny County; 30 Days To File Appeal [PaEN]

-- EPA Issues Permit For Class IID Oil & Gas Waste Underground Injection Well In Jefferson County [PaEN]