COMMENT LETTER
April 5, 2021
Kevin Rowsey
Source Water & Underground Injection Control Section
US EPA Region 3
Email : This email address is being protected from spambots. You need JavaScript enabled to view it.
Phone : 215-814-5463
Re: Underground Injection Control (UIC) Program Notice of Draft Permit Roulette Oil and Gas, PAS2D050BPOT
Dear Kevin:
Environmental Review, Inc. has reviewed the draft permit PASD050BPOT and has the following comments:
1. Draft Permit, Part II Section 3.C: Monitoring Requirements: The Permittee (Roulette) proposed a fixed radius Area of Review (AOR) of 0.25 mile. In its permit application (see Attachment A, Part II), the Permittee defended this AOR, stating “No wells, springs, or hazardous waste facilities found with the radius of the circle and one-quarter mile beyond the boundaries of the AOR.” However, the Permittee did not indicate the source of this data. Was this data based on the New York State Land Surveyor map also attached in its permit application? Were county real property records used? How about data from the US Geologic Survey or US Environmental Protection Agency? Additionally, was the data field-verified to make sure no wells, springs, or hazardous waste facilities in fact do not exist within the 0.25-mile AOR. Information about any field review confirming the absence of wells, springs and hazardous facilities needs to be clarified. Further information or clarification through field reports or other substantial documents is required to confirm the absence of hazardous facilities.
2. Draft Permit, Part II Section 3.C: Monitoring Requirements: The Draft Permit requires the Permittee to “monitor the nature and composition of the injected fluids injected into the Injection Well by sampling, analyzing, and recording the injection fluid for the parameters listed below at the initiation of the injection operation and every two (2) years thereafter, or whenever the operator observes or anticipates a change in the injection fluid.” Under Appendix C: Clara Field Water Analysis in the Permit Application with attachments, the sampling tests attached with the permit application are dated more than 2 years. Additionally, their attached sampling tests do not include all 15 of the parameters the draft permit requires them to sample. We suggest that a representative sample of the brine to be injected in the well be sampled for these 15 parameters before permit issuance to ensure the brine discharge will be protective of drinking water sources.
3. Draft Permit, Part II, C: Monitoring Requirements: The Monitoring Requirements include a measurement of listed parameters including Specific Conductance. In Attachment D: Injection Operation and Monitoring Program, the permittee has stated that “The specific gravity was not reported in this brine water analysis,but given the NaCl concentration of the brine a specific gravity of approximately 1.1 is expected.” and “The conductivity of the brine was not measured.”
When responses to these comments are available, please email those to me at This email address is being protected from spambots. You need JavaScript enabled to view it..
Sincerely,
Namratha Nallappan, EIT
Sr. Reviewer (Associate in Utah)
Aubrey Glynn, PE
Sr. Reviewer (Associate in Illinois)
Environmental Review, Inc.
(a 501(c)(3) nonprofit public benefit organization)
1792 Rogers Avenue
San Jose, California 95112