ACTION ALERT: EPA Comments on Injection Wells

ACTION ALERT: EPA Permit Wayne County Solution mining and Injection Wells

Once again the EPA is preparing to issue permits for solution mining and injection wells, this time in rural Wayne County by applicant Buckeye Terminals, LLC from Emmaus, Pennsylvania. It may be interesting that the Limited Liability Company hails from an area not far east of the fracking area for the Marcellus Shale. They have applied for one Class III permit for solution mining for salt and five permits for Class I non-hazardous in-jection wells.

“The Class III area permit covers 4 proposed cavern wells to be excavated by solution mining of the Salina B Salt formation via pressurized injection of fresh water and mineral oil or nitrogen gas to a depth of 1070 feet”… “Brine (salt water) created from injection of fresh water (not to exceed 1.8 million gallons per day) will be injected for disposal into any of the five proposed Class I wells… to a depth of 3470 feet.” “The completed caverns will later be used for storage of liquified petroleum gas.” (Propane) However, the Company is not bound by that intended storage for its investors. Fracking waste possible?

————(quotes from the EPA document seeking comment by deadline July 3)

What could possibly go wrong here?

Let us list a few areas of concern:

1.) Primary aquifer is 350 feet below the surface. It is supposed to be separated from the mining operation by impermeable rock formations per the typical geological succession charts and fancy well casings. However, as with all injection wells, the so-called non-hazardous fluids will not be put in a container, they will be dumped in a “con-fining” layer under the assumption that fluids do not migrate anywhere and there are never cracks in rock formations or nearby abandoned shafts from past operations. In other words, as usual, the EPA expects an alternate reality that doesn’t always pan out in the real world. There is always a danger of leaks at the surface, migration with exist-ing drill sites, or earthquake events and cracks. All of these dangers have proven real in numerous locations around the country.

2.) 1.8 million gallons of fresh water a day turned into salt solution and removed from further use seems like a really serious waste of a precious resource. This is in Wayne County, the location of a water department that has chosen to shut off water to over 100,000 residents who could not afford the high bills common in the area. Yet we are supposed to turn over this much water from the commons to an LLC from Pennsyl-vania?

3) Salt is already mined in the Detroit area and it is certainly possible there is not a real market for more of it. There is no market for the potash the EPA has tried to let a Colorado LLC mine in Osceola County. Will the caverns created eventually be used to

store toxic waste from elsewhere to recover costs of excavation or to simply store pro-pane as they now claim? Either way we are asked to approve the further use and stor-age of fossil fuel products at a time of climate crisis. We are being asked to continue turning Michigan into a toxic waste dump to service the needs of the fossil fuel industry, at the expense of our fresh water and as a continuing diversion from the necessary cre-ation of renewable energy options. We don’t need more holes in the ground, more toxic brine, more storage spaces for the waste of an obsolete industry.

Public comment on this is open until July 3. We encourage you to demand a public hearing on these permits first of all. If enough people do they have to have one. Then we can raise a multitude of concerns and ask our questions.

TO SEND COMMENTS:

Refer to Buckeye Terminals, LLC

Class I permits – injection wells

BDW-1: MI-163-II-0004

BDW-2: MI-163-II-0005

BDW-3: MI-163-II-0006

BDW-4: MI-163-II-0007

BDW-5: MI-163-II-0008

Class III area permit:

MI-163-3A-0001

Mail or email your comments to:

Allan Batka (Class I permits) batka.allan@epa.gov
William Tong (Class III area permit) tong.william@epa.gov

U.S. EPA Region 5, Water Division
Permit Branch
77 W. Jackson BLVD. (WU-16J)
Chicago, IL 60604-3590

Thank You,
Michigan Citizens for Water Conservation Board
savemiwater.org