Savoy Energy seeks to place underground injection well in Raisin Twp.

Hello everybody,

I just send the below email to William Tong, U.S. EPA Water Division, UIC Branch (WU-16J), 77 W. Jackson Blvd., Chicago, IL 60604-3590 tong.william@epa.gov to state my objection against issuing of such a permit, and to request a public hearing in Adrian, Michigan before the permit is issued. Please support that the EPA organizes a hearing by quickly emailing Mr. Tong and asking for it. Deadline is 6/30.

Thanks, Tom

William Tong U.S. EPA Water Division, UIC Branch (WU-16J) 77 W. Jackson Blvd., Chicago, IL 60604-3590 By Email to: tong.william@epa.gov

Date   June 13, 2015

Concern:          Permit application for a a Class II injection well by Savoy Energy L.P. off of East Valley Road and Breckel Highway in Raisin Township, Lenawee County, Michigan

Dear Mr. Tong,

I suggest that the EPA withholds the requested permit for a Class II injection well due to the risk of aquifer contamination (Bloetscher und Gao 2014; Maliva et al. 2007), especially in fractured geological strata and increased tectonic activity caused by multiple injection wells (Frohlich 2012). The major risk factors are failures of well casings, especially cement fatigue failures (Yuan et al. 2013). Such failures become more likely because current regulations require that operators maintain and monitor wells just for 2 years after plugging the wells. This is one of the reasons why the U.S. Government Accountability Office (GAO) stated that the “EPA Program to Protect Underground Sources from Injection of Fluids Associated with Oil and Gas Production Needs Improvement” (U.S. Government Accountability Office 2014).

In addition, the applicant of the disputed permit application, Savoy Energy L.P. has a track record of cutting corners and running its operations not in accordance with best practices – as recently shown in their violations of the Clean Air Act (EPA-5-15-MI-04). It is therefore doubtful that the applicant will show more respect for the Clean Water Act.

I therefore request that the EPA should organize a public comment session in Adrian before issuing the permit.

Thank you in advance!

Dr. Thomas Waßmer

References:

Bloetscher F, Gao J. 2014. Analyses of Physical Data to Evaluate the Potential to Identify Class I Injection Well Fluid Migration Risk. Water Resources Management 28(15):5283-5296.

Frohlich C. 2012. Two-year survey comparing earthquake activity and injection-well locations in the Barnett Shale, Texas. Proceedings of the National Academy of Sciences of the United States of America 109(35):13934-13938.

Maliva RG, Guo W, Missimer T. 2007. Vertical migration of municipal wastewater in deep injection well systems, South Florida, USA. Hydrogeology Journal 15(7):1387-1396.

U.S. Government Accountability Office. 2014. DRINKING WATER: EPA Program to Protect Underground Sources from Injection of Fluids Associated with Oil and Gas Production Needs Improvement. Washington DC: U.S. Government Accountability Office. p. 103.

Yuan Z, Gardoni P, Schubert J, Teodoriu C. 2013. Cement failure probability analysis in water injection well. Journal of Petroleum Science and Engineering 107:45-49.

After More Than 1 Year The EPA Finalizes Findings of Savoy's Violations of the Clean Air Act

The most important parts are on page 9 and 10:

65. Due to numerous odor complaints from citizens, the Savoy Adrian 25 Facility emissions of air contaminants have caused injurious effects to human health or safety, animal life, plant life of significant economic value, or property, or caused unreasonable interference with the comfortable enjoyment of life and property, in violation of Michigan Rule 336.1901 and the Michigan SIP.

66. Savoy’s above-referenced violations have caused, may and will cause excess hazardous air pollutant (HAP) and VOC emissions.

67. Excess HAP emissions can cause serious health effects, such as birth defects and cancer, and harmful environmental and ecological effects.

68.  Excess VOC emissions can cause eye, nose, and throat irritation; headaches, loss of coordination, nausea; damage to liver, kidney, and central nervous system. Some VOCs can cause cancer in animals and some are suspected or known to cause cancer in humans.

69. VOC emissions are a precursor to ground-level ozone. Breathing ozone contributes to a variety of health problems including chest pain, coughing, throat irritation, and congestion. It can worsen bronchitis, emphysema, and asthma. Ground-level ozone also can reduce lung function and inflame lung tissue. Repeated exposure may permanently scar lung tissue.

Unfortunately, the email to blogger function does not post attachments - and to post PDFs on blogger is unnecessarily complicated - therefore I post the document as PNG images.

Fwd: Another spill:

Friends,

As summer begins, the beaches of Santa Barbara, California are closed after a 105,000 gallon spill from an oil pipeline running just along the shore. This is what we are fighting to stop in the Midwest with the Tar Sands Resistance March on June 6th in St. Paul:

While workers in safety gear struggle to clean up, the pipeline company Enbridge is plotting to expand their network of tar sands pipelines running through the Midwest, crossing hundreds of waterways and under areas of the Great Lakes.

Enbridge is responsible for the largest onshore oil spill in American history. In 2010, their Line 6B pipeline spilled over a million gallons of tar sands into the Kalamazoo River in Michigan.

When pipelines break they upend the entire way of life for the communities surrounding them. Enbridge wants to bring this danger to more and more people. We want to stop them. On June 6th, we're holding the biggest action against the tar sands the Midwest has ever seen, in St. Paul, MN. Can you join us to stop Enbridge? Click here to join the March.

Pipelines leak. And if Enbridge's pipes leak, the cleanup won't look like what's happening in California. Tar sands oil sinks. If you thought cleaning oil off a beach was hard work, imagine trying to clean oil off the bottom of the Great Lakes -- which tens of millions of people rely on for drinking water.

Even if Enbridge's pipelines worked as planned, they'd help put millions of tons of additional carbon pollution into the atmosphere -- bringing more heatwaves and other extreme weather to the Midwest.

The whole scheme is a disaster we can't afford. What happened in Santa Barbara is just a reminder of the risks we face. Let's take that reminder to heart, and mobilize for serious action on the 6th. I'll see you there. 

Andy

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Effects of exposure to ambient levels of benzene, toluene, ethylbenzene, and xylene (known together as BTEX in areas areas impacted by oil and gas development

New Look at BTEX: Are Ambient Levels a Problem? - Environmental Science & Technology (ACS Publications)

BTEX exposure and hormone-related health conditions: implications for ambient exposures, and areas impacted by oil and gas development

http://pubs.acs.org/doi/abs/10.1021/es505316f


Sent from my iPhone

Human-caused global warming is responsible for 3 out of 4 super hot days, new study calculates

Source: NASA/Goddard Space Flight Center Scientific Visualization Studio

Newspaper article by SETH BORENSTEIN, AP Science Writer
http://www.usnews.com/news/world/articles/2015/04/27/study-blames-global-warming-for-75-percent-of-very-hot-days (also published at the Daily Telegram)

Here is the link to read the full text of the scientific publication. Click on the words in brackets, e.g. [Article]...

Fischer, E.M., and R. Knutti, 2015: Anthropogenic contribution to global occurrence of heavy-precipitation and high-temperature extremes, Nature Climate Change, 10.1038/nclimate2617. [Article] [Supplementary Information] Nature News and Views , ETH Blog, Nature News.

Biased Jurisdiction in Eminent Domain Cases

I am wondering why fossil fuel companies always get their way (literally) without proving that they are actually working in the public interest. In contrast to this clean renewable wind parks cannot just take the land they want. Seems that the laws are seriously biased to favor past century dirty industries that might have been in the public interest once but certainly are not anymore today. In contrary the fossil fuel industry should be held accountable for droughts, diseases, floods, and other disasters caused by global climate change. Every new facility that is build today will be in service for at least 30 years to return the investment - and during this time contribute to further damages to the world. It is profoundly immoral to plan, build an run such facilities based on outdated technologies and definitely NOT in the public interest!

Why Tesla’s announcement is such a big deal: The coming revolution in energy storage - The Washington Post

http://www.washingtonpost.com/news/energy-environment/wp/2015/04/30/why-teslas-announcement-could-be-such-a-big-deal/?tid=sm_FB