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
|
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.