Saturday, April 9, 2016

Three comments about the Brine Leak in Adrian Township

The event during which an estimated 100 gallons of brine leaked from a facility pipe owned and operated by Savoy Energy uncovers several concerning issues:
1.) "Brine" is a very corrosive fluid that dissolves metal pipes despite added anti-corrosive chemicals. In this case I suspect that this brine might even contain hydrochloric acid. It is therefore far from just "salt water" and definitely not harmless for the environment. It is a frightening thought that millions of gallons of this stuff polluted with drilling chemicals are pumped permanently into soon 4 brine disposal injection wells in Lenawee county, and over 1200 such wells in Michigan. Once not needed anymore, these injection wells are entirely unmonitored after only a short observation period of a few years. A time bomb for the artesian aquifers of our state.
2.) Savoy Energy showed once more that they are not a decent partner to communities and land owners on whose property they operate. They did not communicate the incident, did not appear on site and even avoided commenting to the press. They have done so in every incident exposing a great arrogance and lack of respect.
3.) The fact that Savoy was not required to inform the township and other officials but only the DEQ shows once more that the industry is not regulated well enough and that there are not sufficient laws in place to safeguard people and the environment. In addition, the scale of the accident was solely determined by the polluter Savoy Energy itself - a general pattern that allows energy companies to almost completely regulate themselves as if they could be trusted to operate in the best interest of the community and the environment. The history of Savoy's conduct of flaring perfectly useful natural gas for almost 2 years and violating the Clean Air Act on their Adrian production facility shows that they are NOT trustworthy at all. In addition, the leaks found by the EPA more than 1.5 years ago were still found at a recent revisit - showing that Savoy Energy does not even care about the few existing laws - not even a federal law like the Clean Air Act!

Friday, April 1, 2016

The disturbing extent of "Brine" Injection Wells

In the face of the newest "brine" injection well in Lenawee County, I was looking for the coordinates of existing injection wells from the EPA and was pointed to the Michigan map server with the below email of the regional permit technician:

EPA does not have a data base with all injection well locations. The information you seek is available from state programs.  EPA has given many states authority to implement the federal Underground Injection Control program for most classes, and I recommend you check with state agencies directly. For Region 5 states (Illinois, Indiana, Michigan, Minnesota, Ohio, Wisconsin), check the Region 5 website for state websites and contacts: https://www.epa.gov/uic/underground-injection-control-epa-region-5-il-mi-mn-oh-and-wi#dwa under "Who regulates UIC wells in my state?"  Several states have online well database systems. Though EPA regulates Class II wells in Michigan, the Michigan Department of Environmental Quality has an online well database system found at http://www.deq.state.mi.us/GeoWebFace/ which can be searched for brine disposal wells.  While I have information for Region 5 UIC well programs only, other EPA Regions and states have similar information. 

Best regards,

Anna Miller
Environmental Scientist
Underground Injection Control Branch
U.S. EPA Region 5  (WU-16J)
77 W. Jackson
Chicago, IL 60604

(312) 886-7060

I generated the below map in Google Earth restricting the well type to: Brine Disposal Wells (1206 wells!!!!, red markers). See for yourself how frightening many of these wells are in the Lower PI of Michigan alone. Now think that abandoned wells only need to be monitored for a few years. What a time bomb below our feet...


You can download the Google Earth KMZ file: HERE

Wednesday, March 30, 2016

There is little Canadian interest in the Rover (or Nexus) gas pipeline

Frank Zaski posted this to FERC this morning. Many of the same arguments can be used against Nexus – even more potent ones – such as over half of Nexus capacity is destined for Canada, costs are higher (see below), they are only 55% to 66% subscribed and an anchor shipper (Chesapeake) is almost bankrupt, Energy Transfer is already subsidizing them. 



There is little Canadian interest in the Rover gas pipeline.

CANADA is a major destination for Rover. It appears virtually all the gas they plan to ship thru Michigan and the Market Segment is destined for Canada and Dawn. However, there does not appear to be much Canadian interest in Rover gas primarily because its delivered COST will be higher and many fear the strong potential for stranded costs being passed on to ratepayers.


ROVER GAS WILL COST CANADIANS MORE THAN GAS FROM OTHER SOURCES
In the most recent Ontario Energy Board (OEB) Natural Gas Market Review (February 2016), a number of Ontario organizations voiced their concerned with Rover (and Nexus) plans to ship gas to Dawn.
TransCanada stated:
Transportation paths from Marcellus/Utica via the Niagara, Chippawa and Waddington, New York interconnect points are more cost effective for Ontario consumers than Rover/Dawn.

The landed cost of gas into the Enbridge EDA (Toronto) would be lower from Niagara ($4.90 $CAD/GJ) and Waddington ($5.30) than from Vector ($5.55), Rover ($5.73) or Nexus ($5.82).

Firm contracts for gas supply from New York to Ontario through Niagara and Chippawa will rise to nearly 1.1 Bcf/d in the winter of 2016/17. TransCanada expects to be able to service this reversal of flow for only $30 million.

The flow reversal is proceeding with Waddington (NY) shipments to Ontario expected in November of 2017. This reversal of flow will also be at low cost.

Western Canadian (WCSB) gas will continue to flow to Ontario thru the TransCanada Mainline, Great Lakes Gas Transmission and Alliance pipeline systems.
As in the US, Canadian gas supplies are at very high levels and prices very low.

CANADIAN BUSINESS ASSOCIATIONS representing industrial gas users, property owners, power producers and manufactures write in Canadian OEB filings that they basically DON’T WANT ROVER GAS:
Associations are concerned that the Dawn Parkway Expansion Application revenues at current rates did not support the investment and that SIGNIFICANT GAS RATE INCREASES will result.

Associations want to avoid “burdening pipeline builds” for the 40 – 50 year life of a pipeline and the potential to pay for stranded assets. They recommend lower cost NY pipeline alternatives, market based, non-facility solutions (such as displacement) and investing in technology to cut gas usage and GHG. 

The associations firmly believe Canadian regulators will act to reduce GHG and natural gas consumption. “Ontario is likely at or very close to peak gas consumption.” (In Canada, natural gas is seen as a contributor to GHG gas emissions and not as a solution - as in the US.)

HOW MUCH GAS DOES ROVER REALLY PLAN TO SHIP TO CANADA (and Michigan)?
Rover claims they are FULLY SUBSCIBED to ship 1.3 Bcfd to Dawn thru Vector. However, Vector’s capacity is only 1.3 Bcfd and Nexus also plans to ship (.76 Bcfd) thru Vector as well. How can these companies ship over 2.0 Bcfd thru a 1.3 Bcfd capacity pipeline?
The stated capacity of Rover’s Market Segment pipeline north of Defiance is 1.3Bcfd. If all of this gas is destined for Canada, then apparently no gas is planned for Michigan customers. No real Michigan customers were identified in FERC filing, and Michigan’s Consumers Energy (CMS) stated that Rover did not meet their requirements.
It appears Rover is not fully subscribed and has contracted for only .9 Bcfd capacity on Vector. https://www.snl.com/SNLWebPlatform/Content/Industry/IOC/PipelineContractDetails.aspx?KeyInstn=4079497
Canada does not need this much extra gas – it is far more gas than what currently flows to Canada thru Michigan and New York today.  

FLAT ELECTRIC DEMAND: The Ontario grid operator sees flat 18-month electric demand thru 2017.  950 MW of wind and 140 MW of solar capacity will be added during this period. https://www.snl.com/InteractiveX/article.aspx?ID=35876685&KPLT=4
Quebec already gets 99% of its electricity from renewable sources (mostly hydro). 

Except for a 100% ethane plant in Sarnia, no new petrochemical plants are planned for Eastern Canada.

There is little potential to ship Rover gas to the US and Canadian East  Coasts or for LNG export. US East Coast pipelines are destined to supply those US states, and for the few US and Canadian LNG export plants possible, they already have designated East Coast pipelines. No LNG plant north of Maryland has received financial approval.

Summary
Rover cannot claim new sources or new markets. Considerable Marcellus and Utica gas is already flowing to Eastern Canada thru Michigan and especially the economical way thru New York. These existing pipelines provide gas at lower cost, thru multiple locations and without Rover’s environmental degradation.

Building Rover will negatively impact, if not destroy, over 9,000 acres of US forests, farmland, wetlands and other property. This is in addition to intimidating thousands of property owners.


Rover’s environmental degradation far outweighs any benefits to Canada or Michigan.