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.