Proposed injection well is bad news for locals

August 10, 2017

Letter to the Editor_Wide

Dear Editor:

Muskegon Development Company has recently applied for a Class II Injection Permit to allow Enhanced Oil Recovery operations on a non-producing oil well located near Townline Lake Road and North Athey Road in Hamilton Township (Holcomb 1-22).

If allowed, this Enhanced Oil Recovery operation could greatly endanger the community, as there are simply too many inherent risks and unknown variables to do this safely.

Indeed, there are too many risks associated with Enhanced Oil Recovery for me to address them all right now; however, one of big dangers is the possibility of contaminated drinking water.

As Hamilton Township is a rural community in which most of the residents depend upon well water for their homes and businesses, any threat to our water is a major risk for the entire community.

But this project is also a major risk for residents outside of Hamilton Township, as the underground aquifers and other fresh water sources that we share don’t respect lines on maps.

As proposed, Muskegon Development Company would have permission to inject an unlimited amount of fresh water (meaning OUR fresh water, as it would be drawn from the area) approximately 5,000 feet underground under high pressures in order to force any remaining oil and gas deposits to the surface, likely through other wells.

According to the draft permit, there is nothing to worry about:

“The applicant has provided documentation on the well population within ¼ mile of the injection well (i.e., the AOR). There are 2 producing, 0 injection, 0 temporarily abandoned, and 1 plugged and abandoned wells within the ¼ mile radius AOR which penetrate the injection zone. Based on current information, there are no inadequately constructed wells within the AOR so there is no need for a corrective action.”

(It should be noted that, according to a representative from the Michigan Department of Environmental Quality who attended an August 3 township meeting, there are technically 3 producing wells.)

In other words, Muskegon Development Company was allowed to provide its own numbers, and they say there are only 3 other wells nearby, only 2 of which are producing, and that these wells are perfectly safe.

This isn’t exactly the proverbial fox guarding the hen house; it’s more like the fox auditing the hen house before it eats the chickens.

The numbers Muskegon Development Company provided could easily be wrong.

And I’m sure the company knows this.

Hamilton Township has a history with the oil and gas industry that goes back at least to the 1930s.

At the Hamilton Township Trustee Meeting held on August 3, 2017, it was acknowledged that there could be numerous old wells in the area that have been abandoned and forgotten. The industry refers to them as “orphan wells.”

These are OLD wells. And nobody seems to know where all of them are. They aren’t on the maps.

And we don’t know how deep they are, either. Or how they were constructed. Or how many there are.

There could be hundreds of these orphan wells.

The Michigan Department of Environmental Quality acknowledged as much during the meeting, where, in response to the question of how many orphan wells were in the area, residents were told:

“There could be wells in the area that we don’t know exist. Only time will tell… I hope there’s not.”
Reassuring, no?

In addition to being hidden, these orphan wells are likely to be leaking.

Modern oil and gas wells use steel and cement. Yet at least 6% – 7% of modern wells have failures upon installation, and that is a conservative estimate.

One recent study conducted in the Marcellus region of Pennsylvania determined that 6.3% of wells drilled between 2005 and 2013 had “a well-barrier or integrity failure.” This finding was consent with another recent study that put the failure rate at 6.2%.

Another study, which included wells drilled in 2012 throughout the entire Marrcellus region, put the initial failure rate at 8.9%.

Statistics from the United States Mineral Management Service indicate that, in the Gulf of Mexico, approximately 5% of all gas wells failed immediately.
These are NEW wells.

But the really scary part is that the rate of failure increases exponentially with age.

According to the United States Mineral Management Service, by the second year of operation, over 20% of Gulf wells have failed.

After 30 years, approximately 60% of wells have failed.

But the old wells in Hamilton Township are obviously a little different.

Back in the 1930s, 40s, and 50s, they used timber or corn posts in these wells, and they didn’t seal them with steel and concrete.

Actually, it was common practice to use garbage from the site to plug the well when they were done with it. At the township meeting held on August 3, a representative from the Michigan Department of Environmental Quality told us he had seen all sorts of crazy things used to plug old wells.

“We’ve pulled up rope, we’ve pulled up wood, trash, you name it, we’ve pulled it up. Wrenches.”

He described the old process of plugging wells as such:
“Basically, when they plugged these wells, that was part of the plan. We take everything we had here, and we put it in the hole.”
Does anyone really think these orphan wells that are literally plugged with garbage have withstood the test of time?
Does anyone really know what will happen when they use high pressure to inject water into the ground underneath them?
Hamilton Township has already had more than its share of problems with this industry. I know families in Hamilton Township who have dangerous methane levels in their well water, probably due to old wells.

And I’ve heard plenty of the old stories of the mysterious exploding basements of Hamilton Township.
But I’m sure the oil and gas industry, under the “supervision” of our various “regulatory” agencies, will get it right this time.
Why wouldn’t they?

And we should definitely have faith in the EPA. I mean, just because it couldn’t even inform the township of the correct meeting time for the July 25 public hearing on the draft permit for this operation (which, strangely, was held in Clare, not Hamilton Township), doesn’t mean it shouldn’t be trusted now to address the far more complicated issues of ground water contamination and orphan wells plugged with garbage.

Forgive me for being skeptical. And very concerned.
But there’s hope.

Because of the confusion regarding the meeting time, the EPA has extended the Public Comment Period for the proposed Class II Injection Well.
We now have until August 18, 2017 to write or email the EPA with concerns.

I encourage every resident of Clare County AND Gladwin County (because this affects you, too) to write the EPA.

Demand a properly-noticed hearing on the Holcomb 1-22 well. Demand that this hearing be held in Hamilton Township, because the well is in Hamilton Township.

Include all of your concerns in the letter, especially your concerns that are grounded in science. And remember to include: “RE: Holcomb 1-22 well, #MI-035-2R-0034.”

Address your letters as follows:
William Tong
U.S. EPA, Water Division
UIC Branch (WU – 16J)
77 W. Jackson Blvd.
Chicago, IL 60604-3590
RE: Holcomb 1-22 well, #MI-035-2R-0034

E. Joseph Addison

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