Injection well raises concerns

July 27, 2017

By Pat Maurer
Correspondent

A small group, concerned over an Environmental Protection Agency permit application from Muskegon Development Company of Mt. Pleasant to convert an existing oil production well to an injection well for “enhanced oil recovery” in the Dodge City area, came to a presentation and Public Hearing with EPA officials Wednesday evening.

Many expressed concern over errors and omissions in the notification process, saying the day and location were incorrect in the Public Notice and that many may not have been aware of the hearing.

EPA Geologist William Tong outlines the process to convert an oil producing well near Dodge City to an injection well to recover oil to a small group of concerned citizens.

EPA Geologist William Tong outlines the process to convert an oil producing well near Dodge City to an injection well to recover oil to a small group of concerned citizens.

During the presentation, Bill Tong, Geologist for the Underground Injection Control Branch, explained the process of developing and monitoring the Class II injection wells, using fresh water to force out oil from a non-producing well.

The application is for the existing Holcomb #1-22 well located on the south side of East Townline Lake Road between North Athey and Bailey Lake Road. The location is about 1.5 miles east of Dodge City.

The presentation, part of the process before EPA makes a decision to approve or deny the permit, included a question and answer session with audience members.
If approved the permit would apply to the life of the well, Tong explained.

He went over the construction of the injection well and specific requirements including pressure limits, fluid composition (fresh water), plugging and abandonment plans, and funds for closing an injection well.

Audience members were not concerned about pollution issues but rather with how much fresh water would be used and how it would affect drinking water supplies to what many said was a “poor, depressed area.”

Jeff Ostahowski of Mecosta representing Michigan Citizens for Water Conservation, questioned why brine water couldn’t be used and fresh water conserved. “For years and years fresh water will be injected into the well. How many drinking water wells will this affect? he questioned.

Tong replied, “Zero.” He explained that the injection system would be “deep below the underground sources of drinking water with confining rock layers above the injections zone which would prevent the migration of fluids upwards. He said there are “significant penalties” for permit violations.

Tong explained that the deepest source of drinking water is 464 feet and the surface casing would extend to 792 feet, 300 feet more than is required. The injection zone would begin at 4,948 feet.

Mary Anne Van Oosterhout asked about the effect on the water table, how much fresh water would be injected and where it would come from.

EPA representative Steve Jann, Branch Chief of the Underground Injection Control Branch of Region 5 in Chicago said “The amount of fresh water used is not in the scope of our permit process. The permit says nothing about where the water comes from. That is a State issue through the Department of Environmental Quality.

Geologist William Tong and EPA representative Steve Jann, Branch Chief of the Underground Injection Control Branch of Region 5 in Chicago, answered questions from a group of about 15 citizens who came to a presentation and public hearing about a permit application for an injection well from Muskegon Development Company.

Geologist William Tong and EPA representative Steve Jann, Branch Chief of the Underground Injection Control Branch of Region 5 in Chicago, answered questions from a group of about 15 citizens who came to a presentation and public hearing about a permit application for an injection well from Muskegon Development Company.

Wayne Terpening asked, “Where does the DEQ interface with the process?”

Several others spoke asking questions about surrounding properties would be affected and how the well would be monitored and regulated.

In his presentation Tong explained that injection wells are designed and constructed to prevent leaks with multiple layers of steel pipe (well casing), cement in between the well casings and confining rock layers to protect drinking water sources.

The presentation said more than 180,000 Class II injections wells are in the United States and about 1,300 are in Michigan.

Following the presentation, vocal comments on the permit application were given by several audience members.

Wes Raymond representing the Citizens for Chemical Contamination was the first speaker. He said, “Your outreach was insufficient. There were errors in communications, a contact number for Tong was wrong. It feels like you’re avoiding us. You need to find new ways to maintain the environment. Cedar Creek on the map is a trout stream and Decker Lake isn’t even on the map. It is frustrating to know you’re compartmentalized about this. You can’t see what is 4,000 feet under the surface. That has to be part of the equation. The climate change factor is real. I would like to see an EPA who would be here to hold a symposium on…anything related to climate change.”

Jen Raymond repeated the “inaccuracies with the date and location of the meeting.” She asked for an extension of time for comments. “The map was inaccurate,” she said. She also noted a lack of restriction on [the amount of] water withdrawal.

Rebecca Terpening said, “I care for the area I live in. The Cedar River is about a mile north of the well.” She questioned why the Public Notice was only in the Clare County Review. “It had the wrong day, the address incorrect. You should consider extending Public Comment (the deadline for written comments is Friday). In the future it would be helpful to have someone here from the DEQ to answer questions on water use.” She continued, “This area is the poorest in the county. Ground water use should be taken into consideration.”

Wayne Terpening said the Public Hearing should have be “advertised in the Gladwin paper since the [well] location is almost on the edge of Clare County” and the water flow is in that direction. “It is important that Gladwin be given an opportunity to have input into this [permit]…Our greatest concern is the safety of fresh water. It should also be the adequacy of drinking water. I challenge you to get someone to answer at the DEQ…I’m nor they can take this seriously. Oil production? What is the point? We have solar and wind power and electric cars.

Rex Raymond repeated the request to extend the time allowed for the public comment “based on the inaccuracies.”

Stephanie Terpening also said “The required comment [period] should be extended and there should be another Public Hearing. You are dealing with people who may not have cars or WiFi to be able to comment. I am feeling like it is very rushed with the publicity with incorrect time, date and location. Also keep in mind how impoverished people are in this area.”

Mary Ann Van Oosterhout said she echoed the request for an extended comment period and “more geographically appropriate notification. The well water we rely on is the thing that binds us all together. Safe water – we protect the access to that and the status of how it might affect the aquafer. I ask that you deny the request.”

Karen Turnbull, also a member of Citizens for Water Conservation of Mecosta, said there were 14 errors in the permit application including the omission of Decker Lake, the gas plant in Section 8 nearby, that the permit needs real data. “The permit should be returned to the applicant,” she said. “I am frustrated with the State of Michigan. In Michigan our water is not managed.”

Jeff Oosterhout of the MCWC said he was grateful for the information and the EPA representative’s willingness to answer questions. He said, however, in the first of five points that, “The MCWC feel you are permitting injection wells you are not able to monitor.”

He also said the area of the well was within 200 miles of an earthquake in 2015; that the problem with this well and Class II D wells is a finding by the U.S. Geological Survey that injection wells cause earthquakes.”

He noted that with [fresh] water withdrawal for this purpose with no limitations, “you are basically allowing draining of the aquafer. Four million people in Michigan draw their water from aquafers. You should not use fresh water…I’m not sure this is an appropriate use [of fresh water].”

Lastly he noted the condition of the application. “We need to have a close look at the application they submitted. It does have errors and inadequate information…it should be sent back to corrections of the errors and omissions in it.

Mary Pat Terpening said her concern is with the questions she has for the DEQ about the water.

The last speaker, Pamela Gilbert said, “The hot seat you’re in is on the social injustice issue. The townships with the largest need and the poorest townships are the most affected.”

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