Comment Today on Trap Hill UIC: No Frack Waste Underground Injection

The Beckley Register-Herald reports: “A Department of Environmental Protection permit application renewal for an underground injection control well used to dispose of oil and natural gas waste in the Trap Hill area of Raleigh County is open for public comment through Jan. 21.” More details on the UIC here.

Note that the commissioners of neighboring Fayette County banned this type of waste “disposal” just 48 hours before this permit renewal was published.

Comments on the Trap Hill UIC permit are due today. Please use the information below, provided by Friends of Water, as a template to create your own comments. Feel free to copy and paste the info, while of course adding your name and hometown instead of the names below. Submit your comment to both the WVDEP, as well as the Raleigh County Commission. Share with anyone who might help, especially residents of Raleigh County! Remember, if you individualize the comments, they will have a greater impact.

Comments should reference Permit No. UIC2D0810281.

Mail comments in writing to WV Department of Environmental Protection, Office of Oil and Gas, UIC Comments, 601 57th St. SE, Charleston, WV 25304 or Justin.E.Nottingham@wv.gov.

Comments may also be faxed to 304-926-0452, with “UIC Comments” in the subject line.

At this DEP webpage you can access the draft permit, a fact sheet and the permit application.

Please mail a copy of your comments to the Raleigh County Commission, 116 1/2  N. Heber St., Beckley, WV, 25801, or ralcom@raleighcounty.com.

Sample Comment

West Virginia Department of Environmental Protection, Office of Oil and Gas
ATTN: Justin Nottingham, UIC comments
Justin.E.Nottingham@wv.gov

Public Hearing Request for UIC 2D0810281

My name is Chris Hale, with Friends of Water. I am a resident of Raleigh County. I am concerned for the health and safety of my family, friends, and all residents of Raleigh County. I am demanding a public hearing for UIC2D0810281.

I am aware that many residents feel the need for a public hearing concerning this permit in the Trap Hill district.  Numbered below are some of my concerns and the concerns of other residents in Raleigh County. I expect a concise response from the WVDEP to every question and comment that I have listed below.

In UIC 2D0810281 permit application, in Section 5: Description of the Injection Zone, it states that the Weir Must Be hydraulically fractured.  If this is the case, is it completely legal to hydraulically fracture a Class II UIC?  If Base Petroleum plans on hydraulically fracturing UIC2D0810281, then they are required to get a hydraulic fracturing permit?

If Base Petroleum plans on hydraulically fracturing the Weir Sandstone, then in addition to a hydraulic fracturing permit, they need to provide a new permit application including updated physical characteristics of the Weir Sandstone.  The WVDEP should also write a new draft permit based on the updated physical characteristics of the Weir Sandstone after Fracturing.

How does the WVDEP methods of handling, storing, and disposing of Technologically Enhanced Naturally Occurring Radioactive Material TENORM chemicals compare with Nuclear Regulatory Commission methods of handling, storing, and disposing of TENORM chemicals?

What does the WVDEP consider the pathways of endangerment to underground source drinking water from Underground Injection Control 2D0810281?

Is there a satisfactory confining layer to hold TENORM chemicals, volatile organic compounds (VOCs), and all other materials that pose a risk to human health associated with oil and gas production?  Is this UIC capable of containing these chemicals for thousands of years due to the alarming amount of Radium 226 and Radium 228 with a half-life of 1,600 years that is associated with shale gas waste?

Define the physical characteristics of all confining layer(s) that the West Virginia Department of Environmental Protection is depending on isolating the Weir Sandstone from other above and below geology.

Define the confining layers also in terms of depositional environment. Is there a possibility of stratigraphically connected porous facies that shorten the distance between injected waste in the Weir Sandstone and underground source drinking waters?

Can the WVDEP define the confining layers responsible for isolating fluids in the Weir sandstone from above geologic units in terms of permeability and porosity, more specifically total porosity, naturally occurring fracture zone porosity, and artificially produced fracture zone porosity?

Citing the MacCrady Shale as the confining layer for the Weir Sandstone implies that the Big Injun Sandstone is also going to be holding this waste. This is contrary to the specific injection zone limited to the Weir Sandstone in the permit and permit application.  If the MacCrady Shale is the confining formation for UIC2D0810281, then the permit and permit application should include all stratigraphic units between the Weir Sandstone (the current target injection zone) and the MacCrady Shale.

If there is any naturally occurring or manmade (well bore, abandoned mines) fracture zone porosity values available from the Weir Sandstone to the MacCrady Shale? Where are these areas with fracture zone porosity and do they pose a threat to surface and groundwater drinking sources?

Given that Dr. Avner Vengosh has reported contamination consistent with oil and gas production in surface waters in Fayette County, has the WVDEP made any efforts to incorporate the parameters tested for by Dr. Vengosh in testing requirements for Class II UIC facilities?

Why is it that there is no requirement for Radium testing in UIC2D0810281 permit and permit application?  Given that tests for Class II injectate show combined radium 226 and radium 228 at levels over 3,000pCi/L . Three thousand picocuries per liter is 600 times safe drinking water limits and 50 times allowable concentrations of combined radium 226 and radium 228 in industrial effluent for any other industry, according to standards set forth by the Nuclear Regulatory Commission.

Given that the WVDEP has the information mentioned in UIC2D0810281 and chooses not to require any Radium 226 and radium 228 testing for Class II UICs across the state, how am I supposed to believe that the WVDEP is using the best available technology to protect the health and safety of residents and the environment?

Can the WVDEP demonstrate accurately that the above ground storage tanks included in UIC permit 2D0810281 are capable of completely isolating the VOCs contained inside the tank from the air outside of the tank?  Keep in mind that VOCs, toxic in parts per trillion, are commonly associated with modern unconventional Oil and Gas waste.

Signed,

Your Name and Address

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