No NGL Storage Next To The Ohio River.
Chief Eric Vendel, Ohio Department of Natural Resources Division of Oil and Gas Resources Management
The Mountaineer Storage Facility Puts Ohio Valley Communities at Risk. ODNR Doesn't Seem to Care.
This February, more than one thousand community members contacted the Ohio Department of Natural Resources to submit their concerns about Powhatan Salt Company's permit applications to begin constructing the Mountaineer NGL storage facility, which would store flammable, highly explosive natural gas liquids in salt caverns next to the Ohio River. (Read more about the risks of natural gas liquid storage here.)
Legal experts also outlined fifty-eight technical deficiencies with the solution mining well applications, pointing out their failure to prove the wells would meet all safety standards and industry-recommended practices for NGL storage in solution-mined salt caverns.
Yet, despite overwhelming public concern and glaring technical deficiencies in the company’s application, on March 11, 2021, the Ohio Department of Natural Resources (ODNR) issued a draft permit to Powhatan Salt Company. The official draft permit addressed only eight of the fifty-eight concerns raised by legal experts. Forty-two comments on the safety and technical integrity of the proposed solution mining wells received absolutely no response from ODNR.
The comments ignored by ODNR included concerns about the project’s Area of Review and its proximity to underground sources of drinking water. Even after ODNR completed a full review of Powhatan Salt Company’s permit application and issued the company an official draft permit, there is still no proof that the company’s injection wells will not cause or allow the injection of contaminated fluid into an underground source of drinking water, as required by Ohio law. Moreover, ODNR has not responded to concerns that the company has only reviewed a quarter-mile radius around each of the three proposed injection wells, only just meeting the state’s minimum requirements. It’s clear that neither state agencies nor Powhatan Salt Company have adequately considered the effect drilling may have on nearby fracking operations, private wells, or population activities that lie outside the quarter-mile Area of Review. Consequently, it’s impossible to determine the safety of this project and the impact it could have on underground sources of drinking water.
ODNR’s failure to respond to -- or even acknowledge -- dozens of technical deficiencies with Powhatan Salt Company’s solution mining well permits undercuts our right to transparent public information about this project and jeopardizes the health and water access of the five million people who rely on the Ohio River for drinking water.
How can state regulatory agencies issue permits if they are unable to respond to expert comments on the integrity of these injection wells? We demand ODNR hold a public hearing to address community and expert concerns with this project. Until our comments are acknowledged and answered, ODNR should not issue a final permit to Powhatan Salt Company.
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To:
Chief Eric Vendel, Ohio Department of Natural Resources Division of Oil and Gas Resources Management
From:
[Your Name]
Subject: Public comment on Powhatan permit applications Salt-1, Salt-2, Salt-3
Dear Chief Vendel,
The construction of proposed injection wells for the Powhatan Salt Company, LLC, places the individual health, drinking water, and the environment at risk of considerable harm for Ohioans and West Virginians.
The Ohio Department of Natural Resources must institute the minimum safety standards as outlined in the American Petroleum Institute RP 1115 applicable to these permit applications. This recommended practice is driven by accumulated knowledge and experience in this industry and covers geological assessments, well design, techniques and operations, as well as monitoring and maintenance, with a goal of long term integrity and safety.
Even after the issuance of a draft permit, there is still no proof that the company’s injection wells will not cause or allow the injection of contaminated fluid into an underground source of drinking water, as required by Ohio law. Expert concerns that the company has only reviewed a quarter-mile radius around each of the three proposed injection wells, only just meeting the state’s minimum requirements, have not been addressed. Insufficient attention has been given to the effect drilling may have on nearby fracking operations, private wells, or population activities that lie outside the quarter-mile Area of Review. Consequently, it’s impossible to determine the safety of this project and the impact it could have on underground sources of drinking water.
The draft permit for this drilling activity does not contain enough information for anyone to evaluate the safety of these operations. The site location for this facility is very problematic due to coal, oil, and gas infrastructure in close proximity. This increases the likelihood of a severe catastrophe. The draft permit does not include a detailed discussion of local geology and hydrology and does not consider the potential threats to underground sources of drinking water and the nearby Clarington water supply. Moreover, there is no substantive contingency plan for Powhatan Salt Company to respond in the event of a leak, well failure, subsidence, or other emergency. Air pollution, water contamination, and the risk of fires and explosions this facility presents endanger the health and safety of Ohio Valley communities. Providing the public with reassurance that the agency is implementing measures that provide a safe environment in which people live and work should be ODNR’s top priority. We deserve better.
We request that the “Area of Review” for the siting of these projects be expanded from one quarter of a mile to eight miles to capture other potential hazards, including but not limited to; well migration and risk of toxic chemical contamination of surface and drink water supplies. We demand the Safety of Underground Natural Gas Storage Facilities rules and regulations promulgated by the Pipeline and Hazardous Materials Safety Administration and made effective on March 13, 2020, as well as the American Petroleum Institute recommendations API RP 1115 be applied to any permits under consideration. And due to the grave threats this project poses to local communities, we urge ODNR to refrain from issuing any final solution mining well permits to Powhatan Salt Company.
This project has been treated with unfair opacity by our state regulatory agencies and the industry itself, and local communities have substantive questions that have yet to be answered. To that end, we request ODNR hold a public hearing to address community and expert concerns with this project. The public comments need to be acknowledged and answered. ODNR should not issue a final permit to Powhatan Salt Company.