Rapid Response ACTION!!!!!! From Michigan Citizens for Water Conservation (MCWC)

A new potash solution-mining operation is planned near Hersey in Osceola County, just 8 miles south of the Nestle’ water withdrawal from Production Well PWE101 in Evart. This operation will consume tremendous quantities of water, starting with 1200 gallons per minute.!! This project threatens the surface and subsurface water from an extensive network of pipelines transporting toxic brine solutions containing hydrocarbons, over a highly sensitive terrain of complex wetlands.!!So far Michigan Potash Operating, LLC has leased approx. 15,000 acres, and the draft permits cover 6000 acres. The toxic brines will be carried through pipelines that pose a threat to the numerous surface waters and shallow aquifers feeding into the nearby Muskegon River.!!

MCWC requests that you:
1) Send an Email to ASK the EPA for a 14BDAY extension for the “Open House Q&A and Public Hearing”. We ask when you write about the time extension to only mention needing more time during holiday season for you to understand this Permit. Take this Action THIS WEEK or ASAP.

2) REQUEST that you COMMENT to the EPA in an email or post office mailing your OPPOSITION to 3 Class I injection wells for disposal of “nonhazardous liquid waste” from solution mining operations and 8 Class III injection wells used to conduct solution mining of salt and potash.!!You can use the Talking Points below. Take this Action before January 4th.

Class I Wells: Allan Batka – batka.allan@nullepa.gov
Class III Wells: Janette Hansen, L.P.G. – Hansen.janette@nullepa.gov

U.S. EPA, Water Division
UIC Branch (WUE16J)
77 W. Jackson Blvd.
Chicago, IL 60604-3590

Talking Points:
● The amount of water that Michigan Potash Operating, LLC will use must be substantial to require 3 high capacity Class I disposal wells. The company has not revealed how much water or where it will come from. Every drop of toxic brine that’s injected down the wells starts out as a drop of fresh water taken from our aquifer.

● The timing of this is terrible during the holiday break. This does not give residents and people in Michigan enough time before the Public Hearing to study the amount of water being turned to toxic brine for this potash mine operation. There is also incomplete information in the application.

● The initial application should have been part of a Dual-Permitting Process between the EPA and DEQ, which is not being adhered to. Because of this, no environmental studies have been produced.

● A big concern of the Injection Wells is upward migration of toxic brines that can invade our drinking water aquifers through older oil, gas, and water wells in the Area of Review (AOR). A large number of old oil and gas wells have been identified by MCWC within the 4 townships involved, and were mailed to the EPA for both counties (Osceola County, 67 wells, and Mecosta County, 66 wells).

● The EPA has already reviewed these wells and is not worried about a migration of toxic brine.

● MCWC has reasons to wonder about this because of lack of records of these old wells as many were poorly plugged and are rotting away. The EPA is not concerned about shallower wells, only the deepest ones (over 4000 feet) that penetrate the “confining zone.”

● We asked the EPA if the confining layer was free of cracks or fissures, which could allow wastes to pass through it. They said there were NO cracks or fissures based on 18 small holes drilled inside of a 4Emile diameter circle. The odds of encountering a crack with any one of these holes would be minuscule. MCWC is concerned that if wastes can travel up to 2 miles horizontally (AOR) and then move up thru an old, leaky well-bore, then they could just as easily migrate that same distance vertically, (including upwards), thru any flaw in the confining layer.

● We believe that the EPA has a Responsibility under the Clean Water Act to protect our aquifers from depletion or contamination from injection wells including surface handling of toxic brines over unprotected aquifers. MCWC is concerned about this.

Almost no information on the 8 Class 3 (mining) Wells was sent out. We would like to know the exact well locations, since that area includes many wetlands, watercourses, springs, and shallow, unprotected aquifers.

● The mining of potash in Michigan has not been successful in the past, and there is a glut of potash on the market right now, which has driven prices down. MCWC has concerns about the injection wells for this reason. If “potash mining” doesn’t work – what will be the purpose of these injection wells?