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**Update: The public comment period for the Mountaineer natural gas liquid storage facility ended on February 6th, but the facility still poses a huge threat to our community and the five million people who drink from the Ohio River. That's why we're still calling state officials to demand a public hearing, fact sheet, and 60-day public comment period extension. The people who will be put at risk by this facility deserve more information about the risks associated with natural gas liquid storage. There simply wasn't enough info in the permit application to reasonably determine if Ohio Valley residents and the Ohio River would be protected from this dangerous project. The applications do not fully consider the possibility of contaminants migrating to underground sources of drinking water, and they include no real emergency response plan.
Please take a moment to share your concerns about the Mountaineer facility with Mary Mertz, Director of the Ohio Department of Natural Resources, and Ohio Governor Mike DeWine using the contact information below. Demand that they grant a public hearing for the Powhatan Salt Company's permit to create the salt caverns next to the Ohio River. Tell them that the ODNR and the public do not have enough information to be sure the public would be protected from this facility. Tell them we need a public hearing, a fact sheet and a 60-day comment period extension. If you're sending an email, make sure you use the subject line, No. SALT – 1 SMP #2, No. SALT 2 – SMP #3, and No. SALT – 3 SMP #4 to ensure your comment is heard. If you're calling, please leave a voicemail and if the mailbox is full, please keep trying until the mailbox is emptied.
Mary Mertz, Director of the Ohio Department of Natural Resources:
Call: (614) 265-1005
Mike DeWine, Governor of the State of Ohio:
Call: (614) 466-3555
Powhatan Salt Company LLC has applied through the Ohio Department of Natural Resources for three solution mining well permits to begin creating storage caverns in the Salina salt formation, just 2.5 miles north of Clarington, OH along the Ohio River in Monroe County, so that its sister company, Mountaineer NGL Storage LLC can store natural gas liquids (NGL) next to and potentially beneath the Ohio River.
The Mountaineer NGL storage facility would store natural gas liquids like ethane, propane, and butanes extracted from fracking, supporting the industry proliferation and increasing the massive amount of toxic, radioactive waste it generates. To create these storage caverns, Powhatan Salt Company would inject millions of gallons of fresh water underground at high pressures to carve out salt cavities. Powhatan would withdraw approximately 1,928,000 gallons of fresh water each day from the Ohio River to carve out the first storage cavern. More caverns could be constructed to increase storage capacity, each of which would require approximately 380,200,000 gallons of freshwater.
The Ohio Department of Natural Resources is currently reviewing Powhatan Salt Company’s application. Please submit your concerns and objections to this dangerous facility to the ODNR by February 6th, 2021. Below you will find a draft comment letter that can be edited and sent to the ODNR.
We believe the existing application materials for these wells do not contain enough information for anyone to evaluate the safety of these operations. The applications do not fully consider the possibility of contaminants migrating to underground sources of drinking water, and they include no real emergency response plan. How will we find out if the caverns leak? What will we do if they leak? Without a doubt, local residents will be the ones to suffer the consequences.
Feel free to use the draft comment letter below but if you are writing your own please note the following:
Please email your comments to ensure delivery by February 6th.
Subject line in email must read: Powhatan Salt Company solution mining well permit applications: No. SALT – 1 SMP #2, No. SALT 2 – SMP #3, and No. SALT – 3 SMP #4.
Request a public hearing, a 60-day comment period extension, and a fact sheet be prepared by ODNR so the public can fully understand the project implications and potential impacts.
Include any special knowledge on local geography, water use, surface structures and uses, or historical and present day practices- the ODNR may not have that information.
Comments should be clearly relevant to issues of public health and safety and substantive, but please write anything you feel called to write.
Reach out to CORR with any questions you might have!
When emailing the ODNR, please bcc: Concerned Ohio River Residents on the email at firstname.lastname@example.org so we can keep track of the comments.
Ohio Department of Natural Resources
Division of Oil and Gas Resources Management
2045 Morse Road, Building F-2
Columbus, Ohio 43229-6693
Comment Letter Template
ODNR Department of Oil and Gas Resources Management,
I urge the Ohio Department of Natural Resources’ Department of Oil and Gas Resources Management to deny the three solution mining well permit applications submitted by Powhatan Salt Company for the construction of solution mining wells No. SALT – 1 SMP #2, No. SALT 2 – SMP #3, and No. SALT – 3 SMP #4.
I reject the construction of solution mining wells that place our community’s public health and natural resources at risk. The site location for this facility is very problematic due to coal and oil and gas infrastructure in close proximity, including active fracking wells. The existing application materials for drilling these solution mining wells do not contain enough information for anyone to evaluate the safety of these operations. The applications do not include a detailed discussion of local geology and hydrology. As just one example, the application materials do not include the geometry of the salt formation, where the edge of the salt beds are, whether they are continuous, or variable, and their depth and thickness. ODNR cannot assess the safety of this project or potential impacts to underground sources of drinking water without this information. They also show no plan for continuous monitoring and geologic coring to keep up with cavern geometry. Monitoring of cavern geometry and integrity is critical to reducing safety risks. The applications also lack detailed information on drilling methods. This must be provided.
The application materials do not include a description of underground sources of drinking water, and the project’s area of review is too small to evaluate safety risks and risks to underground sources of drinking water. The area of review must be expanded to include an assessment of the potential for NGL migration and interaction with other nearby wells, including drinking water wells, old mining water wells, abandoned mines and shafts, and current hydraulic fracturing operations. The company must also present a substantial contingency plan to prevent underground sources of drinking water contamination in the event of a leak, well failure, or other emergency.
Powhatan Salt Company must demonstrate that the wells meet all safety standards and industry recommended practices for NGL storage in solution-mined salt caverns before any permit to drill can be issued. The current application materials do not show that these wells will comply with American Petroleum Institute’s Recommended Practices for the Design and Operation of Solution-Mined Salt Caverns Used for Liquid Hydrocarbon Storage (RP 1115). These recommendations cover well drilling, solution mining techniques, and monitoring and maintenance practices and were designed with public safety in mind. At the very least, the applications must show how these recommendations will be met. Air pollution, water contamination, and the risk of fires and explosions this facility presents endanger the health and safety of Ohio Valley residents. We deserve better.
I also request that a 60-day extension of the public comment period and a public hearing be granted. The community has many questions and must be granted a hearing in order to fully understand the project implications and potential impacts, and due to the COVID-19 pandemic, a 30 day public comment period simply isn’t enough time for the community that would be most impacted to become aware and have the opportunity to comment. I also request that a fact sheet be prepared. There is widespread public interest and concern regarding this facility and due to the above mentioned deficiencies of the application materials and because there is no mention of natural gas liquids in the public notice, a comment period extension, public hearing and fact sheet are necessary.
YOUR NAME AND CONTACT INFORMATION
Deficiencies in Powhatan Salt Company’s application:
Powhatan Salt Company has not proven it will not cause or allow the injection of contaminated fluid into an underground source of drinking water, as required by Ohio law.
There is no emergency shutdown plan included in the applications (this is a HUGE problem for NGL storage—the inability to get blowouts under control has been due to this lack in the past at least in the case of natural gas storage).
There is no planned mechanical integrity testing on the cavern prior to NGL storage included in the applications—this should be required to ensure safety.
There is no final plan for monitoring wells submitted with the application.
Powhatan Salt Company has not published a comprehensive plan to prevent leaks, well failures, or other drilling-related emergencies.
Powhatan Salt Company has only reviewed a quarter-mile radius around each of the three proposed injection wells, only just meeting the state’s minimum requirements. The company has not considered the effect drilling may have on nearby fracking operations, private wells, or population activities that lie outside the quarter-mile Area of Review and therefore cannot determine the safety of this project and the impact it could have on underground sources of drinking water.
Powhatan Salt’s applications do not show that the project will meet the American Petroleum Institute’s Recommended Practices for the Design and Operation of Solution-Mined Salt Caverns Used for Liquid Hydrocarbon Storage (RP 1115). These recommended practices were designed with public safety in mind.
The applications do not include a detailed discussion of local geology and hydrology. As just one example, the application materials do not include the geometry of the salt formation, where the edge of the salt beds are, whether they are continuous, or variable, and their depth and thickness. ODNR cannot assess the safety of this project or potential impacts to underground sources of drinking water without this information.
They also show no plan for continuous monitoring and geologic coring to keep up with cavern geometry. Monitoring of cavern geometry and integrity is critical to reducing safety risks. The applications also lack detailed information on drilling methods. This must be provided.
Below are some facts/risks on the NGL storage facility at large:
The Mountaineer NGL storage facility would store natural gas liquids extracted from fracking, supporting the industry proliferation and increasing the massive amount of toxic, radioactive waste it generates.
To create these storage caverns, Powhatan Salt Company would inject millions of gallons of fresh water underground at high pressures to carve out salt cavities. Powhatan would withdraw approximately 1,928,000 gallons of fresh water each day from the Ohio River to carve out the first storage cavern.
More caverns could be constructed to increase storage capacity, each of which would require approximately 380,200,000 gallons of freshwater.
Once freshwater is injected underground, it would turn into a salty brine that could no longer be used for agriculture, drinking water, or recreation. The brine would be sent about 3.5 miles south to Westlake Chemical for processing.
At least three pipelines would carry brine and natural gas liquids beneath the Ohio River, creating a risk of explosions and contamination of the river - the drinking water source for 5 million people - with salty brine. A map is included with this fact sheet to show the pipeline routes and associated infrastructure.
An enormous brine reservoir would be constructed near the bank of the Ohio River to pressurize the storage caverns as the natural gas liquids are removed. Brine from this reservoir could contaminate underground sources of drinking water or the Ohio River, potentially compromising the river once again.
If built, the storage facility would likely only permanently employ up to 12 workers.
Economists believe that the PTTGC ethane cracker plant proposed for Dilles Bottom would need the Mountaineer facility in order to operate. The cracker plant has been indefinitely delayed and the company is doing a feasibility study that is supposed to be completed by June of this year. Even if the cracker plant is never built, Mountaineer is still proposing to operate and do business with other companies needing NGLs in the Valley.
The facility could also potentially encourage “bomb trains” filled with highly explosive and flammable natural gas liquids to run through our communities.
NGLs are highly flammable and costly to manage, store, and transport. A plume of NGLs poses a particular risk because the vapor is heavier than air, hence, releases from the storage facility would hover in the valley polluting communities along the Ohio River and creating risk of explosions.
Despite Mountaineer NGL Storage Company’s recently announced plans to pursue “carbon-free” hydrogen storage, this project as proposed would still contribute to a worsening climate crisis. Any hydrogen stored at Mountaineer will, for the present and for many years into the future, not be green. The hydrogen Mountaineer stores will be manufactured using fossil fuels and will not reduce greenhouse gas emissions. As for the question of whether Mountaineer will ever store real green hydrogen, that will depend on the development of new businesses and production capabilities that at present aren't even on the drawing board for the region. Also, Mountaineer has said nothing about scrapping its plans to store hazardous natural gas liquids produced from fracking in its caverns.
There are no known existing sources of hydrogen in the region, or even any “green” projects to create hydrogen from water using electrolysis and renewable energy sources. Even if there was, storing it creates additional hazards for people who live in the area.
Natural gas liquid storage facilities can have significant flaring episodes with excessive emissions that can cause negative health impacts. Researchers note that gas flaring “is a prominent source” of carbon monoxide, carbon dioxide, sulfur dioxide, polycyclic aromatic hydrocarbons, smog-forming volatile organic carbons (“VOCs”), nitrogen oxides and soot.
Other underground storage facilities have seen serious and even deadly incidents caused by inadequate regulation, including fires, explosions, chemical leaks, earthquakes, and sinkholes. How can we be sure a similar disaster wouldn't happen to Mountaineer?
Three people were killed and 21 more were injured after an uncontrolled release of dense petroleum gas exploded at the salt-dome storage cavern near Brenham, Texas, in April 1992.
In January 2001, two people died and two businesses were destroyed after natural gas escaped from a failed wellbore near Hutchinson, Kansas, and exploded through an abandoned well nine miles away.
More than 5,000 households were displaced due to severe health concerns when a methane leak near the Aliso Canyon went uncontained for four months. The incident, the result of an aging, failed well repurposed for natural gas storage, was the largest leak from an underground storage facility in U.S. history.
The Bayou Corne sinkhole was created from a collapsed underground salt dome cavern operated by Texas Brine Company and owned by Occidental Petroleum. The sinkhole, located in northern Assumption Parish, Louisiana, was discovered on August 3, 2012 and hundreds of area residents were ordered to evacuate and the order wasn’t lifted until 2016. The sinkhole grew in size for years to about 34 acres.