Comment deadline 2-6-21: Call for ODNR Public Hearing and comment extension on dangerous saltcavern industrial permit

Speak out now for our rights to a safe region and planet! Write ODNR to oppose Powhatan (Mountaineer) underground salt cavern industrial storage immediately adjacent to the Ohio River!

Please demand a public hearing and extension of the comment period.  Comments due Feb. 6.

Powhatan Salt Company LLC has applied to the Ohio Department of Natural Resources for three Class 3 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. The storage caverns will initially be used to produce brine from the Salina formation 6,000 feet below the surface. The brine will be piped under the Ohio River to Natrium, WV, to a chemical plant, which produces chlorine from brine.

To create these storage caverns, Powhatan Salt Company would inject millions of gallons of freshwater underground at high pressures to carve out cavities in the salt. Powhatan would withdraw approximately 1,928,000 gallons of freshwater each day from the Ohio River to carve out the first cavern. More caverns could be constructed to increase storage capacity, which could require withdrawal of approximately 380,200,000 gallons of freshwater.

The application does not disclose that, as Powhatan Salt Co. LLC and its sister company Mountaineer NGL Storage LLC have stated in numerous news stories, they have actually intended to use the caverns for the storage of natural gas liquids like ethane, propane, butanes and possibly hydrogen extracted from fracking. This use not only creates additional explosive and contamination hazards but also supports proliferation of fracking and its climate impacts and increases the massive amount of toxic, radioactive waste generated by this industrial process. Ohio Underground Injection Control (UIC) Class 3 permitting does not require modification of the permit even if this drastic change of use occurs.

Please speak out now, by writing to ODNR, to help prevent this assault on our region and our climate. Please demand a public hearing based on the significant health, environmental, and safety concerns of this project. Tell ODNR that, given these substantive health, safety, and environmental concerns, they must provide the opportunity for the people of the region to share our concerns in a public forum where people can hear one another and learn about the issues involved.

The Ohio Department of Natural Resources is currently reviewing Powhatan Salt Company’s application. The public has until Feb. 6 2021 to submit comments. Please submit your concerns and objections to this dangerous facility by February 6th to:

Ohio Department of Natural Resources Division of Oil and Gas Resources Management , 2045 Morse Road, Building F-2, Columbus, Ohio 43229-6693

Important to include: RE: UIC Well Applications Powhatan Salt Company LLC Salt-1 Salt-2 and Salt-3

or e-mail: oilandgas@dnr.ohio.gov

Sample letter.  Please personalize!

Re: UIC Well Applications Powhatan Salt Company LLC Salt-1 Salt-2 and Salt-3

To ODNR Director Mary Mertz and Division Oil and Gas Chief Eric Vendel:

The Ohio Department of Natural Resources’ Department of Oil and Gas Resources Management must 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.

The construction of solution mining wells will place our community’s public health and safety and natural resources at risk. Powhatan Salt Company’s (PSC) application is woefully lacking in information for the public to evaluate. Therefore, I demand a public hearing so the public can learn of and respond to the important issues raised therein in a public forum.

The following concerns are of such gravity and concern that Chief Vendel must hold a public hearing to address these substantive health, safety, and environmental issues, per OAC 1501:9-7-07 H(4)(c). I also call on the Chief to extend the comment period 60 days in order for the public to have adequate time to review the not yet available required fact sheet. A few of many significant issues regarding substantive health, environmental, and safety concerns:

  • The area of review on the map clearly shows a Class V well in the area of review, which is not identified by PSC in the application and which could be a conduit for whatever ends up in the caverns contaminating drinking water or groundwater supplies through breaches in the Class V well.
  • There are no monitoring wells indicated for the solution mines, which are necessary to detect any migration of toxic materials, and there are no seismic monitoring requirements to determine potential breaches of supposed containment. There is no emergency shutdown plan included in the applications. This is a significant problem both for brine, which could contaminate the drinking water of millions downstream, and for potential natural gas liquids (NGL) storage, which could likewise contaminate the drinking water of millions as well as cause blowouts immediately jeopardizing the lives of thousands in the region, either directly or by resultant hazardous air pollution. The inability to get blowouts under control is often due to lack of such monitoring.
  • Earthquakes are known throughout southeast Ohio, especially in recent years. A facility of this magnitude, with millions of gallons of water a day being injected under high pressure, and millions of gallons of either salty brine or, potentially, highly toxic NGLs could cause a disaster affecting millions of people in the region. ODNR must require Applicant to prove this cannot happen, because the public’s safety and health are in jeopardy.
  • There is no mention of the many abandoned underground mines throughout the area of the proposed caverns. There is no mention of fracking operations of CNX Gas LLC, which has a lateral within a ½ mile of the cavern site. How will the health and safety of the people near the operation not be jeopardized when the possibility of subsidence, conduits, and migration thus threaten the area?
  • Ohio law and rules do not require notification if the company changes its storage of river water to storage of NGL’s, which is what the project was intended to be several years ago. This is complete obfuscation from both the company and DOGRM! The public will not know that highly volatile liquid gas products will be transported through Southeast Ohio and stored in their community or upstream of their drinking water supplies. The company has no contingency plans for disasters. How does this NOT jeopardize public health and safety? This is one of many examples of the inadequacies and incompleteness of the application that require the chief to hold a public hearing under OAC 1501:9-7-07 H(4)(c).
  • Moreover, when Applicant converts the solution-mining caverns to create Applicant’s previously planned underground NGL storage, assuming the NGL storage will have a direct or an indirect connection to the interstate NGL pipeline network, a certificate of public convenience and necessity issued by FERC will be required.  Receipt of that certificate should be made a permit requirement to be satisfied prior to conversion of the caverns created by solution mining to an underground storage facility. How will this be accomplished if there is no notification required of such a conversion?
  • The fact sheet required in OAC 1501:9-7-07 H(3)(a) does the public no good after this comment period and should be available to be commented on now. In that regard, the public comment period should be extended 60 days in order for the public to have adequate time for its review and use it to prepare for a public hearing.

Sincerely,

YOUR NAME, COUNTY, STATE, and CONTACT INFO

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