Why I Oppose Montana Renewable’s EPA Wastewater Permit
By Lisa Schmidt For WTF406
I raise cattle and sheep on my ranch that, fortunately, has 16 natural springs. Those springs are vital to my livelihood so I protect them fiercely. Contamination of the groundwater would cause irreparable harm to my natural resources and livelihood. Montana Renewables, a subsidiary of Calumet, produces biodiesel in Great Falls. The most efficient method to dispose of the wastewater is to treat it at the refinery. No-brainer.
Instead, the company currently trucks the wastewater 85 miles to load it on railcars and haul it to out-of-state waste sites. This is a temporary disposal plan. Montana Renewables has contracted with Montalban Oil and Gas Operations, hoping to inject that wastewater into two abandoned oil wells at the end of a gravel road 91 miles from the refinery and about five miles as the crow flies from my springs. These wells are within a half mile of Dupuyer Creek, which flows into Lake Francis. Lake Francis is the source for drinking water in Conrad, Valier and Brady, along with irrigation water for 77,000 acres of cropland.
To inject wastewater, owner Patrick Montalban needs a Class V permit from the Environmental Protection Agency. I’m concerned about this plan for three important reasons.
First, Montalban’s permit application describes the injectate materials as “including, but not limited to” vegetable oils and animal fat, among others. In other words, anything could go down those wells. Montana Renewables has never provided comprehensive test results of the wastewater to the Pondera County commissioners, Great Falls water treatment managers or the public, despite repeated requests.
A basic test of potential wastewater reveals that it is contaminated with trace amounts of arsenic, barium and lead, among other things, along with sky-high levels of salts and phosphorus. Water treatment managers normally treat water that contains 3 to 5 parts per million of phosphorus. Montana Renewables wastewater contains 250 ppm. Water treatment managers estimate rates would have to increase by $3 million to $4 million each year if they had to pull that much phosphorus from the water they treat.
Second, the permit application states that 171 times more material will be injected under pressure into the ground than was originally removed. Two containment layers of rock are supposed to maintain separation between the injectate and groundwater. Those layers are limestone and shale. Limestone is known to crack under pressure and shale is only semi-permeable, not impermeable, under pressure.
The permit application requires monitoring with the quarter-mile Area of Review. But Montalban and Montana Renewables corporate officer Bruce Fleming note that the Madison sandstone layer where they want to inject materials runs from Canada to North Dakota, so they have lots of space to fill with contaminated wastewater. But the Madison layer is also a source of groundwater past the quarter-mile, monitored Area of Review. Either the injectate remains within a quarter mile of the wells and builds incredible pressure or it is allowed to flow beyond the Area of Review and potentially contaminate groundwater.
Third, Fleming says people can drink this wastewater. This declaration that people can drink wastewater that contains more than 50 times the amount of phosphorus is only true because the federal government doesn’t have a drinking water standard for phosphorus, yet water treatment plants are required to remove it. Excessive phosphorus can cause diarrhea and hardening of organs and arteries. Fleming is not quite lying, but he certainly is not answering questions in the public’s best interests or being transparent about the process. One has to wonder why.
Montana Renewables has developed an exciting new process to produce biodiesel. They have a unique opportunity to demonstrate to the entire world how to handle wastewater the right way. They should embrace that opportunity.
The deadline for comments to the EPA is February 15.
Learn more at https://www.epa.gov/uic/mogo-jody-field-34-1-34-2-disposal-well-glacier-county-montana-permit-s-mt52443-12513-mt52439