To: David Dunaway, Patrick Adams, Jerry Smit, and Matt Ivers, UIC Rulemaking Team
Regulations for Underground Injection Control (UIC) Program in Arizona
I, the undersigned hereby petition the Underground Injection Control (UIC) Program administrators or committee members of Arizona Department of Environmental Quality (ADEQ) to look at and adhere to the proposed guidelines and regulations for the safe monitoring of “produced water” and brine/saline water injection in the state of Arizona. Data continues to reveal the potential hazards and ensuing guidelines for safer practices set up for safeguarding the health and well-being of the average citizen, his/her land, livestock, the surrounding areas and environment. It is paramount that this be taken into serious consideration.
The potential harm to the inhabitants and the environment from the practice of injection of “produced water” is complex and potentially very severe both in short and long term consequences. The knowledge of these potential hazards is continuing to become evident and guidelines and safer practices to ensure the health and well-being of the average citizen, his/her land, livestock, the surrounding areas and environment need to be taken into serious consideration.
We are submitting guidelines as a community to the UIC that must be implemented in the case that injection of “produced water” and brine/saline flowback is allowed. It is mandatory that the health, resources, land, and quality of life in Arizona is protected first and foremost. As a state agency we feel it is your primary responsibility to the people, to protect their health,well-being and future viability across the state. It is imperative that your agency first consider human safety and review the precedence set forth by other states in establishing their regulations as a result of the negative impacts upon the water, air, soils, climate change, health and social degradation resulting from hydraulic fracturing practices within the past 5-10 years. As a state agency we feel the first responsibility of this agency is to the people of Arizona, their health and well-being and future viability here in the state of Arizona. We ask that you consider safety first and look at what other experienced states are doing with their regulations as a lot of painful learning experiences have happened in the last 5-10 years. Our aquifers and water supply are a precious and life sustaining resource that cannot be replaced or renewed after damage and contamination occur.
This is by no means a total or complete list of what needs to be included in state regulations but a start as we look at underground injection regulations in the state of Arizona with guidelines and monitoring by the UIC.
We are requesting for you to implement the recommendations for the UIC listed below:
• The burden of proof of any well water contamination be placed on the companies injecting “produced water” or stiff foam into the ground to ensure that well and drinking water is not contaminated. The company must pay for and obtain 3rd party testing on five separate sites within ½ mile of each proposed well site before the well is dug. Repeat testing of the same sites needs to be completed at three month intervals after the well is dug and activity has commenced, with the results disclosed to the company, UIC, the public and each well owner. This would help allow early identification of any contamination at these sites and allow appropriate measures to be taken at this time and prevent widespread and severe contamination.
• Air and groundwater studies and testing must be paid for by the companies injecting “produced water” and/or brine/saline water before any drilling starts in a given area. Every three months repeat studies must be completed to monitor for any negative changes. This again would allow for early identification of any contamination at these sites and allow appropriate measures to be taken at this time and prevent widespread and severe contamination. A complete list of tests to be conducted must be further researched. Precedence has been set across the nation and resources are available on this subject.
• ALL chemicals intended for underground injection purposes must be disclosed before any disposal begins.
• Potential contamination of the surrounding areas to a wellhead need to be tested at 30 day intervals.
• With this disclosure a ban on using hydrofluoric acid is requested as the toxicity and hazards have been extreme in other states.
• If any contamination is found, drilling must stop immediately, a spill and contamination report must be filled out and report made to the UIC supervisor and posted online for the public to view.
• The company will be responsible for ALL costs in cleaning up and any and all damages that result from this spill. This can be addressed further in the “Financial Assurance and Environmental Response Funds” section listed in the next bullet point of this document.
• All companies must set up and maintain a “Financial Assurance and Environmental Response Fund” prior to any permits being issued to a comp...
The potential harm to the inhabitants and the environment from the practice of injection of “produced water” is complex and potentially very severe both in short and long term consequences. The knowledge of these potential hazards is continuing to become evident and guidelines and safer practices to ensure the health and well-being of the average citizen, his/her land, livestock, the surrounding areas and environment need to be taken into serious consideration.
We are submitting guidelines as a community to the UIC that must be implemented in the case that injection of “produced water” and brine/saline flowback is allowed. It is mandatory that the health, resources, land, and quality of life in Arizona is protected first and foremost. As a state agency we feel it is your primary responsibility to the people, to protect their health,well-being and future viability across the state. It is imperative that your agency first consider human safety and review the precedence set forth by other states in establishing their regulations as a result of the negative impacts upon the water, air, soils, climate change, health and social degradation resulting from hydraulic fracturing practices within the past 5-10 years. As a state agency we feel the first responsibility of this agency is to the people of Arizona, their health and well-being and future viability here in the state of Arizona. We ask that you consider safety first and look at what other experienced states are doing with their regulations as a lot of painful learning experiences have happened in the last 5-10 years. Our aquifers and water supply are a precious and life sustaining resource that cannot be replaced or renewed after damage and contamination occur.
This is by no means a total or complete list of what needs to be included in state regulations but a start as we look at underground injection regulations in the state of Arizona with guidelines and monitoring by the UIC.
We are requesting for you to implement the recommendations for the UIC listed below:
• The burden of proof of any well water contamination be placed on the companies injecting “produced water” or stiff foam into the ground to ensure that well and drinking water is not contaminated. The company must pay for and obtain 3rd party testing on five separate sites within ½ mile of each proposed well site before the well is dug. Repeat testing of the same sites needs to be completed at three month intervals after the well is dug and activity has commenced, with the results disclosed to the company, UIC, the public and each well owner. This would help allow early identification of any contamination at these sites and allow appropriate measures to be taken at this time and prevent widespread and severe contamination.
• Air and groundwater studies and testing must be paid for by the companies injecting “produced water” and/or brine/saline water before any drilling starts in a given area. Every three months repeat studies must be completed to monitor for any negative changes. This again would allow for early identification of any contamination at these sites and allow appropriate measures to be taken at this time and prevent widespread and severe contamination. A complete list of tests to be conducted must be further researched. Precedence has been set across the nation and resources are available on this subject.
• ALL chemicals intended for underground injection purposes must be disclosed before any disposal begins.
• Potential contamination of the surrounding areas to a wellhead need to be tested at 30 day intervals.
• With this disclosure a ban on using hydrofluoric acid is requested as the toxicity and hazards have been extreme in other states.
• If any contamination is found, drilling must stop immediately, a spill and contamination report must be filled out and report made to the UIC supervisor and posted online for the public to view.
• The company will be responsible for ALL costs in cleaning up and any and all damages that result from this spill. This can be addressed further in the “Financial Assurance and Environmental Response Funds” section listed in the next bullet point of this document.
• All companies must set up and maintain a “Financial Assurance and Environmental Response Fund” prior to any permits being issued to a comp...
Why is this important?
My family draws our household water from the Coconino Aquifer, which is at risk unless the ADEQ effectively regulates toxic flowback and brine in waterways, wells and aquifers. Community health should not be jeopardized for the convenience of industrial wastewater producers.