Laserfiche WebLink
According to the applicant, the water will be stored in "Baker" tanks, metal storage tanks <br />provided by BakerCorp. BakerCorp rents the tanks for storage of a wide range of fluids <br />generated by industrial operations, wastewater facilities, environmental remediation <br />firms, refineries, and others. Baker tanks are used to store everything from storm runoff <br />to sewage. Water contaminated with dirt, petroleum products, antifreeze, sludge, mine <br />wastewater, and various hazardous wastes are stored in Baker tanks. <br />The applicant proposes to rent Baker tanks to store about 200,000 gallons of pump test <br />water. The applicant says the tanks will be steam-cleaned before being used to store <br />water from the Fox Hills aquifer. The draft permit does not require inspection of the <br />interior surfaces of the tanks prior to use by the applicant. <br />After the tanks are filled and closed and the pump test is completed, the applicant is <br />required to provide EPA with summary results of the pump test. After reviewing the <br />results, the EPA decides whether to authorize the injection. For some undetermined <br />period of time, the water will sit in the tanks. The draft permit does not allow the <br />addition of a disinfectant, such as sodium hypochlorite, to the stored water to prevent <br />growth of bacteria or other organisms. <br />Any injection permit issued to the applicant, as a condition for authorizing injection, <br />should require full physical, metallurgical, chemical, radiological, and bacteriological <br />testing and analysis of the injectate after storage in the Baker tanks. Authorization to <br />inject should be withheld if any previously-tested constituents exceed baseline, or if any <br />previously-untested substances exceed federal drinking water standards or are determined <br />to endanger public health. <br />Further, all sampling, testing, and analysis should be done by independent consultants <br />and labs under the direction of an independent party. <br />To conclude, I urge the EPA to deny a final permit for this proposed injection well <br />because of the serious deficiencies and potential problems noted in these comments. <br />I hereby incorporate by reference all of the public comments submitted in this comment <br />period, to the extent such comments address issues or detail facts or evidence not <br />included in my comments. <br />Sincerely, <br />James B. Woodward <br />7