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TexCom CEO hopes to dispel ‘misinformation’ on injection well


TexCom’s injection well, shown to scale compared with existing Class 2, brine disposal wells in the same field and drinking wells that extend into the aquifers. The company’s officials say the clay-like Jackson shale layer would keep the injected water from seeping into the water supply.

By JAKE MUONIO
Updated: 08.07.08
TexCom Gulf Disposal, a Houston-based disposal company seeking to operate an injection well in Montgomery County, is first seeking to dispel what its CEO calls misinformation being put forth about the project.

Louis Ross, the company’s CEO who lives in Houston, presented his case to the Oak Ridge North City Council July 28.

Ross keyed in on what he believes are three specific erroneous claims being made by opponents of the project, which would be located off Creighton Road in northeast Montgomery County.

A decision on approval of the well is pending with the Texas Commission on Environmental Quality.


“There is a general perception around the county,” Ross said, “most of it disseminated by people who oppose our permit, saying essentially this: That there’s going to be 600 trucks a day coming to this site. They’re going to be carrying toxic chemicals, which we will inject into this well, and those toxic chemicals will percolate up into the aquifer and polluter underground sources of drinking water in 54 counties.”

“I’m here to tell you that none of that is true,” Ross added.

Ross’ assertions indicate a situation where two groups of engineers, geologists and hydrologists hold vastly differing opinions, said Jennifer Real of CROW (Citizen Residents Opposed to Wells).

With more than 100 members, CROW has spearheaded resident protests against the injection well. Efforts have included town hall-style community meetings in The Woodlands and Conroe. CROW also has organized chartered bus trips to Austin, bringing groups to voice concerns to Gov. Rick Perry and TCEQ officials.

“It’s basically expert against expert,” Real said. “... Our beef is with the (Texas Commission on Environmental Quality) doing their job. In this situation (it should) err on the side of public safety.”

A three-person TCEQ panel is expected to issue a ruling on whether or not to grant TexCom a permit to operate the well after a final public hearing sometime later this year. The date for that hearing has not yet been set.

The concerns of CROW members are shared by Jim Stinson, general manager of The Woodlands Joint Powers Agency.

The Woodlands Joint Powers Agency is the central management agency for the eleven municipal utility districts that currently provide water distribution, wastewater collection, storm drainage and tax collection services in The Woodlands.

“This is just an inappropriate site for an injection site,” Stinson said. “There are risks associated with it and we should not be (taking a) risk with the drinking water sources of Montgomery County.”

The differences in opinions begins with what would eventually be injected into the well.

Real and members of CROW have specifically referred to the well as a toxic injection well. But, the well wouldn’t include any water that could be classified as toxic or hazardous, Ross said.

Anything that could be considered hazardous in larger quantities would be so diluted in the water that it could safely be ingested, he said.

TexCom is seeking a permit to dispose of Class 1 Nonhazardous Industrial Wastewater.

Among the types of water that would likely be injected at the site are water used during manufacturing processes, runoff from parking lots and water used for cleaning at automotive repair facilities.

Ross said the water that will be injected into the well is safer than much of the water that enters municipal water treatment sites as runoff from large retail sites.

Nothing corrosive, toxic, flammable or reactive will be allowed to be injected into the well, Ross said. And every load of water brought to the site must carry a detailed description of what it contains. An on-site lab then takes a sample of the contents and verifies that it is what was purported to be. That documentation is required for all water that is injected into the site, and must be available for review by the TCEQ. Ross said fines and/or jail time could result if that documentation isn’t maintained properly.

To Real, the distinction between whether or not the water injected into the well includes quantities of materials that meet the government’s definition of hazardous isn’t relevant.

“(It’s) not going to kill somebody if they took that one drink, but what happens is those carcinogens build up and they are toxic,” she said.

Among the list of chemicals listed on TexCom’s permit application for potential injection are several which have been identified as carcinogens, including tetrachlorethylene, methylene chloride and trichloreoethylene.

Ross said millions of gallons of water already are injected into the ground in the same area each day by companies pumping the last of the oil from the Conroe field. As the oil in the field is depleted, salt water is removed from the ground as well as the oil. That water is then pumped back into the ground into Class II wells, which are typically at depths of about 3,000 feet — half the depth of the injection well TexCom is pursuing.

Ross said well monitoring reports from the Texas Railroad Commission list 40 Class II injection wells in existence in the Conroe field, and from January 2007 through January 2008, a total of 50,048,470 barrels of water, or 2.1 billion gallons, that had been removed along with the oil were re-injected into the field.

At more than a mile under the ground, the wastewater injection well TexCom would operate is far beneath several layers of clay-like shale, which would keep it from ever developing into a sinkhole or pollute the aquifers above it, Ross said.

As part of the application process for an injection well, TexCom was required to examine all oil well shafts that were within two miles of the well and ensure they were not at risk of leaking wastewater.

“There is no potential for this well to pollute the aquifer,” Ross said.

TexCom’s study of the old oil wells in the area surrounding the injection well site only included the wells included in TRRC’s records, Real said. Those records don’t include the earliest wells in the oil field, which date back to the 1920s, she said.

The Texas State Office of Administrative Hearings, after hearing both sides state their cases this past December, added a condition supporting CROW’s concerns about some wells not being examined.

SOAH’s ruling included a condition that all wells within the injection site’s “cone of influence” be properly examined.

The well TexCom would operate, if it was operated around the clock at the highest amount allowed under the permit the company is seeing, would be able handle about 100 truck loads of wastewater a day.

Since the well will only be operated eight to 10 hours a day, between 35 and 40 trucks worth of waste will be injected into the well a day, Ross said.

That number of trucks still concerns Real, who lives in a residential area very near the proposed injection site. She said the 600 truck number was taken from testimony by a witness for TexCom at the hearings before SOAH.

Ross said the waste injected in the well would likely almost all come from the companies located in Montgomery County. One of the larger users of the well could be Huntsman Corporation, a Woodlands-based manufacturer and marketer of differentiated chemicals.

“We are not a user of the well and have no present intention of using the well,” said Russ Stolle, Huntsman’s vice president of public affairs. “The question was raised within our manufacturing organizations on whether we had any interest. We don’t envision being a customer of the well.”



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Reader Comments

MCO resident wrote on Aug 10, 2008 12:40 AM:

" For you information, this location was previously permitted by the TCEQ for injection of Class 1 non-hazardous waste under the name of Crossroads Environmental without protest. Crossroads never constructed the facility and the permit was revoked. At the time of the original permitting the proposed injection wells design and operational standards meet both the State (TCEQ) and Federal (EPA) criteria for attainment of a operating permit. To obtain the permit, you must evaluate all penetrations/wells within a two mile radius of the well bore. The evaluation is conducted using what is termed as a SWIFT/no migration model which is the same model used by the government to evaluate containment of nuclear waste. The interesting thing is the fact that there is no different between hazardous and Class 1 non-hazardous injection well design requirements or mechanical integrity testing requirements. The injection zone must be protected by a confining/barrier layer (clay). The injection tubing is enclosed within a secondary pipe (annulus) which is externally cemented to the injection zone. The annulus is pressured to a greater PSI than the injection PSI and automatically monitored. Any failures in the injection tubing or tubing packer are immediately detected. The usable groundwater zone is protected by the annulus casing which is encased by concrete. These wells are required to have annual mechanical integrity testing performed and chart record daily operations (temperature, pH, injection and annulus pressures).

With out rambling on and as a environmental consultant for 25+ years, I fully understand the concerns regarding groundwater protection. I do not agree with Mr. Ross that is no potential for the well's activities to pollute groundwater; however, it is not likely due to current design/construction and regulatory operating requirements. The alarming issue is, go east of the proposed site down Rocky Road at the Y in the road, drive to the back of the property if you can get in, look and sample the earthen constructed oil skim pond adjacent to the Railroad Commission permitted injection well which represents an immediate threat to groundwater. A little knowledge or the lack thereof is very dangerous in the hands of radicals. Look at todays gas prices that have evolved based on pure BS.

To clear the air for comment, I have no involvement with TexCom. "

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