MICHIGAN POTASH OPERATING, LLC – PART 625 MINERAL WELLS

Michigan Potash Operating, LLC (Michigan Potash) has recently applied for eight solution mining wells (EPA UIC Class III) and three non-hazardous processed brine disposal wells (EPA UIC Class I) permit applications. These types of wells are dually permitted by the Michigan Department of Environmental Quality (DEQ), Oil, Gas, and Minerals Division (OGMD) and the United States Environmental Protection Agency (USEPA), Underground Injection Control Program (UIC). Under Michigan statute and rules, the construction, drilling, and operation of these wells are subject to the provisions of Michigan’s Mineral Well program, Part 625, of the Natural Resources and Environmental Protection Act, 1994 PA 451, as amended (NREPA). Michigan Potash initiated the Class I and Class III permit applications with USEPA prior to submitting their Michigan Part 625 applications. USEPA held a public meeting on these proposals in January 2017, and issued their Class I and Class III permits to Michigan Potash in August 2017 and June 2017, respectively.

The proposed well locations are approximately 5 miles southwest of the city of Evart in Southern Osceola County.  Two of the processed brine disposal wells are on a shared well pad with the eight solution mining wells, while a third processed brine disposal well is located roughly one-half mile to the south on a separate well pad. The solution mining wells are targeting potash and food grade salt production. Potash is a water-soluble compound that naturally occurs as Sylvite (KCl) in Michigan. Potash is primarily used as an agricultural fertilizer. In this area of Michigan, high quality zones of Sylvite and Sodium Chloride (NaCl) are found within zones of the A1 Evaporite Formation of the Salina Group at depths of 7,500 to 7,800 feet below the ground surface.

Michigan Potash proposes to extract Potash through the process of solution mining. In doing so, water or brine is pumped downhole into targeted zones thereby dissolving the Potash. The resulting dissolved, potash rich brine is returned to surface where it is mechanically evaporated to recover potash and food grade salt. This process creates potash deficient brine and freshwater that is recycled in a closed loop system and reused. The three proposed non-hazardous disposal wells would be utilized to handle the residual brine that is no longer able to be used in the process. The disposal wells are targeting porous zones within the Sylvania and Bass Island Formations at depths of 5,100 to 5,600 feet below the ground surface.

Some of the source water needed in the dissolving process would be obtained from two proposed water wells drilled in the area. According to the applicant, operations will reuse 90% of the source water. The initial water requirements and pumping rates for this project are considered large quantity water withdrawals and are subject to the provisions of Part 327, Great Lakes Preservation, of the NREPA. Michigan Potash has registered the two proposed water wells within Michigan’s Water Withdrawal Assessment Tool (WWAT). Based upon the pumping rates, well depths, and proximity to streams and rivers, the WWAT indicates there will be no adverse resource impacts from these registered water withdrawals. Michigan Potash has also obtained a DEQ Air Quality Division permit to install, Part 55, Air Pollution Control, of the NREPA, for their proposed manufacturing site at the NE corner of Scofield Road and 120th Avenue in Evart Township. Depending upon future plans, additional permits or approvals from the DEQ may be necessary.

Solution mining for potash and salt production is not new in this area. There is a facility presently operated by Cargill that is currently producing salt, but did produce potash up until about 5 years ago. This facility has been in operation since the early 1980s and is located less than 2 miles Northwest of the Michigan Potash solution mining well locations.

Under federal and state regulations and requirements, disposal wells and solution mining wells must be designed and constructed to allow disposal of wastewater or injection of fluids to dissolve and extract minerals while preventing the movement of these fluids into freshwater zones.  Wells that meet design and operating requirements are very low risk.  There are redundant protections and strict guidelines related to well location, design, construction, operation, monitoring, testing, reporting, and closure.  The safeguards in place ensure protection to freshwater, the environment, and human health.  The proposed Michigan Potash wells are designed to isolate the disposal/solution mining zones from the freshwater zone by utilizing multiple strings of casing (steel pipes) cemented to the surface. Under no circumstances would a disposal well or solution mining well be approved or allowed to operate if there were indications that the disposed fluids or mining fluids could migrate into freshwater zones.

Pursuant to Part 625 of the NREPA, the eight proposed solution mining applications are subject to confidentiality, while the three disposal well applications are not.  Michigan Potash has waived some of the confidentiality provisions for the solution mining applications, which allows the OGMD to discuss some of the details regarding these proposals. The three disposal well applications can be viewed here by following this link to the OGMD Mineral Well webpage. For more information, please contact Mark Snow, Supervisor, OGMD Permits and Bonding Unit at 517-230-8233 or snowm@michigan.gov

OGMD will be holding a public information session and public hearing on this project at the Evart Middle School Auditorium (321 North Hemlock St., Evart, Michigan 49631) on March 12, 2018, from 6:00 to 9:00pm. Public comments will be accepted at this hearing. Comments will be accepted through Monday, March 19, 2018 and may be submitted via email to:

DEQ-OGMDpubliccomments@michigan.gov

Or mailed to:

Michigan Department of Environmental Quality - Oil, Gas, and Minerals Division

RE: Comments Michigan Potash Applications

PO Box 30256

Lansing, MI. 48909