The U.S. Environmental Protection Agency’s underground injection control program is holding a public hearing on proposed permit modifications and aquifer exemption expansion for wells in Pondera County for Montalban Oil and Gas Operations.

The request is associated with Calumet and Montana Renewables operations.

The public hearing is 5:30 p.m. Sept. 23 at Conrad High School.

Written comments must be submitted online using this link and can be submitted by mail to: Velrey Lozano, U.S. EPA Region 8, Mail Code: 8WD-SDU, 1595 Wynkoop Street, Denver, CO 80202-1129

Written comments must be submitted online or postmarked by midnight Mountain Time on Oct. 13.

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“Only relevant comments associated with the changes described in this public notice will be considered for the final decision. EPA will issue a document with responses to all relevant comments that will become part of the administrative record,” according to the EPA.

The proposal involves the Jody Field 34-1 well, which was initially authorized to inject into the Upper Madison Formation under an aquifer exemption that EPA approved in August 2011 for a depth of about 3,428 to 3,496 feet and horizontally within a radius of a quarter-mile from the wellbore.

The Madison Formation extends from 3,428 to 3,700 feet and consists of fine-grained dolomite with good vuggy and intergranular porosity, according to the EPA project overview.

[READ: Permit details and documents]

The EPA documents indicate “injected fluids would be limited to those composed of fluids associated with oil and natural gas production and wastewater from Montana Renewables generated from the pretreatment of renewable feedstocks. The renewable feedstocks may include, but are not limited to, vegetable oils (such as soybean oil and canola oil), animal fats (such as beef tallow, choice white grease, and poultry fat) distiller’s corn oil, and used cooking oil. The pretreatment process technology is developed and licensed by Applied Research Associates, Inc. The pre-treatment system is currently under construction and final water quality data for the various blends of feedstock are
not available. However, the [total dissolved solids] is approximated to range from 5,000 mg/L to 8,000 mg/L based on bench scale analyses from ARA.”

According to the EPA, the Madison Aquifer “does not currently serve as a source of drinking water for the area near the
proposed aquifer exemption. The Madison Aquifer at this location is not a valuable potential source of drinking water either now or in the future. The water quality is poor.”

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In response to the EPA extending the public comment period on the amendments to the Montalban permit in Pondera County, Calumet issued the following statement:

“In this amendment, EPA modeled fluid migration over a 10,000-year period and aligned the aquifer exemption with the 10,000-year boundary. The modeling that EPA conducted shows the migration of fluids over a 10,000-year period won’t impact any U.S. drinking water sources. Even though the regulations don’t require this level of analysis, we appreciate EPA’s increased scrutiny to address public concerns about aquifer impacts. The wells in Pondera County are not owned or controlled by Montana Renewables. Montana Renewables continues to analyze options for the safe and compliant management of additional non-hazardous wash water generated during renewable fuel production. These options are sustainable and science-based solutions that meet regulatory standards.”

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Pondera County Commissioners continue to oppose the permit modification and said in a statement that injecting Montana Renewable’s wastewater into the well in their county “needlessly threatens clean drinking and agricultural
water sources. The EPA’s determination that an expanded aquifer exemption is necessary for this project to move forward underscores what we’ve been saying all along – the wastewater is not going to stay where it is injected due to the fractured underlying geology. There is no justifiable reason to risk our precious sources of clean water when a common-sense solution exists, wastewater treatment. Montana Renewables can, and has said they will do the right thing and build a wastewater treatment facility in three to five years to manage their wastewater at the refinery, though they have unfortunately not yet taken the use of these wells off the table in the interim.”

About a month before the EPA announced in late August that it was extending the public comment period on the Montalban permit, Montana Renewables said it intends to build additional water treatment capacity at the Great Falls facility to allow the company to manage agricultural wash water, a byproduct of its production process, without shipping water to third-party locations.

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Montana Renewables operations include washing renewable feedstocks such as canola and corn oil before they’re used to produce renewable fuels.

“The same approach is used by the food industry in preparing the same vegetable oils for the supermarket shelf. The resulting non-hazardous wash water is safely disposed of at permitted out-of-state facilities. This includes shipping of water by truck and rail,” according to Montana Renewables.

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“As we expand our production, onsite water treatment is a logical improvement that serves MRL and Montana,” Bruce Fleming, Montana Renewables CEO, said in a release.

Calumet received a $1.44 billion U.S. Department of Energy loan late last year for construction and expansion of the Montana Renewables facility, a subsidiary that’s co-located with Calumet in Great Falls.

The expansion is expected to increased Montana Renewables’ annual production capacity of sustainable aviation fuel to about 300 million gallons and increase capacity to about 330 million gallons of combined sustainable aviation fuel and renewable diesel.

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The company is adding a second renewable fuels reactor, which will allow about half of the 300 million gallon sustainable aviation fuel capacity to be online by 2026, according to Calumet.

Calumet said that the proposed additional water treatment capacity requires DOE approval before construction can begin.

When Calumet announced it planned to build the additional water treatment facility in July, City Manager Greg Doyon told The Electric he was unaware of any discussions or permit applications related to the announcement, but for the city to accept the company’s effluent, it would need to meet industrial discharge requirements, which were to be determined.

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Calumet initially funding to the city to “upgrade” the wastewater treatment to “accept its raw effluent for its biodiesel process, but that would have required the city to change its treatment from a biological one to a chemical based treatment process. At that time, we felt that it would increase the cost to the city and therefore the utility ratepayers without a clear ability to attribute those increased costs to Calumet. Pre-treatment is a common requirement for industrial users who want to discharge into the public waste treatment system,” Doyon told The Electric in July.

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Asked a series of questions pertaining to the proposed water treatment capacity, Calumet spokesperson Lanni Klasner said a week later that didn’t didn’t have “a lot of details to share. We are coordinating with the Department of Energy. We will share updates as they become available.”