Attest Application for Permit for Salt Water Disposal Well by Select Energy Services, LLC

Gentlemen:

On June 15, 2013, a W-14 was received describing the above proposal by Select Energy Services, LLC; please see concerns below from neighboring residents leading to the protest of this application.

1) The proposed site is located in a residential area with many homes a short distance of the site, within 25-75 yards, estimated.

2) The Highway entrance is located on Hwy 90A East. This Highway is an alternate to IH-10 and is used by many large trucking firms, already creating more traffic than this area is designed to handle.

3) The recent Eagle Ford Shale discovery in Gonzales, and surrounding counties, has created additional traffic consisting of large and sometimes dangerous cargo to triple the flow.

4) The noted site is located at the top of a hill, numerous driveways are a short distance across from the entrance, also on this same hill. This hill makes it difficult to see a great distance in enough time to prepare to stop on a fast moving highway.

5) Hwy 90A East has a 70 mph speed limit making it difficult, nearly impossible, for vehicles to stop safely behind large trucks turning in or pulling out of the entrance.

6) This residential area is mandated by the US Postal Service to have mail boxes next to the highway. This increases the risk of accidents with all the above mentioned factors in play.

7) This area of highway has been the site of numerous accidents, some fatal. These accidents happened prior to the recent growth in traffic; the risk has increased due to the traffic explosion since the oil boom. The proposed Salt Water Well at this site will add to these possibilities and raise the risks of more accidents and injuries.

8) Accidents and/or fatalities could be costly to Select Energy Services as well as to the families residing in this area. Loss of lives, property and possible lawsuits can be detrimental to all involved.

9) The Gonzales Independent School District has a bus route that stops twice a day, in this area, letting school aged children off and picking them up each week day from Sept- May.

10) There are many homes located along the highway near this site, as close as 60 feet from the edge of the highway. We are greatly concerned that a vehicle, large or small, will end up crashing into homes if a driver is not able to stop for a truck turning into the site.

Residential owners in this area have many questions to be addressed.

1) Will the proposed site be paved? There will be heavy dust created by constant flow of traffic in and out of the site.

2) Will the disturbances of the disposal site devaluate our property and homes? Some residents have lived in their home for more than 50 yrs, they may be forced to sell if the disturbances are unbearable.

3) Will the excessive lighting and noise be a nuisance to the nearby property owners and be an invasion of their privacy? Will the large lights be a distraction for drivers on the highway?

4) Will the air be contaminated from toxins in the waste being disposed of at this site? This can cause great harm to the health and welfare of residents and their pets and/or livestock.

We ask these concerns be heard for resolution to the safety of the environment and to protect the community from projected tragedies.

We realize there’s a possibility of the permit being granted due to the oil industry giants. In this event we ask for the following conditions to be considered:

For Select Energy to honor their commitment as quoted on their website www.selectenergyservices.com. “ Our team of geologist and landmen strategically identify each location, and each facility is built with the environment, safety and convenience of our clients and communities in mind.”

For Select Energy:
To pave the truck route located on the site to reduce heavy dust and environmental control.

To position security lights away from the highway for prevention of accidents and to prevent privacy intrusion on home owners nearby.

To petition the state to have the current speed limit, in this area, reduced to a safe speed.

To provide resources for nearby residence to maintain a safe living environment in their homes.

To assist home owners in the event they need to sell their property and re-locate.

To send all nearby home owners, within 1 mile radius, quarterly reports of test results, performed by independent organization, on all fluids to assure the well contains Salt Water and RCRA Exempt Waste . Same report to be sent to The Railroad Commission.

To send all nearby home owners, within 1 mile radius, annual reports by independent organization, preferably by the Environmental Protection Agency (EPA) that the contents of disposal meets guidelines for RCRA Exempt Waste management. Same report to be sent to The Railroad Commission.

To send all nearby home owners, within 1 mile radius, annual reports by independent organization, preferably the Environmental Protection Agency (EPA) that the contents of disposal meets guidelines for RCRA Exempt Waste management. Same report to be sent to the Railroad Commission.

To notify nearby home owners, within 1 mile radius, immediately of any spills or leakage of well walls, tanks, trucks or any other dangers caused by the site.

For Select Energy:
To provide 24 hr hotline numbers directly to Select Energy, and contact information of Management, to all homeowners (approx 65-100 homes), within 1 mi. radius, to report problems or complaints derived by business.

To erect a warning signs of the dangers of large trucks entering the highway and stopping on the highway to turn into the site.

To survey the site for the most busiest times and considered seizing operations during these times of day or night.

To employ 24 hr emergency services personnel to remain on the site to assist their employees, pedestrians and drivers when accidents happen for at least one year from the time operations begins.

For the Railroad Commission Environmental Services:
To re-visit the permit if Select Energy does not uphold their own company policies and follow regulations set by all State Agencies to protect the environment and all citizens concerned.

Please consider the following recommendations as more conducive alternatives for this Salt Water Disposal Well Site.

1) Disposal Wells located in sparsely populated areas; less homes affecting less than 100- 200 citizens, who live 24 hrs a day in their homes, and decrease the dangers of both parties.

2) Disposal Wells located over the Yoakum Channel, a short distance from this proposed site. “The channel or canyon, clearly erosional, is filled largely with silty shale, which contrasts sharply on the well logs with the sandy character of the typical Wilcox strata through which it was gouged.
This canyon can be traced for more than 50 miles, from its mouth evidently near the southeast line of Lavaca County up-did in a north-northwesterly direction to the outcrop of the Wilcox in Bastrop County. At its maximum known development near the town of Yoakum it has a width of 10 miles and a depth of 3,000 feet.”
Ref. http://archives.datapages.com/data/gcags/data/009/009001/0041.htm

3) Disposal Wells located in safe areas; no children, no school bus stops within a few yards from entrance, no entrances located on road or highway that is not easily visible by other drivers considering speed limit on road. These conditions will assist in reducing chances of injury, accidents and possible fatalities.

Thank you for your consideration and your dedication to protect the environment.