Here is the comment I submitted today:
Consumers Energy is on the fast track for approval of permits to install two deep injection wells in Port Sheldon. The wells will be used for long term storage of ‘’non-hazardous wastewater generated from the JH Campbell” plant.
Per Chat GPT:
“What the wastewater actually looks like there from site documents and broader coal-ash data:
• The wastewater is primarily coal ash landfill leachate + contaminated groundwater
• It contains dissolved salts and metals like boron, chloride, calcium, iron plus typical coal-ash contaminants like arsenic, selenium, mercury
• It is chemically complex, often high in total dissolved solids (TDS)
• Volumes are large and long-term due to decades of ash disposal (millions of cubic yards) and continuing leachate generation even after plant closure
That combination- high volume plus dissolved contaminants- is what drives the feasibility of each option.”
A significant factor here is that Consumers Energy chose the easy, inexpensive path for decades (“decades of ash disposal”), rather than the most environmentally responsible path of selling the ash for use in commercial and industrial processes, so that it would not accumulate on site.
Here is what Chat GPT further says regarding how the wastewater could be more optimally managed than Consumers Energy’s plan:
“A More Nuanced Take (What a “best possible” plan would look like)
If you were designing an optimized approach (not just cheapest), it would likely be:
• Deep injection wells to handle bulk volume
• Targeted treatment systems to reduce toxicity before injection
• Ash reuse to reduce future leachate generation
In other words: a hybrid system, not a single solution.”
So Chat GPT suggests there is likely a more optimized approach than what Consumers Energy plans.
Other sources like the Pro Publica article entitled “Injection Wells: The Poison Beneath Us” paint a far more cautionary warning about injection wells: “…scientists and environmental officials have assumed that deep layers of rock beneath the earth would safely entomb the waste for millennia. There are growing signs they were mistaken…” It should be noted that environmental groups like Earth Justice strongly oppose the widespread use of deep injection wells for wastewater disposal, viewing them as a dangerous and unsustainable “false solution”. The organization argues that these wells threaten to contaminate drinking water, induce earthquakes, and have other risks. Earth Justice argues that rather than relying on well injection, industry should focus on treating, reducing, and recycling wastewater. While disagreeing with Earth Justice on many things, including whether coal should be used for electric generation, I tend to agree with them on this. We should not repeat the mistake of selecting the easy but legally permissible path now only to regret it later.
As a matter of general policy, we should seek to treat and reuse wastes, including such wastewater, rather than burying it as is and hoping for the best. I would especially suggest investigation that a significant portion of that bulk wastewater be treated for use in both a co-located data center’s cooling system (an exploratory committee for a locally controlled electric cooperative represented by many townships in Ottawa County is pursuing a co-located data center for the Campbell plant), plus perhaps other ones, and for other commercial purposes. Data centers in Arizona and Virginia use reclaimed municipal wastewater, so there is precedence for using wastewater in data centers, but it should be noted that the Campbell wastewater would need more pre-treatment than these municipal wastewater systems. There is a huge need for water in data centers now, so there is good reason to explore using the water for them rather than simply injecting them deep underground as is. Consumers Energy’s plan is within standard industry protocol, but the risks of their method can be reduced the more we can decrease the volume of wastewater injected deep underground.
In summary, there is good reason to believe there are better ways to address the wastewater issue than simply burying it deep underground as is, where it potentially can leak and cause damage over time. A public hearing and further investigation of more optimal solutions are certainly in order.
While this comment does not speak on behalf of the Exploratory Committee for a Locally Controlled Electric Cooperative in Ottawa County as a whole, I am the moderator of this exploratory committee, and the exploratory committee as a whole is investigating the purchase of the Campbell facility from Consumers Energy (seeking federal assistance) and its more long-term use for electric generation in an environmentally responsible way, combined with a co-located data center to utilize some of its generated electricity, as well as to take advantage of the location’s water availability for a cooling system.
Joseph Parnell McCarter