Aethon (Moneta Divide) Proposed Discharge Permit

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Comment From: Wyoming Game and Fish (Angi Bruce)

7/07/19 @ 5:00 PM

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Comment From: Gardner Livestock, LLC (Greg Gardner)

7/05/19 @ 11:27 AM

We own and/or lease nearly 11 miles of private land along Badwater Creek (between Lysite and Bonneville) which is downstream from the proposed permit areas. For the past 38 years, we have ran livestock on Badwater Creek and have serious concerns abou...↓t both the QUANTITY and QUALITY of water that is to be dumped into receiving waters of Alkali Creek which flows into Badwater Creek. Our livestock is our livelihood and approximately 11 miles of the stretch between Lysite and Bonneville is owned or leased by us and we feel our concerns need to be heard. QUANTITY: It takes decades for a creek to stabilize and find its natural way from its starting point to its final destination. Meandering is a natural way for creeks to wander through the watershed. It slows down the water flow, helps reduce erosion, and dissipates the impact of flood waters. Around 1913-14, the railroad "straightened" the creek bed to make way for construction of the railroad. This eliminated the natural meandering and ultimately started the early deterioration of Badwater Creek. The creek drops approximately 460 feet in elevation between Lysite and Bonneville and the creek bed is made up of a lot of sand and very little rocks to slow down the water flow. These factors compound the natural erosion. Since we have been operating our ranch we have noticed major changes in the Badwater Creek channel. The creek has gotten deeper and the banks have gotten steeper making it much more dangerous for cattle and wildlife to cross. Case in point, the flood of 1923 was disastrous to the railroad and the creek! The significant drop in elevation compounded with the lack of natural meandering that would've normally dissipated the flood waters allowed the water to rush at much more catastrophic speeds washing out many of the railroad bridges and the original railroad right of way. This prompted them to rebuild the railroad in the location it is today. That flood would not have been nearly as devastating, in that area, had the natural flow of the creek not been tampered with years prior. Evidence of the erosion can be seen downstream as a massive amount of silt piled up at the mouth of Badwater Creek just before it flows into Boysen Reservoir, West of Highway 20. We've already noticed an increase in water volume since installation of the wells in Frenchie Draw area, several years ago and are seriously concerned that adding an even larger volume of water to an already volatile creek is going to compound this man-made erosion disaster. QUALITY: In addition, we're very concerned about the quality of water that is going to be dumped into the creek. Our livestock drink it as do wildlife. We've been told that the water is safe, but you can imagine our concerns when we've already been noticing an odor and a thin film appearing on the creek banks that is sometimes red colored water. We notice it in the late summer, when the creek is at its lowest. This has only become apparent in the years since wells were added to Frenchie Draw and water has been dumped into the creeks upstream. We certainly do not want our livestock drinking contaminated water of any sort. As I mentioned, our livestock is our livelihood. This will affect the entire stretch of Badwater Creek that we run our cattle on during the winter months. We believe that the significant increase in water volume as proposed by WY0002062, Frenchie Draw Permit #1 will compound the erosion problem that already exists. We believe the wildlife will be affected as well. We had had previously been told there were discussions of a possible installation of a pipeline from the wells to the Boysen Reservoir. What happened to that idea? Has it just gone by the wayside? If the water is as safe as you say it is, we would like to hear more about this possible solution as an alternative to the further destruction of Badwater Creek. Greg & Barbara Gardner Landowner at Badwater Creek Gardner Livestock, LLC

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Comment From: Tinnelli's House Of Wonder (Ryan Tinnell)

7/05/19 @ 11:04 AM

Ryan Tinnell As an owner and operator of a historic building and business in central Wyoming, highly visited by worldwide tourists located very, very close to one of the most amazing water tributaries in the world, I am deeply disturbed by the thoug...↓

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Comment From: Ian Abernethy

7/05/19 @ 9:56 AM

I urge the Wyoming Department of Environmental Quality to reject the proposed discharge of produced water from the Moneta Divide expansion project. While I fully understand the economic benefits local communities and Wyoming enjoy from our energy eco...↓

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Comment From: Jazmyn McDonald

7/05/19 @ 9:51 AM

I have attended the Riverton informational meeting and reviewed a number of the documents made available by DEQ about the proposed Aethon Energy Moneta Divide development and I still have grave concerns. ....All the water produced from these sites...↓

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Comment From: Kristy Palmer

7/05/19 @ 9:47 AM

Please show that you value the people of Wyoming more than industry by not allowing fracking waste product in the Boysen Reservoir. If you do it, I would like to see warning signs to all visitors of the Reservoir and I would like to see everyone who ...↓

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Comment From: Mark Sanderson

7/05/19 @ 9:18 AM

This proposed discharge of produced water into Boysen Reservoir is so patently absurd, it hardly deserves comment. But since I do have the opportunity, I would urge you adopt Alternative 4; no action! I have not seen anything regarding the irradiatio...↓

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Comment From: Sierra Club Wyoming Chapter (Connie Wilbert)

7/05/19 @ 8:14 AM

July 5, 2019 Jason Thomas Department of Environmental Quality Water Quality Division 200 West 17th Street Cheyenne, WY 82002 Re: Comments on Moneta Divide Gas Field Discharge Permit (WY0002062, Aethon Energy) Submitted via WDEQ public comm...↓ent portal and email Dear Mr. Thomas: On behalf of more than 1,200 members of Sierra Club Wyoming Chapter (SCWC) and more than 3.5 million members and supporters of the Sierra Club nationwide, we submit the following comments on Aethon Energy's application for renewal of its Moneta Divide Gas Field Discharge Permit, WY0002062. As America's most enduring and influential grassroots environmental organization, the Sierra Club is dedicated to defending all people's right to live in a healthy world, with clean water, clean air, and access to functional natural ecosystems. Here in Wyoming, we work to help our members, Wyoming residents, and visitors to our state enjoy, explore, and protect our remarkable natural places, and to ensure that our environment remains clean and healthy for people and wildlife. As stated on the Wyoming Department of Environmental Quality (WDEQ) website, WDEQ is "charged with protecting, conserving, and enhancing Wyoming's land, air and water for the benefit of current and future generations". It is the responsibility of the WDEQ to ensure that proposed industrial activities such as this proposed permit renewal comply with all state and federal laws including the Clean Water Act, National Pollution Discharge Elimination System, Wyoming Environmental Quality Act, and all other applicable law. The WDEQ must ensure that the proposed permit renewal will not adversely affect the health and safety of Wyoming's residents, that it complies with all relevant water quality standards, that it does not excessively harm other natural resources including wildlife and wildlife habitat, that it does not harm recreational users, and that it respects the rights of private property owners, including downstream water users. After reviewing the permit renewal application and independent third-party expert evaluations of the application and the modeling report submitted by the applicant, we have concluded that the WDEQ must deny the permit renewal because of noncompliance with state and federal laws, potential negative impacts to human health and safety, negative impacts to water quality, unacceptable harm to wildlife and wildlife habitat, unacceptable harm to recreational uses, and general unacceptable environmental degradation. Aethon Energy has proposed a major expansion of its Moneta Divide field that would approximately quadruple the wells in the field, going from around 900 existing wells to 4,100 wells. The field now discharges about 1 million gallons of wastewater per day, and the proposed expansion would produce an estimated 1.4 million barrels (58 million gallons) of waste water per day. 1. The Boysen Reservoir Water Quality Model is fatally flawed and cannot be used to evaluate or approve the permit Without any independent verification, the WDEQ completely relied on the Boysen Reservoir Water Quality Model, developed by the project proponent's contractor Environmental Resources Management (ERM), to erroneously conclude that discharging the proposed level of produced waste water would not violate water quality standards in Boysen Reservoir or the Class 1 segment of the Wind River downstream, harm aquatic life or other wildlife, elevate risk to human health or safety, or harm downstream users. Having some concern about the impartiality and quality of a model developed by a consultant for the project proponent, the SCWC joined with several other organizations to hire an independent scientific review of the model and its interpretation. The independent review by Hydros Consulting, a firm with no financial interest in this project, of the model and supporting reservoir modeling files, concluded that ERM's report, and the underlying model on which it is based, are fundamentally flawed and cannot be used for regulatory compliance. Some of the key findings of the review conducted by Hydros Consulting included: • The model was not developed properly and excluded many important factors. o Little to no tributary flow data was collected to ground-truth flow assumptions. o Reservoir evaporation effects were completely ignored. o Tributary flow estimates were arbitrary and inconsistent. o Inflow data from the Wind River was improperly manipulated. o Wind speeds were unrealistically limited. o Assumptions about water quality in different tributary streams were unsubstantiated. o Density changes for inflow water into Badwater Bay were completely ignored. o Water released at Boysen Dam into the Wind River was not correlated to inflow density, and there was no differentiation between water released through the low-level outlet and the high-level spillway. • The model was not properly evaluated or calibrated, and cannot be considered realistic or reliable. o The model compared water quality measurements in the Wind River to water quality simulated only in the top two-foot layer of Boysen Reservoir, which completely ignores the facts that the reservoir stratifies, more dense inflows may sink and flow along the floor of the reservoir to the dam, and most of the water released flows through the dam's low-level outlet. o High quality, meaningful data was arbitrarily excluded during the calibration and validation process, including data collected during periods of low natural flow and highest percent produced water (for example, in winter months). • Compliance analysis methodology and conclusions are incorrect. o Extensive valid and high quality data sets from the US Geological Survey on the Class 1 segment of the Wind River were excluded from analysis of baseline conditions. o The analysis improperly used monthly averages to incorrectly reduce impacts to the Class 1 segment of the Wind River. o The analysis used inflated and incorrect statistical values to reach statistically unsupported conclusions. o An antidegradation analysis for Bosyen Reservoir, required by the Clean Water Act and Wyoming Environmental Quality Act, was not conducted. Please see the attached Hydros report for further explanation and details of their review of ERM's model and report. We hereby incorporate the Hydros report in its entirety into our comments. 2. Existing water quality impairment must be corrected Current discharge of produced wastewater from the Moneta Divide field already has caused significant and ongoing impairment to both Alkali and Badwater creeks, and increases risk to Boysen Reservoir and the Wind River below Boysen. Allowing additional discharges will only worsen existing damage and further increase risk of unacceptable water quality impairment downstream. To meet its fundamental charge, the WDEQ must not authorize more pollution until existing problems are corrected. For decades, WDEQ has authorized the discharge of massive quantities of highly saline and contaminated produced water into Alkali and Badwater creeks from nearby oil and gas fields. Even though WDEQ rules explicitly prohibit it from allowing modified effluent limits that would violate water quality standards, they have continued to exempt discharges from water quality standards limiting chlorides, sulfates, conductance and total dissolved solids. Continuing to exempt discharges from water quality standards violates the Clean Water Act and the Wyoming Environmental Quality Act, and could undermine Wyoming's authority to issue NPDES permits. Alkali Creek is a Class 3B stream, meaning it is an intermittent tributary stream including adjacent wetlands not known to support fish populations or drinking water supplies, but with sufficient hydrology to normally support and sustain communities of aquatic life including invertebrates, amphibians, or other flora and fauna. The designated use assigned to this classification is "aquatic life other than fish", and the WDEQ is responsible for protecting this designated use including water quality and habitat necessary to sustain populations of organisms other than fish to support diverse aquatic communities. According to the BLM, oil field wastewater flowing into tributaries of Alkali Creek and Alkali Creek itself has caused disturbance of the drainage beds and destruction of drainage vegetation, leading to accelerated erosion. In Alkali Creek, degradation and scouring have increased downcutting (downward erosion) in tributary channels, inhibiting livestock movement, grazing and watering, and increasing sediment loading in Alkali Creek. According to monitoring done by Aethon as required by its current discharge permit, Alkali Creek above the point of discharge is well vegetated, stable, and no scour or aggradation has been noted. Downstream from discharge points, channel changes include scour, degradation, and aggradation of sediment, with documented bank loss. Aquatic life will not be protected by the terms contained in the draft permit, violating Wyoming water quality standards. A report prepared by well known and highly respected aquatic biologists Dr. Harold Bergman, Professor Emeritus, University of Wyoming, and Dr. Joseph Meyer, former UW faculty member and Chief Scientist, Applied Limnology Professionals, in Golden, Colorado, describes numerous critical deficiencies and omissions in the draft permit, and based on aquatic toxicity modeling, concludes that components of Aethon's produced water as proposed in the draft permit would be acutely lethal to aquatic species. Please see the attached Bergman-Meyer report for full details, which we hereby incorporate in its entirety into our comments. Continuing to allow discharges that do not protect designated uses, and that do not maintain water quality necessary to sustain them, violates the Clean Water Act, the Wyoming Environmental Quality Act, and the WDEQ's rules. Badwater Creek is a Class 2AB stream, a Tier II, high quality surface water. This designation, according to the Clean Water Act, the Environmental Protection Agency, and WDEQ Water Quality Division Rules and Regulations, requires that water quality in Tier II, high quality surface waters must be maintained to standards that protect existing uses fully. Existing uses include propagation of fish, shellfish, and wildlife and recreation in and on the water. Unfortunately, the DEQ has failed to meet these standards, in violation of the Clean Water Act, the Wyoming Environmental Protection Act, and its own rules and regulations. The quality of Badwater Creek water is lower than the applicable standards, existing uses of Badwater Creek have not been maintained and protected, and WDEQ's claim in the draft permit that additional discharges will not result in significant degradation of Badwater Creek are laughable. Please see the attached Bergman-Meyer report for supporting details. Boysen Reservoir is also a Class 2AB body of water, with the same requirements for water quality maintenance as described for Badwater Creek. As previously noted, the WDEQ based all its assumptions and conclusions on the fatally flawed ERM model and report, which cannot be used as the basis of decisions. Please see the attached Hydros report for a full description of the many problems with the ERM model, especially related to inflows into Boysen Reservoir. Notably. ERM failed to conduct an antidegradation analysis for Boysen Reservoir, as is clearly required by the Clean Air Act, the Wyoming Environmental Quality Act, and WDEQ's rules and regulations. The Wind River below Boysen Dam is a Class I, Tier 3 river, into which no additional water quality degradation by point source discharges other than from dams are allowed. The water quality and biological integrity that existed at the time of designation must be maintained and protected. Again, we direct your attention to the attached Hydros report for a full description of the many problems with the ERM model, especially those related to issues that render any conclusion about the flow of water through the reservoir from Badwater Bay to the dam and into the Wind River as totally meaningless. An uncalibrated, unverified model that cherry picks data, misuses basic statistical parameters, fails to accurately assess water density, water temperature, wind speed, and other highly influential factors that dictate how water vertically segregates and flows through a reservoir, ignores the effect of evaporation, and fails to differentiate between low- and high-level releases to the river simply cannot be used to support any conclusions about this project. To base a conclusion that this project would not harm water quality of the Wind River on such an incomplete and inaccurate model and report clearly would be illegal on any number of fronts. 4. Wildlife and Human Impacts The proposed "mixing zone" in Boysen Reservoir, where highly contaminated water would be discharged into the reservoir, is fundamentally inappropriate and unacceptable. Boysen is heavily used during summer months for swimming, boating, and other water sports, and in winter for ice fishing and other winter recreational activities. Badwater Bay, where Badwater Creek flows into the reservoir, is a nursery area for sauger, designated by the Wyoming Game and Fish Department as a sensitive species. WDEQ has not analyzed potential toxicity of Aethon's produced wastewater to this species or other valued sport fishes in Boysen, or to aquatic life in general in Alkali or Badwater creeks. WDEQ has not meaningfully analyzed potential impacts to human health and safety, either in Boysen Reservoir or in the Wind River downstream. People who use the Wind River further downstream are deeply concerned about this project, and rightly so. Municipalities such as Thermopolis use the water for a number of municipal purposes. Farmers draw from the river for irrigation and livestock use. Elevated salinity, toxic metal contamination, and other harmful substances concern these folks, and their concerns must be taken seriously. Their health and livelihoods are at stake. The water level in Boysen Reservoir fluctuates seasonally and annually, so polluted water will extend further out into the reservoir during low water periods, and the dilution capacity of the reservoir will decrease during low water periods. Badwater Creek regularly experiences periods of low and sometimes no flow, during dry periods. Conversely, these desert drainages also occasionally experience gully washers when the rains come, which sometimes occur only once every several years. WDEQ has done no analysis of what happens when contaminants in wastewater are deposited and concentrated in streambed soils during dry periods, and then flush out in great surges during storm events. What damage will these pulses of extremely concentrated TDS, chloride, sulfate, and oil field chemicals do to aquatic life in the reservoir and the river, and to the people who recreate on and live along these waterways? WDEQ's policy on mixing zones clearly states that a proposed mixing zone may be denied due to concerns about designated and existing uses. Such zones also may be denied in biologically important areas such as fish spawning or nursery areas. Clearly, the WDEQ has the authority to deny this permit, and should do so. 5. Conclusion Draft permit WY0002062, Aethon Energy violates the Clean Water Act, the Wyoming Environmental Quality Act, and the WDEQ's rules and regulations. Produced wastewater from this facility already has damaged streams, threatens wildlife and wildlife habitat, and puts recreational users and downstream communities at risk. Increasing discharges of contaminated wastewater will only make a bad situation worse. The DEQ should deny the permit, and take immediate steps to correct current damage. Aethon should go back to the drawing board and consider other, less environmental damaging alternatives. This watershed simply should not be used as a toxic wastewater treatment facility. We don't need to sacrifice this popular reservoir, its inflowing tributaries, or the Wind River below the reservoir, to this type of industrial development. We should enforce existing laws to stop current levels of unlawful pollution from being discharged into these waters, and Aethon should be required to treat all produced wastewater to all applicable water quality standards at the point of discharge, or to dispose of contaminated water by some other legal means. Sincerely, Connie Wilbert Director Sierra Club Wyoming Chapter P.O. Box 1736 Laramie, WY 82073 (307)460-8046 connie.wilbert@sierraclub.org CC: Governor Mark Gordon Beth Callaway, Policy Advisor Todd Parfitt, WDEQ Director Kevin Frederick, WQD Administrator Darcy O'Connor, EPA Region 8, Assistant Regional Administrator Office of Water Protection Enclosures: Bergman/Meyer Memorandum Hydros Report

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Comment From: National Parks Conservation As... (Ms. Sharon Mader)

7/05/19 @ 7:52 AM

Use this version of NPCA's comments.

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Comment From: Kathy McCoy

7/05/19 @ 7:38 AM

I am totally against Aethon dumping water into the streams that run through our small town. It used to be your could hear frog at night down on the creek and no more. Please don't allow this because our water is a precious and rare commodity that o...↓

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Comment From: John Osgood

7/05/19 @ 7:14 AM

Come on, you folks, what is on your minds? You don't dump potentially very polluted water into a public waterway. You've got tons of water-based recreation going on downstream. You at least need to sample and assay what is in the water before turn...↓

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Comment From: elaine casteel

7/05/19 @ 6:36 AM

I attended the public meeting in Riverton and was very disappointed in the presentation of facts and information given. Very little explanation was given about the actual process to clean the water for those who were not familiar with this subject. T...↓

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Comment From: Joanne Westbrook

7/05/19 @ 6:26 AM

I strongly urge the Wyoming DEQ to ensure that Wyoming surface waters are kept clear of pollution from the Moneta Divide oil and gas field by requiring that discharged water be fully treated and purified and not be discharged into area creeks or in ...↓

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Comment From: National Parks Conservation As... (Ms. Sharon Mader)

7/05/19 @ 5:54 AM

Mr. Jason Thomas Wyoming DEQ Water Quality Division 200 West 17th Street Cheyenne, WY 82002 Delivered via email to: jason.thomas@wyo.gov RE: Moneta Divide oil and gas field pollutant discharge permit, WYPDES Permit Number WY0002062 (Aethon...↓ Energy) Please accept comments on behalf of the National Parks Conservation Association (NPCA) regarding the Moneta Divide oil and gas field pollutant discharge permit. After review of the draft Environmental Impact Statement (EIS) NPCA has concluded that EIS lacks the level of analysis, is missing critical information including discharge limits, water quality standards and effect of aquatic biota to permit the discharge of a potential oil and gas pollutant into a national park unit connected reservoir.   The mission of the NPCA is to "protect and enhance America's National Park System for present and future generations." Founded in 1919, NPCA is the leading citizen voice for the national parks. We are a national nonprofit with headquarters in Washington, DC, and 27 regional and field offices across the country including our Grand Teton Field Office located in Jackson, Wyoming. NPCA represents thousands of Wyoming residents who, along with our 1.3 million members and supporters nationwide, understand the need to conserve and protect our National Park System throughout the country. A top priority for NPCA is protecting the resources within parks, including the larger watersheds in which they are embedded. Poorly planned oil and gas development including the discharge of oil and gas byproducts and pollutants without full understanding of the potential negative impacts can result in significant impacts to national park resources. NPCA is working to ensure that oil and gas development on Wyoming's other public lands, including BLM lands connected to national park units is planned with consideration and care for the many non-drilling uses of the land as well as the potential impacts on park resources, visitor experience and human health. Draft EIS fails to protect National Park units in Wyoming The draft EIS fails to adequately account for the impact to national parks. Additionally, it would set an alarming precedent by discharging potentially contaminated water into the Greater Yellowstone River system- a first of its kind proposal for national parks. Wyoming national parks impacted by this proposal are no exception, particularly considering the proposed permit authorize the discharge of up to 8.27 million of gallons per day of untreated and partially treated produced water into surface waters that could directly impact the water quality of Big Horn National Recreation Area, a national park unit. The watershed connected to Big Horn- waters from Boseyn Reservoir flows into both the Bighorn River, a Class I Watershed, and into the Wind River. This watershed and ecosystem, if contaminated, would reach far outside the boundaries of Boseyn Reservoir and trigger serious immediate and long-term impacts to public health, wildlife, and native trout connected to the larger ecosystem. This risk is compounded by the lack of comprehensive assessment or study of the potential impacts of produced water discharges to surface waters in the draft EIS; nor does it adequately examine their downstream impacts. Permitting the daily discharge of a drilling waste product into public facing water resources without fully understanding existing relevant activities poses extreme risk water quality and at best is premature. Collectively, moving forward with the permit by the state of Wyoming could compromise the critical importance, both legally and in the spirt of America's best idea, which national park units across the country rely on clean water. Additionally, our analysis determined the draft EIS contained inadequate chemical analysis, including limited analytical methods, and in-depth short and long-term toxicity impacts, among others. The draft permit allows Aethon to dump more than 2,100 tons of total dissolved solids, including 719 tons of chloride, into a national park connected reservoir each month. The highly saline wastewater flows from oil wells at temperatures as high as 186° Fahrenheit, according the Bureau of Land Management's Moneta Divide Environmental Impact Statement, which contains a long list of pollutants, yet this issue is not addressed in the state's draft discharge permit. The constitution and range of temperature clearly conflict Wyoming state regulations that designate Boysen Reservoir a "high quality water" requiring "the highest statutory and regulatory requirements for all new and existing point source discharges . . . " Further, additional hydrology analysis conducted raises a series of concerns and questions regarding the impact of Aethon Energy's discharge of produced water into Boydsen Reservior and subsequently Big Horn National Recreation Area include: • Monitoring data necessary for evaluation of the proposed permit renewal – At a minimum, the temperature, pH, TDS, chloride, alkalinity, and flow of Alkali Creek and Badwater Creek should be monitored at least monthly immediately upstream and downstream of Aethon's current discharge in Alkali and Badwater Creeks and also in Badwater Bay. That monitoring should begin at least one year before a final permit is signed by WDEQ, so knowledge of annual variations of flow, temperature, pH, TDS, chloride and alkalinity in Alkali Creek, Badwater Creek and Badwater Bay can be used to better establish acceptable dilution factors for untreated produced water discharged by Aethon.   • Predicted elevation of pH above the pH 9 Wyoming water quality standard – The chemistry of untreated produced water discharged by Aethon will worsen as it flows down Badwater Creek (i.e., the pH of the water will increase and might exceed the in- stream Wyoming water quality standard for pH if not diluted adequately), thus posing a hazard for aquatic life in Alkali Creek, Badwater Creek and Badwater Bay. If pH becomes elevated in Badwater Creek and approaches or exceeds the Wyoming water quality standard's upper pH level of 9, Aethon's hydrologic analysis should be repeated to take into account the potential for adverse water chemistry changes downstream in Badwater Creek as the untreated produced water equilibrates with the atmosphere. Averting such water chemistry changes might necessitate even greater dilution of the untreated produced water than the currently planned for salinity constraint in the Wind River downstream of Boysen Reservoir necessitates. • Predicted toxicity of Aethon's untreated produced water – Based on a published model of the toxicity of saline oil and gas industry produced water to freshwater fish and invertebrates, Aethon's untreated produced water would have to be diluted at least 10- fold to avoid decreasing short-term survival of aquatic organisms; and it is likely that even more dilution would be needed to avoid longer-term, sublethal impairment (e.g., decreased growth and/or reproduction). Thus, averting such adverse effects in Alkali Creek, Badwater Creek and possibly in Badwater Bay might necessitate even greater dilution of the untreated production water than the currently-planned-for salinity constraint necessitates (which is based on projected salinity changes in the Wind River downstream of Boysen Reservoir). • Contributions of potassium to the toxicity of Aethon's produced water discharge – The lack of an analysis for potassium in the water chemistry reported by Aethon means we have no way of knowing if the reportedly most-toxic major ion in the water, potassium, will be present at a high enough concentration to impair survival, growth, or reproduction of fish and other aquatic organisms.   • Inadequate hydrogen sulfide analyses in the permit application – The analytical method used for sulfides in the water chemistry reported by Aethon was not sensitive enough to determine whether the Wyoming water quality standard for sulfide will be exceeded and thus impair survival, growth, or reproduction of fish and other aquatic organisms.   • Cumulative effects of all discharges – Any analysis of the potential effects of Aethon's discharge of produced water should include the cumulative effects of all discharges into the Badwater Creek drainage (Aethon, Burlington, and any other discharges, current and future). And when evaluating the potential effects in the Wind River downstream of Boysen Reservoir, the cumulative effects of all discharges (current and future) in the entire Boysen Reservoir drainage should be considered.   • Toxicity testing requirements in the permit – To test whether Aethon's produced water discharges might adversely affect fish and/or other aquatic organisms in Alkali Creek, Badwater Creek and Badwater Bay, stricter toxicity testing requirements will be needed in a final discharge permit. Whole Effluent Toxicity (WET) tests should be required quarterly (rather than annually), include each outfall rather than a flow-weighted composite sample, include acute 48-hour lethality tests with Daphnia magna and acute 96-hour lethality tests with Fathead Minnows, and include chronic toxicity tests for 7-day larval Fathead Minnow growth and 7-day Ceriodaphnia magna reproduction (this Ceriodaphnia chronic test is now not included in the draft permit but would be important in evaluating potential effects of the discharge in Alkali Creek and Badwater Creek). Additionally, WDEQ should require Aethon to conduct a preliminary toxicity study before the discharge permit is finalized, to ensure the required dilution of untreated produced water is sufficient to avoid long-term toxicity downstream. To evaluate the possible effects of pH shifts to greater than pH 9 due to CO2 de-gassing, these tests should include testing of both "fresh" untreated produced water and "aged" untreated produced water, with the length of the "aging" determined by the longest projected transit time for water between its discharge into Alkali Creek and its entry into Badwater Bay.   Elevating these concerns is disclosure that the State of Wyoming Water Quality Division relied on modeling and analysis from a consultant hired by Aethon Energy to determine adverse impacts to human health to the reservoir, a negligent and alarming action by the state, who failed to independently analyze the impacts, and opted to accept the findings of a potentially biased, or narrowly focused assessment- which by omission or inadvertence, could have failed to capture impacts that would be determinative in the permit process. The permit proposal is highly technical, however in total, the permit allows for the discharge of over 508 million gallons of oil and gas drilling byproduct per year into a national park connected public reservoir, rather than call for the thorough study using highest level of science and analytics to determine impacts, both direct and cumulative in nature, to the environment and human health. Summary Considering the weight of the risks of contamination of the west's most valuable resource, NPCA urges the state of Wyoming to immediately conduct additional, independent study of this proposed discharge, which accounts for impact to national parks and the broader connected watershed. At a minimum, the state of Wyoming should prohibit any oil and gas byproduct to be dumped into Alkali and Badwater Creeks, which would exacerbate potential environmental risks and impacts, until thorough, comprehensive analysis is conducted. As solution to wastewater disposal issue, we urge Aethon and state of Wyoming to pursue 21st century solutions that will ensure protection of human health and our national parks as well as allowing for oil and gas development to occur where appropriate without immense risk to Wyoming's watershed. Use of state-of-the-art water treatment facilities, technology and regulatory oversight, including whole effluent toxicity testing, full disclosure of chemicals to state regulators would aide in ensuring the protection of national parks and communities in the Yellowstone River watershed. Sincerely, Sharon Mader Senior Grand Teton Program Manager National Parks Conservation Association

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Comment From: Willis Patterson

7/05/19 @ 5:40 AM

If ever there was ever a situation where something will inevitable go wrong, .... This is it !! The drainage of TOXIC Chemical Waste into BOYSEN Reservoir has to be high on our Wyoming Resident's concern! It is Highly unlikely the DEQ would be abl...↓

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Comment From: Todd Smith

7/05/19 @ 5:18 AM

To whom it may concern, as a local resident of Fremont County I oppose the proposed dumping of waste water into Boysen Reservoir. This water way is the main source of recreation, fishing, and irrigation water for us and surrounding areas. I feel ther...↓

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Comment From: Matt Stefanich

7/05/19 @ 5:18 AM

According to the WDEQ water quality website, the Division "works to keep Wyoming's water clean by monitoring and protecting surface- and groundwater in the state." I ask the WDEQ perform its due diligence and deny this permit. This proposed draft per...↓

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Comment From: Brett McDonald

7/05/19 @ 5:02 AM

Discharge water from fossil fuel extraction is contaminated. I do not want this solution to be placed back in the environment in central WY.

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Comment From: Kevin Kershisnik

7/05/19 @ 4:48 AM

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Comment From: Linda Healow

7/05/19 @ 4:34 AM

I am commenting on the Moneta Divide discharge permit, WYPDES # WY0002062. I live in Billings MT. I have fished in the Bighorn River upstream from Hardin MT, have paddled Bighorn Canyon a number of times both from the MT side (Ok A Beh) and the WY...↓

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Comment From: Christine Lichtenfels

7/05/19 @ 4:33 AM

I live in Fremont County and enjoy Boysen, the Class 1 Wind River, and surrounding lands and habitat in multiple ways. This draft permit has numerous, significant legal and scientific deficiencies, too numerous to address here. Notably, the aquatic a...↓

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Comment From: Felicia Alvarez

7/05/19 @ 4:12 AM

Why would you deliberately poison fresh water - Wyoming may be vast in open space. This waste contamination will impact not only the environment, but animal habitats, water habitats, any human consumption this water way may feed. Not to mention the t...↓

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Comment From: Wayne Lax

7/05/19 @ 3:51 AM

My comments are in response to the Moneta Divide oil and gas field pollutant discharge permit - WYPDES Permit Number WY0002062 (Aethon Energy). Letting industry discharge millions of gallons of contaminated water into creeks and streams that flow in ...↓

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Comment From: Sharon Kearney

7/05/19 @ 3:34 AM

I urge Wyoming DEQ to reconsider allowing discharge of any kind or amount into surface waters running into Boysen Reservoir. Our ecosystems are struggling on all fronts where humans make amplified impact. We already have enlarging ocean dead zones, ...↓

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Comment From: Jean Harris

7/05/19 @ 3:26 AM

Water is our most precious resource. We are made of water, everything on this earth requires clean water to thrive. Including, YOU, who wish to pollute our water system. This is within the boundaries of the Wind River Indian Reservation, to which the...↓

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Comment From: Hot Springs Conservation Distr... (Sonja Becker)

7/05/19 @ 2:41 AM

Please see attached documents.

Attachments:

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Comment From: Merit Energy Company (Michael A. Williams)

7/05/19 @ 1:54 AM

Please see attached letter in support of the project with refined modeling, operational targets, and/or administrative control.

Attachments:

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Comment From: Carlos Martinez del Rio

7/05/19 @ 1:53 AM

This is an insane idea. Boysen Reservoir is important as a clean water source for Worland and Thermopolis. It is an important source for drinking and agriculture. It is also an important recreational fishery and a place where thousands recreate. It s...↓

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Comment From: Jeannette Reina

7/05/19 @ 1:49 AM

I am writing to clarify my previous comment. In the attached link, please open the "Tables" sections to see which chemicals are present in hydraulic fracturing wastewater. The lists are extremely long and frankly terrifying. It is imperative that yo...↓

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Comment From: Karen Zoller

7/05/19 @ 1:36 AM

Please do not �dump waste water in boysen/wind river. This river is for all people and it is not appropriate to be used as a dumping site. I know there are safer solutions to choose to dump waste water that will protect the environment and human hea...↓

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Comment From: John Swynarczuk

7/05/19 @ 1:10 AM

Absolutely not! How is this even remotely acceptable?

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Comment From: ROBERT HAGUE

7/05/19 @ 12:25 AM

I am in favor of this project! It would be a good boost to the economy and create jobs. Tks

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Comment From: Traci Mathias

7/04/19 @ 11:48 PM

I am outraged you would even consider allowing an energy company to dump processed water that was used for fracking in our precious water. I deeply oppose any and all dumping of contaminated water anywhere that harms humans or animals.

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Comment From: Martha Martinez del Rio

7/04/19 @ 10:50 PM

As a Wyoming resident and future inhabitant of Riverton, I strongly oppose any dumping of mining waters into Boysen Resevoir. The current Moneta proposal is an abhorrent idea - dangerous chemicals will pollute a vital resource for wildlife and peopl...↓

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Comment From: Robb Hitchcock

7/04/19 @ 5:00 PM

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Comment From: J. J. Joel Farber

7/04/19 @ 5:00 PM

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Comment From: Cynthia Newman

7/04/19 @ 4:47 PM

As an avid boater and user of Boyson Reservoir, I care deeply about maintaining or improving the water quality of the reservoir. I believe the discharge permit should require quarterly whole effluent testing, rather than annual. I think additional st...↓

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Comment From: Charlotte Belton

7/04/19 @ 4:02 PM

I have been following the discussions about the proposed discharge of water from oil and gas field operations into Badwater and Alkali Creeks, which water makes its way to Boysen Reservoir, then through the Wind River Canyon, on to the municipal wate...↓r supply of Thermopolis and beyond. Because the pollutants that Aethon proposes putting into the creeks have the potential to impact the quality of the reservoir, the river, its fish and bird life, the drinking water of downstream towns, and water used to irrigate crops we will eat, I ask that the DEQ thoughtfully place restrictions on the discharge. I understand that there was initially hope that the pollutants might be diluted adequately, but Wyoming people are aware that even though the reservoir is high this year, there are years when it is very low, with extremely low levels now seeming more possible. When the increased discharges from the future oil/gas production coincide with severe drought years, the level of pollutants in the river could seriously damage the fish of the Wind River or the quality of the drinking water in downstream towns. In any case, the water will be degraded, either to a greater or lesser extent. The DEQ and Aethon should explore how to clean the produced water of the petro- and any, perhaps unnamed, fracking chemicals before the water reaches our Class I Wyoming waters. It seems reasonable for the state to ask that the discharge be cleaned and then piped to Boysen, as Encana apparently planned to do. DEQ has an obligation to thoughtfully and thoroughly examine the financial and environmental consequences the people of Wyoming and the downstream communities will have to bear should Aethon be allowed to discharge pollutants into our waterways. The clean air and water of Wyoming are undeniably among Wyoming's most important resources. Because they seem "free" we may not value them adequately. There is not the drama of the boom and bust cycles of oil, gas and coal. Our clean water and air, the fish and the birds, don't have comparably well-funded lobbyists. But allowing the water and air quality to degrade harms the State in myriad ways – the health of our people and animals and crops, the quality of life, the environment we all treasure and which is part of intricate biological systems which connect far beyond our State or even our nation. I ask that the DEQ carefully weigh the immediate and future consequences of a permit. Sincerely, Charlotte Belton

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Comment From: David Zimmer

7/04/19 @ 1:06 PM

Please don't pollute another waterway! It is a sad testament to our lack of competent representation on both the State and National levels that would allow the dumping of toxic fracking chemicals into Boysen Reservoir.

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Comment From: Cindy Young

7/04/19 @ 9:15 AM

I am against discharge into Boyson Lake.

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Comment From: Robert Marcus

7/04/19 @ 9:05 AM

Cut the allowed limit for all categories I thru VI in half to prevent aquatic biological harm caused by the heavy influx from Badwater inflows, dilution measured at Boysen outflows does not mitigate the harmful concentrations at the mouth of Badwater...↓

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Comment From: Micah Carpenter-Lott

7/04/19 @ 8:09 AM

Micah Carpenter Lott Northern Arapaho Tribal member Moneta Divide Project 04 July 2019 To whom this may concern: On June 18th, 2019, I had the opportunity to join Trout Unlimited and other concerned citizens on a tour of the proposed expansion...↓ of the Moneta Divide Project. Many citizens shared their concerns about the project and the necessity to protect the numerous species of wildlife whose habitats will be affected if this project is expanded. For example, the native Sauger and Walleye that live and mate in tributaries such as the Poison Creek and Badwater Creek around the Boysen Reservoir. The justification that allows companies and regulators to minimize the damage is that they have been polluting these seasonal streams for 55 years and now Aethon and Burlington are asking to expand the destruction of our ecosystems and continue the misuse of public lands that would allow more than a million barrels of briny water every day into tributaries that flow into Boysen reservoir during interval times of the year. The short life spans of various species that live in and around these areas also are often overlooked when talking about long term risks. The short term benefits of temporary jobs and short-lived profits for corporations continue to be the main reasoning behind the projects in which regulators "hold the corporations hands" throughout the process, helping them jump through regulations, legalities and such in hopes that it stimulates local economies, and our independence from foreign fossil fuels while neglecting the land & its finite resources and trampling over Indigenous rights, human rights, and nature rights . SACRED SITES There are 3 sacred sites within the designated areas. including Cedar Ridge, a sacred site to 18 different tribal nations & their respective citizens and also Castle Gardens, which is within the buffer zone of the project area. The Castle Gardens Petroglyph Site is a 6-mile by 1-mile region of vertical cliff faces in Fremont County, Wyoming, with extensive petroglyph images incised in the rock faces. The petroglyphs include images of water turtles and circular shields, as well as human and animal figures. There has been consultation between the companies and the tribes but consultation doesn't mean consent. I am worried about these areas, their vitality, and safe access to these sacred sites for tribal members in the far future. NATURAL & RECREATION AREAS The permit to discharge produced water from oil and gas development into Badwater predates the Clean Water Act of 1972. With a name like "Badwater" & "Poison Creek," this also minimizes the effects on the environment downstream and the native and naturalized species that still live in these streams. There are 12 additional discharge permits that are already discharging into the areas. Aethon also has 5 aquifer-exempt permits that allow them to treat and pump water into the aquifer formation at designated spots. The amount of chlorine and salinity of the brine will affect plant life, wildlife, and human life as Boysen Reservoir is a recreational area and used to swim, fish, and camp for hundreds of people who live all over America. All of the discharge permits are outside the Wind River Reservation, yet, the water also could potentially flow into the Wind River, meaning flowing back into the exterior boundaries of the reservation putting Wyoming's most vulnerable people at risk for short-lived gains. I suggest you deny Aethons request for permits for the Moneta Divide Expansion Project.

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Comment From: Jeannette Reina

7/04/19 @ 7:55 AM

Please do not allow fracking water to be dumped into Boysen Reservoir or its tributaries. Any waste water should be treated to high quality drinking water standards and tested (before dumping) for any and all chemicals, and not allowed to be dumped i...↓

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Comment From: Brian Cooper

7/04/19 @ 5:57 AM

It appears to me that numerous questions were not properly addressed when the DEQ ok'd the release of millions of gallons of oilfield waste to be dumped into the Boysen reservoir tributaries. I have recently purchased property in nearby Shoshoni, WY...↓

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Comment From: Michele Irwin

7/04/19 @ 5:31 AM

Like most Wyomingites, my husband and I are not anti development. We know how important it is to the state. But we've also long held to the belief we could have "growth on our terms." That's what win-win solutions look like. Unfortunately, the ...↓

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Comment From: Lynne Berg

7/04/19 @ 4:57 AM

We must prevent polluted fracking wastewater from an oilfield from being discharged into Boysen Reservoir and the Wind and Bighorn rivers. The polluted water threatens our communities, outdoor recreation, human health, fisheries, and local economies....↓

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Comment From: Richard Page

7/04/19 @ 4:22 AM

I am against this proposal on all levels.

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Comment From: Tasia Naegle

7/04/19 @ 4:05 AM

Don't dump polluted water into our lakes, rivers, and streams. Tell the DEQ to analyze other options fordisposing of produced water (wastewater) from the Moneta Divide oil and gas field. If "surface discharge" ofproduced water is necessary, it shoul...↓d be purified and piped to Boysen Reservoir, not dumped into Alkali andBadwater creeks, where the effects on fish and water quality could be felt for hundreds of miles downstream.Don't trash Boysen State Park. Boysen is one of the most popular state parks in Wyoming — its waterquality should remain clean to protect swimming, municipal drinking water supplies, crop irrigation, boating,and fishing.Keep the Wind River clean. Tell the DEQ to maintain the quality of water that existed in the Wind River whenit was designated a Class 1 river in 1979, and to not use 2010-2016 water quality levels as the baseline forestablishing existing water quality.Too much salt is bad for you (and for fish!). Tell the DEQ to require Aethon to clean up its existingdischarge before allowing more pollution to enter these streams. In particular, the amount of chloride allowed inAethon's wastewater must be reduced to no more than 230 mg/L in order to restore and protect aquatic life inAlkali Creek and Badwater Creek. Existing chloride concentrations (in excess of 2,000 mg/L) are already muchtoo high to support sensitive aquatic life found in these desert riparian systems.Save our sauger! The DEQ must ensure that the toxic effects of produced water are properly disclosed andaddressed in the permit to ensure that sauger (a native species of fish related to walleye) are not harmed bythis project. For more information on the sauger, watch this video.What are the costs? The DEQ's draft permit fails to discuss the potential negative social and economicimpacts for the life of the project from increasing oilfield wastewater volumes to downstream communities.Such consideration is required by the Clean Water Act. Impacts to the Wind River's Blue Ribbon fishery, increased salts on crops, and potential retrofits to Thermopolis' drinking water treatment facility could besubstantial, yet the draft permit is silent on those issues. Tell the DEQ to follow the state's anti-degradationpolicies by requiring this analysis.Do you like your fish boiled or fried? The BLM's Moneta Divide draft EIS indicates that the temperature ofproduced water flowing from the wells is as high as 186° Fahrenheit, yet this issue is not addressed in theDEQ's draft discharge permit. Tell the DEQ to include a requirement to ensure that water temperatures inAlkali and Badwater creeks do not exceed the limits specified in the state's rules to protect fish and aquatic life.Require full toxicity testing. Tell the DEQ to increase the frequency of monitoring and testing of the effluent— liquid waste discharged into surface waters. "Whole effluent toxicity" testing of the discharge into BoysenReservoir should be required at least quarterly. Once a year is not sufficient.Water quality and flow data is missing. The DEQ cannot adequately assess the impacts to water quality if itdoesn't know the existing quality. If the DEQ is going to rely on a dilution model, it needs adequate flowinformation to ensure that water quality standards are going to be met, and that existing and designated usesin these streams will be protected.Say 'no' to grandfathering. Tell the DEQ that "grandfathering" high levels of chloride authorized in previousdischarge permits should not be allowed to continue. Multiple successive owners of the Moneta Divide oil andgas field (including Exxon, Tom Brown, Inc., and Encana) have had 40-plus years to comply with all applicablewater quality standards. The DEQ needs to end this legally dubious and environmentally unsound practice.The goal of the Clean Water Act is to restore and maintain water quality. Grandfathering historic and highlydamaging pollutant concentrations does not achieve that basic goal.Provide independent review. The DEQ hasn't established the scientific integrity of the model used by Aethonbecause it lacks the expertise and data to do so. Without this professional expertise in house, the agency mustcommission its own third-party review and make sure that the cost of that review is paid by the permitapplicant, not Wyoming taxpayers.Disclose all chemicals. Tell the DEQ to insist that Aethon disclose the trade names and amounts of allchemicals used in well drilling and fracking operations, and submit a plan to the public that ensures that thefracking chemicals contained in the "flowback" water are completely removed before being discharged intosurface waters

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Comment From: Tyler Martin

7/04/19 @ 4:01 AM

Absolutely not it will harm all wild life and plant life. It will turn that into a wasteland where plenty of people enjoy being able to go fishing and camping

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Comment From: Katherine Lenhardt

7/04/19 @ 3:42 AM

Stop the pollution of our water by oil and gas production, also mining.

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Comment From: Bonnie Bath

7/04/19 @ 3:20 AM

Wouldn't this action require a bit more study?

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Comment From: Kim Wilbert

7/04/19 @ 3:17 AM

Wyoming Department of Environmental Quality: Following are my comments I ask you to consider and respond to regarding Aethon Energy's application for a wastewater disposal permit for the Moneta Divide Field. Based on the concerns I enumerate ...↓below, I ask that the DEQ reject the permit application. My concerns are as follows: 1) Aethon's disposal plan is based on a dilution model designed by their contractor who apparently has no Wyoming engineering or geological certification, or recognition by Wyoming licensing agencies. Further, just the fact that the consultant creating the modeling data is totally bought and paid for by the company desiring the permit makes me very suspect. The model proposed must be thoroughly examined and investigated by licensed Wyoming engineers and geologists who are independent of the company benefiting from the proposed permit extnesion. 2) The whole premise of the permit, that Boysen Reservoir is to act as a water treatment facility for oil field wastewater, laden with a host of salts and toxins, is counter to the recreational and ecological values of this important central Wyoming lake. The current legally recognized beneficial uses of Boysen include drinking water supply, contact recreation, and cold-water fishery. The addition of wastewater treatment as a use is contrary to these long standing other beneficial uses. 3) The entire permit is based on a premise that everybody acknowledges is not based in reality. The model assumes that all the wastewater, treated and untreated, magically mixes (all 16 discharge points are physically separate, and would depend on stream flows in Alkali and Badwater Creeks to mix with other flows) and all flows some 40 miles downstream to Boysen. Yet the DEQ, and certainly local folks realize that Badwater only typically flows all the way to Boysen very sporadically. Even though the permit contemplates the higher flows of additional production water being dumped into these natural streams, the higherst flows amount to about 12cfs. Where is the analysis that demonstrates how far that production water will actually flow, especially during dry years So why is the permit model based on a fantasy that all the waste water uniformly flows in those drainages all year around into Badwater Bay? The answer to my question may be that the engineering is much easier than trying to model the real situation. Tons and tons of chloride and sulphate salts enter the drainages from the discharge points. Most of the time, all those pollutants will get deposited into sediments in the drainages, to lie there until larger flows carry them downstream. How often that may happen is up to the weather, but certainly not contemplated in the model. This is important because the dilution model is based on the pollutants continually reaching Boysen, whereas in reality, they may likely only reach Boysen in surge events, radically changing the concentrations. There have been periods of several years when Badwater virtually never flowed all the way to Boysen, times like 2000-2005. So, how does the model work when a big summer thunder storm causes a big flood down these ephemeral creeks, and pushes thousands of tons of sediment, with years of toxins included, into Badwater Bay? How will the sauger spawning beds do with two years worth of chloride and sulphate flowing in there in one day? 3) Why is the DEQ totally unconcerned with pollutants and toxins in Badwater Creek? With it's designation as a Class 2AB waterway, Badwater should get careful consideration as to what all these chemicals and salts are doing to that desert stream. This project proposes to dump tons of pollutants into this natural stream, impacting the entire ecosystem of Badwater Creek for many miles. The whole riparian zone of this unique waterway will be impacted, but I see no analysis of these impacts. The salts will heavily impact riparian terrestrial vegetation, not to mention aquatic plants and animals. We must see careful analysis of aquatic invertebrates and plant life in Badwater Creek, upstream of any oil field discharges, as compared to various points downstream of where Alkali with all the production water joins the drainage. 4) The proposed permit, as well as the current operating procedure, depends on the field operator adding a portion of treated water from their reverse osmosis facility, the Neptune Plant. Further, the permit applicant claims they can get up to 50% more capacity out of that plant than it is rated for. Yet, at the DEQ meeting in Thermopolis, we heard that the plant is often off line, and that it has never operated at rated capacity for any significant period of time. The operator's ability to consistently treat the portion of the production water required by the model, is not based in fact. The track record of Neptune, since it went on-line in 2015 to present should be the basis of the model, not Neptune's rated capacity, and certainly not on greatly improved outputs as imagined and hoped for by the operator. 5) To my ears, the DEQ is trying to pass off this plan to dump hundreds of thousands of tons of pollutants into natural Wyoming waterways as acceptable because, first, Alkali and Badwater Creeks have always had crappy water quality, and second, the Bighorn River system has long had lots of oil field chemicals flowing in from this oil field and well as many other oil fields. Why not add a bunch more nasty stuff? The effects of oil field discharge into Badwater Creek, a Wyoming Class 2AB waterway are not carefully considered in this permit application. Further, because we are already adding bunches of nasty stuff to the Bighorn system does not make it acceptable to add a bunch more. Two bunches might add up to disaster. 6) The whole premise of the proposed operating model is to find the maximum amount of pollutants that the operator can put into Boysen without exceeding maximum limits in the Wind River below the reservoir. The DEQ says, for totally unknown reasons, that it is ok to raise the pH of the ENTIRE WIND RIVER from pH 8 to pH 9!!! That is an order of magnitude more alkaline, as the pH scale is logarithmic, not linear. Water at a ph 9 is very poor water quality in terms of plant life. Many essential plant nutrients are not available to most plant types (like Cottonwood trees, and most other trees, shrubs, grasses and forbes) from soil solutions at pH 9. I know this because my wife and I owned and operated a greenhouse and plant nursery in Riverton for 25 years. Our customers with high pH well water often could not successfully grow most local landscape plants. High sulphates, high chlorides, and high pH = not much grows. Our own greenhouse growing operations were impacted by pH change, from pH 8.2 Riverton city water in the winter when our water is from the city wells, to pH 7.8 when the city switches to treated river water in May. Of course, we also saw a drop in dissolved salts when the water quality changed every spring. We had to very carefully monitor our fertilizer applications in concert with these swings in water quality. The point is, adding salts and raising pH creates big impacts to plant life. How can it be acceptable that the permit may allow raising the pH of the Wind River to a level TEN TIMES AS ALKALINE AS PRESENT?? The baseline measure of pH8 is ALREADY MUCH HIGHER THAN THE NATURAL RIVER WOULD BE BECAUSE OF POLLUTED INFLOWS. We must see the DEQ provide careful analysis of the impacts of pH 9 water in the Wind River on the whole riparian system, as well as downstream uses. In conclusion, I am adamantly opposed to this permit extension. We need to be trying to figure out how to make our waters safer and cleaner. This permit allows just the opposite, allowing the field operator to add tons of pollutants to the river system, and knowingly making the water quality worse by every metric as it goes downstream. Please, let's not allow this to happen. The idea that we will keep dumping into the river, right up to the maximum amount allowed, is abhorrent, and absolutely contrary to any reasonable notion of excellence in environmental quality. Kim Wilbert 1400 W Park St Riverton, WY 82501 dkimwilbert@gmail.com

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Comment From: Robert Nagel

7/04/19 @ 2:52 AM

Dear WY DEQ, I am writing to express my strong opposition to issuing Aethon Energy a discharge permit to dump fracking waste water into Boysen Reservoir. Why on Earth would you allow contaminated water from fracking to be dumped into a reservoir w...↓

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Comment From: Val Snyder

7/04/19 @ 2:32 AM

Of all Wyoming resources, our water is of most importance, without clean water, the state is uninhabitable. Allowing our water resources to become contaminated by industries whose profits are taken outside the state is allowing the poisoning and pl...↓

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Comment From: Jim Dodds

7/04/19 @ 1:56 AM

This should not even be allowed. I want clean water and recreation. Do not put my health below Texas oil profits.

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Comment From: Jim Dodds

7/04/19 @ 1:51 AM

This should not even be allowed. I want clean water and recreation. Do not put my health below Texas oil profits.

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Comment From: Ahliilai Hatch

7/04/19 @ 1:20 AM

Keep boysen clean! This is my families favorite lake to spend our summer, keep it safe for our families. Keep it all natural!

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Comment From: Guy Harris

7/04/19 @ 1:07 AM

I, my friends, my family, and my animals all spend multiple weekends throughout the entire year enjoying the recreation and fishing available from boysen and it's beautiful outlying rivers. Pouring this wastewater into any of wyomings beautiful lands...↓

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Comment From: Elaine Balius

7/03/19 @ 10:57 PM

The thought that a company be allowed to poison water is never a wise choice. Find another way that doesn't destroy natural resource like water. Why would you intentionally do something that insane? Don't do it.

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Comment From: Jared Keplinger

7/03/19 @ 9:47 PM

I personally find it abhorrent that you'd in any way shape or form allow or entertain the idea of allowing 190,000 barrels of produced water to be dumped into a fresh water supply. Saltwater of this sort is deadly and toxic in many many ways, just r...↓

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Comment From: Vikkilyn Frank-Robledo

7/03/19 @ 5:53 PM

I am greatly concerned about the proposition by Aethon (Moneta Divide) to allow dumping of produced water from gas and oil fields into Boysen Reservoir. There is no doubt in my mind that this will negatively affect the water supply and the wildlife ...↓

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Comment From: Kris Hunter

7/03/19 @ 5:12 PM

I can't believe this is even a possibility! When you read through the list of pollutants and poisons, who would ever allow any waste water from oil and gas production, to be dumped into a reservoir, that is used for DRINKING water and game fishing???...↓

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Comment From: Bruce Bulman

7/03/19 @ 4:10 PM

Boysen Reservoir is too important to pollute with contaminants. Once this action is taken it cannot be reversed. Do not allow this tragedy to take place.

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Comment From: Emily Petty

7/03/19 @ 3:44 PM

I am not supporting this discharge permit. One thing I love about Wyoming is its natural beauty and the outdoor recreation activities it has to offer. This permit is a threat to both. You need to find another option for this discharge that will not e...↓

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Comment From: Jean Nelson

7/03/19 @ 2:56 PM

I strongly oppose the dumping of oil field water into Boysen Reservoir!

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Comment From: Linda Kracht

7/03/19 @ 1:55 PM

NO WASTE WATER IN BOYSEN. Build a recycle center to recycle it. DO NOT SCREW UP OUR FISHING.

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Comment From: Kyle Welsh

7/03/19 @ 1:06 PM

To Whom this may concern: Don't let poison in Boysen. Wyoming's economy depends on a healthy ecology brought in by out of state wildlife monies. Quit giving the oil industry a free pass on destroying Wyoming' s beautiful landscapes for generatio...↓

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Comment From: Duane Schweigert

7/03/19 @ 12:56 PM

The discharge permit will forever pollute the waters of Boysen Dam and all downriver users. What kind of DEQ does Wyoming have that allows pollution from a fossil fuel development that is a short time benefit to a dying industry. Renewable energy is ...↓

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Comment From: Alanita White

7/03/19 @ 12:35 PM

As a citizen of this Equality State i strongly disagree with any pollutants being allowed to flow into Boysen Reservoir or any other body of water. I have confidence that the DEQ will realize the importance of clean water...not only for humans but f...↓

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Comment From: Alanita White

7/03/19 @ 12:34 PM

As a citizen of this Equality State, Wyoming, county of Fremont located on the Wind River Reservation, I strongly disagree with any pollutants being allowed to flow into Boysen Reservoir or any other body of water. I have confidence that your compan...↓

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Comment From: sarah krall

7/03/19 @ 12:26 PM

I have already sent one letter to you. I can not believe I still have to fight against and try to politely oppose this mad idea. Stop fracking water from being dumped into Boysen Reservoir. !! Please. Please. Use commonsense (common sense) and ...↓

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Comment From: TODEEN DARLINGTON

7/03/19 @ 11:26 AM

My name is Toddi Darlington, I live in the Wind River Canyon, 3 miles north of Boysen Dam. I attended the public meeting held in Thermopolis on the Atheon Discharge Permit. This permit depends on a holding bay strategy, where discharge water is mix...↓ed with clean water as it enters Badwater Bay. It assumes Boysen remains in a constant state. What happens if the mixing bay no longer exists? I asked one of the Wyoming DEQ representatives if they had considered the possibility of the dam being destroyed by an earth quake. They hadn't. That thought had not entered their mind. I doubt they considered drought as well. Assuming Boysen will stay in a constant state with an ever-present mixing bay is foolish. No one can predict the future. This permitting process should address the possibility of the mixing bay no longer existing. Not doing so is irresponsible. I have experienced two earth quakes in the Wind River Canyon. Boysen dam is an earthen dam. The permit does not address what happens if the dam is damaged or destroyed by a natural disaster like an earth quake, or by a manmade disaster like a terrorist act? Boysen carrying capacity would be reduced considerably. The mixing bay could no longer exist. What is the contingency plan if this happens? This should be addressed in the permit. I have also experienced severe droughts over the years I have lived in the Canyon. I have seen Boysen water levels lowered drastically. I have seen the proposed mixing bay itself lowered considerably during drought years. What happens if water levels in Boysen lower to the point of eliminating the mixing bay through drought? This is not addressed in the permit. I would also like to address the following, as presented through bullet points. 1. The executive summary mentions, in its opening statement, that the Wind river and Big Horn River below Boysen Dam is a Class 1 water. The Water Quality Compliance Analysis fails to confirm that the Class 1 waters below the dam will not be degraded. 2. DEQ's Anti-degradation Policy (2013 Wyoming Surface Water Quality Standards), states that no permit shall degrade water quality in any tributary to Class 1 waters. By Approving this Discharge Permit, DEQ would violate its own Anti-Degradation Policy. 3. The Executive Summary only addresses the methodology, and does not summarize the findings or conclusions of the Water Quality Compliance Analysis. It is a prelude to, rather than a summary, of the main document. The Executive Summary should conclude with a summary of the findings of the Water Quality Compliance Analysis. 4. The last paragraph of the Executive Summary on Page 22 states "Chronic water quality criteria outside the mixing zone (Badwater Bay) with the reservoir is met in all three flow conditions." This assumes that mixing is thorough and instantaneous beyond Badwater Bay, and ignores the effects of stratification – a known factor in Boysen Reservoir. These questions raise significant concerns about future water quality in future dam releases. 5. Irrigators below the dam are already troubled by high salt content in irrigation water from the Big Horn River. This proposal would cause DEQ to raise the upper limit of allowed levels of chloride in Boysen. Elevated salinity would be detrimental to downstream agriculture. Until these concerns are addressed in the permit, I object to the discharging of water into Boysen Reservoir.

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Comment From: Rebecca Dankert

7/03/19 @ 11:19 AM

Until it is proven that fracking water doesn't hurt wildlife water life fowl animals or people it should not be carelessly dumped. Research and be proactive instead of dumping and then having to be reactive to the demise of animals etc.

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Comment From: Cynthia Dietzmann

7/03/19 @ 11:08 AM

Stop fracking water from being dumped into Boysen Reservoir!!!!! Protect our clean water. All produced water from oil and gas fields must be treated to remove all toxic contaminants before being dumped into Boysen Reservoir and its tributaries. ...↓

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Comment From: Allen DARLINGTON

7/03/19 @ 11:01 AM

My name is Al Darlington, I live in the Wind River Canyon, 3 miles north of Boysen Dam. I attended the public meeting held in Thermopolis on the Atheon Discharge Permit. This permit depends on a holding bay strategy, where discharge water is mixed ...↓

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Comment From: Walter Steele

7/03/19 @ 10:35 AM

Are you people out of your mind? Over 8 million gallons of oilfield waste into good clean water?!?! Whoever thought this idea was a good idea needs to be fired or sent for a psych evaluation. To purposely poison the rivers and boysen with this is out...↓

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Comment From: Lisa Rozar

7/03/19 @ 10:34 AM

Don't allow poisoning of Boysen reservoir

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Comment From: Tara Adkison

7/03/19 @ 10:29 AM

That is the absolute worst thing in the world that you could ever do to the environment around here. I seriously think that you could come up with a better way to dispose of your waste and save the environment. Do not be evil like the rest of corpora...↓

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Comment From: Kristine McGuire

7/03/19 @ 10:18 AM

Keep Boysen Clean.

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Comment From: Carol Lundgren

7/03/19 @ 10:18 AM

Please protect our water

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Comment From: Rebecca Gallaher

7/03/19 @ 10:05 AM

Please do not allow Aethon Energy to dump over 8 million gallons of produced water from oil and gas fields into Boysen Reservoir. Protect our clean water. All produced water from oil and gas fields must be treated to remove all toxic contaminants be...↓

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Comment From: Kim Accurso

7/03/19 @ 10:01 AM

Regarding the Aethon discharge application, as a life-long citizen of Wyoming whose family, on this 4th of July weekend, is enjoying time on the lake, just as we and many other families have done year after year, throughout the summer, I am absolutel...↓

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Comment From: Terry McClellan

7/03/19 @ 9:41 AM

Allowing fracking companies to dispose of their fracking water into a reservoir is just stupid. Regardless of what regulations are in place to make sure this water meets some theoretical safety minimum standard, do you think I actually trust frackin...↓

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Comment From: Jody Garland

7/03/19 @ 9:24 AM

There is no possible justification for polluting water. People, animals, food sources all depend on clean water. The fracking company, its employees and families all need clean water. I can't imagine allowing an industry to dump their chemicals in a ...↓

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Comment From: Kathy Jensen

7/03/19 @ 9:22 AM

Please, NO! Do not dump fracking waters into Boysen res. There is so much water already. I'm on the Big Horn River coming from Boysen's dam and our River is extremely high. The fish will not benefit, but face possible harm. No! No!

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Comment From: Anne Scott

7/03/19 @ 8:57 AM

PLEASE DO NOT APPROVE THIS PLAN! It would be very shortsighted to allow more polluted oil field wastewater into this valuable freshwater resource. Please think of all of the downstream effects on anglers, sportsman, boaters and human beings. Plea...↓

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Comment From: Multiple fishing businesses (Nick Dobric)

7/03/19 @ 8:43 AM

Letter attached

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Comment From: DEB FRENCH

7/03/19 @ 8:37 AM

It is really disheartening to know that you are willing to give up one of the few nonrenewable resources for money.we can't live without water and neither can you. We should support solar and wind resources that everyone can benefit from while preser...↓

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Comment From: Charles Mickelson

7/03/19 @ 8:21 AM

What a dumb idea. Sounds like something trump would dream up

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Comment From: Brooke Brewer

7/03/19 @ 7:55 AM

DIG A HOLE AND PUT IT IN THERE. BURN IT. SEND IT TO SPACE. DONT DUMP A HARMFUL SUBSTANCE INTO A PLACE WHERE YOU ALL ARE FULLY AWARE OF THE OUTCOMES. WHY WOULD YOU WILLINGLY POISON AND KILL THE LIVINGS THINGS THAT WILL BE IN HARMS WAY. ALSO- WHY WOULD...↓

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Comment From: Richard Clark

7/03/19 @ 7:30 AM

I have reviewed the draft permit and supporting modeling. I am very concerned about the discharge of waste water into Boysen Reservoir, the waters of which are important to recreation and agriculture. The discharge of any effluents into this body o...↓

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Comment From: Mark Heineken

7/03/19 @ 7:30 AM

Please deny this permit. This is too risky given the potential impacts to Boysen as well as the incredible Wind River canyon and downstream communities.

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Comment From: Mary Orr

7/03/19 @ 7:24 AM

I hope I'm missing something here, but I am pretty sure that dumping that much waste into any waterway should be a crime. I am going to assume you guys have this covered and won't approve this permit, but just in case you are somehow confused as to y...↓

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Comment From: Laney Hicks

7/03/19 @ 7:24 AM

It is beyond my understanding how it can even come up to think about dumping fracking water into Boysen Reservoir. This is the source of irrigation for thousands of acres of farmland downstream, not to mention recreation on the lake and fisheries. ...↓

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Comment From: Cathy Lewis

7/03/19 @ 7:15 AM

Please don't pollute my family's water and our source of joy. It can't be worth it to take this from Thermopolis. Sincerely Cathy Lewis

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Comment From: Ron Harper

7/03/19 @ 7:07 AM

Please do net allow the discharge into Boysen Reservoir. Proposing to do so is simply insane!

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Comment From: Bruce Ostermann

7/03/19 @ 6:59 AM

To the Department of Environmental Quality, Do not let more produced water into Boysen. I have recreated on it extensively since 1985. You need to look at the drought years when it was so low. It can't take more salts and pollution. The ground in W...↓

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Comment From: Barbara Hawkins

7/03/19 @ 6:55 AM

Protect our clean water. All produced water from oil and gas fields must be treated to remove all toxic contaminants before being dumped into Boysen Reservoir and its tributaries. It's not worth the risk. Downstream communities like Thermopolis an...↓

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Comment From: Sister Ruth Hehn

7/03/19 @ 6:53 AM

Please don't contaminate the beautiful water that gives such pleasure to many people who count on the water for healthy fish and being able to swim and ski without fear of being infected with some disease or illness. Thanks for taking care of peo...↓

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Comment From: MICHAEL QUIVER

7/03/19 @ 6:49 AM

The produced water that is being dumped into Boysen Reservoir will eventually kill the part of the reservoir where the produced water is being introduced. It will affect that part of the reservoir and will eventually affect whatever else is downstrea...↓

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