Letter to ODNR
By Bernhard Debatin
Dear Director Zehringer and Chief Simmers,
I am respectfully submitting my comments and concerns regarding the K&H2 permit application in Athens County.
In accordance with Ohio Revised Code 1501:9-3-06 (C), I ask you to immediately suspend the permit process for the K&H well and initiate thorough seismic and other necessary studies before further considering permitting this injection well. Furthermore and in accordance with Ohio Revised Code 1501:9-3-06 (D), I ask you to suspend delivery of fracking waste fluids to the existing injection wells in Athens County until seismic studies have been concluded. I also ask you to take appropriate measures to seismically monitor the wells and to monitor potential waste water migration by drilling monitoring wells around the existing injection wells according to EPA standards.
As you know, a 3.5-magnitude earthquake struck the northwestern part of Athens County near Doanville on November 20 at 12:59 p.m. (see http://earthquake.usgs.gov/earthquakes/eventpage/usb000l2y3#summary). Regardless of whether the earthquake in was caused by local injection wells or not — either way, the mere occurrence of this earthquake makes injecting fracking fluids in our area a potentially dangerous and irresponsible activity. Every earthquake, injection-induced or not, may introduce new faults and fractures or extend existing ones that then can serve as a migration path for polluted waste water into underground sources of drinking water (USDW).
An EPA training document for designing and constructing injection wells states:
“It is important that the formations intended to seal the injection interval from the USDWs are free of intersecting faults and fractures. If faults or fractures are present, the injected fluid, introduced into the injection interval at an elevated pressure, will seek the path of lower pressure and move upward into a USDW.” (U.S.EPA 2002: Introduction to UIC Permitting. April 2002, p. 1-64. http://water.epa.gov/learn/training/dwatraining/upload/dwaUIC-uicpermit.pdf).
In other words, the creation and extension of fractures due to injected fluid may not even require significant seismic activity. Additionally, fracking fluids contain lubricants and sand, used to lubricate and prop open the fracked shale formation in order to release the trapped oil or gas. Fracking waste fluids will likely have a similar lubrication effect when introduced into an injection well and thus facilitate the emergence of fissures and cracks.
Moreover, both injection pressures and the injected volume exert considerable forces on the area where the fluids are stored. This is a known cause of the creation of new fractures or the extension of already existing fractures, which then may lead to a pollution of underground drinking water sources. This is why the above cited EPA document requires not only limiting the injection pressures, but also that
“Class II wells must be sited so that they inject into a formation that is separated from any USDW by a confining zone free of known open faults or fractures within the designated area of review.” (U.S.EPA 2002, p. 1-70)
No such requirement appears to be mandated by ODNR, contradicting the agency’s statement that “Ohio’s Class II disposal well regulations meet, and many instances, far exceed U.S. EPA regulations.” (ODNR 2013: Class II Disposal Well Reforms/Youngstown Seismic Activity Questions and Answers, p. 1. http://ohiodnr.com/downloads/northstar/YoungstownFAQ.pdf). ODNR does not seem to require seismic and geologic studies that would allow to determine whether there are faults and fractures in the vicinity of the planned injection well.
In fact, the current K&H2 application does not includes any seismic data, nor is the specific geological situation of the site known (i.e. with respect to existing faults and fractures). At the same time, the K&H2 injection well, if approved, would be the largest fracking waste water disposal site in Ohio with a planned volume of 63,000,000 gallons per year.
The Youngstown earthquakes have shown that the injection of waste fluids can cause a series of earthquakes. ODNR confirmed: “Evidence gathered by ODNR regulators and geologists suggests that fluid from a deeply drilled injection well intersected an unmapped fault in a near-failure state of stress causing movement along the fault.” (ODNR 2013, p. 1)
The consequence was the immediate shutdown of the involved injection wells. The November 20 earthquake in Athens County has shown that we live in a seismically active area, regardless of whether this activity was caused by natural tectonic movement or induced by the injection wells in our area. Furthermore, it is unclear and thus needs to be investigated if this earthquake created new faults and fractures that could reach the injection wells. I therefore urge you, again, to suspend the permission process and the injection of fluids in the existing wells.
The ODNR FAQ document on the Youngstown earthquake states, “All of the conditions associated with induced seismic activity can be addressed in the well permitting and construction process…” (ODNR 2013, p. 2). So far, it appears that ODNR has not taken any steps to address the seismic problems of our area in the permitting and construction process of injection wells in our area. Permitting the K&H2 well without a seismic survey would be reckless. As stated at the beginning, the Ohio Revised Code authorizes you to require such investigations and to suspend all activities until you have evaluated the results of any tests performed.
Finally, I also want to point out that even without seismic activity, the practice of injecting high volumes of polluted water into underground wells is potentially dangerous and irresponsible. It is a known and scientifically established fact that the cement casings of injection wells will fail over time. The question is not if, but only how soon they will fail. In other words, even without seismic activity, there is a risk, increasing over time, that aquifers will be polluted by toxic waste water.
I assume that you are aware of the fact that only the gas and oil industry is allowed to dispose this type of toxic waste water in unmonitored class II injection wells. The same waste water, coming from any other industry, would be considered hazardous waste and would need to be disposed of under much higher safety requirements.
The disposal of fracking waste fluids puts the health and well-being of the people in Athens County at risk even under normal conditions. The recent earthquake has sharply increased this risk and clearly brought to light that we can’t naively assume that Athens County is a seismically quiet area simply because no significant earthquake had occurred for a long time.
I therefore request, as already stated at the beginning, that you suspend the K&H2 permission process, initiate appropriate tests and surveys, and suspend all and any fracking waste water injections in Athens County.
Dr. Bernhard Debatin
Professor of Journalism (Ohio University)