Comments due Nov. 30, 2015. Tell ODNR enough is enough!
Here’s the ridiculous permit application.
Will this document ensure protection of our groundwater and drinking water? Of course not!
Will it ensure there won’t be spills and leaks into the Hocking River? Of course not!
Will it ensure there won’t be non-stop air emissions of toxic volatile organic compounds? Of course not!
The Division of Oil and Gas doesn’t care about your health. Tell them what you think of their management of our drinking water supplies, which they are legally obligated to protect!
Key points: A “well” is not a container. It is a hole in the ground. ODNR does no geologic evaluation to ensure that what is pushed down won’t come back up through fissures, old wells, or new fractures from increasing earth movement throughout the continental plate.
RE: PERMIT # APATTO27661
CC: Ms. Susan Hedman, Regional Administrator, USEPA Region 5 email@example.com, State Senator Lou Gentile: firstname.lastname@example.org, State Rep. Debbie Phillips Rep94@ohiohouse.gov, Athens County Commissioner Lenny Eliason email@example.com
Dear Chief Simmers:
I write in strong opposition to the proposed Athens County injection well Atha #2, #APATTO27661, which is likely to cause long-term harm to our community’s air, water, public health, and property values and is a safety concern, not only because there will be constant air emissions and because there is no reason to think that the waste won’t find a way to the surface but also because the site lies along the Hocking River and on a windy, hilly road.
I list here just a few of the many concerns that I share with many in our community who are not able to respond within your very short comment period, timed once again during family holidays:
- This is a highly deficient application that will not prevent pollution of land, surface water, and drinking water sources as required by Ohio law (OAC 1501:9-3-04). There is no geologic data presented to protect water supplies—drinking water, groundwater, and underground water sources—or public health, safety and environmental conservation. There is not even a map provided in the application!
- The Chief unlawfully and unreasonably approved the permit for the first Atha Frost well in a manner that does not protect underground sources of drinking water in violation of federal and state requirements governing the injection of oil and gas waste liquids.
- There is no reference as to nearby aquifers as USEPA requires, thus showing the inadequacy and therefore illegality of Ohio’s injection well program.
- There is no provision in the application or ODNR regulation that can assure the public that surface water contamination, including major truck or equipment spills into the Hocking River, can be prevented. ODNR is charged with these environmental, safety and health protections by state and federal law.
- Aquifers of the region are not mapped and so are not taken into account in the siting and plans for this well, in violation of Safe Drinking Water Act and USEPA standards, thus showing the illegal inadequacy of ODNR’s injection well program.
- The Atha site is so close to the Hocking River that any spill, such as the recent spill at the nearby K&H site from K&H#1 in which 15 tons of contaminated soil was removed downhill from the well site, would potentially pollute drinking water supplies for millions of downstream Hocking and Ohio River water consumers. The Sept. 2015 K&H #1 spill reports also give no indication that the removal of the 15 tons of contaminated soil resulted in adequate remediation of the site. ODNR has no remediation or enforcement standards. Was this removal merely surface scraping? What tests determined that the removal was adequate to prevent contamination of surface and drinking water supplies near K&H #1? What was done with the contaminated soil and what assurance does the public have that the contaminated soil, if dumped in a sanitary landfill, will not continue to pollute our region’s surface and ground water and drinking water supplies? How would permitting of the Atha well insure that such a spill, potentially resulting in contamination of drinking water supplies for millions of downstream water customers, could be prevented? It was not prevented at K&H #1. How would the Atha #2 well be any more likely not to have spills?
- The June 2014 weeklong Eisenbarth fire in Munroe County Ohio, which resulted in the death of over 70,000 fish and countless other unnamed species and contamination of a tributary of the Ohio River upstream of drinking water intakes, is an example of what can and has happened in Ohio when frackwaste tanks explode and burn. This application for the Atha #2 well, relying on similar tanks filled with explosive hydrocarbon mixtures and located only hundreds of feet of the Hocking River, cannot give us any assurance that such a catastrophe will not happen in our county and along our Hocking River, upstream of millions of Ohio River water customers.
- The Atha #1 injection disposal well at the same facility has shown in multiple incident reports that well integrity has been breached numerous times, indicating that another well operated by Mr. Atha at the site may likely result in adverse effects on human health and contamination to ground water, prohibited by R.C. Chapter 1509 and the federal Safe Drinking Water Act.
- ODNR does no monitoring of drinking or ground water around its injection wells, including the current Atha well, so neighbors will not know when contaminants find a pathway to groundwater from Mr. Atha’s wells. There is no assurance that the Atha #1 has not already contaminated local drinking water sources and the Hocking River.
- Studies of oil and gas waste emissions confirm that benzene and other known human carcinogens are present, often at extremely high and often illegal levels. ODNR does no air monitoring around its injection wells, so neighbors will not know what chemicals they are being subjected to in the air they breathe. The current facility with its multiple storage tanks continually vents toxic hydrocarbons and volatile organic compounds directly into the riverine community, leading to chronic exposure of chemical combinations for anyone living along the river.
I request a public hearing in Athens County based on my substantive concerns with the serious deficiencies of this permit application to prevent contamination and pollution of surface of the land, surface water and groundwater, as required by Ohio Administrative Code 1501:9-3-04, which states: (A) All persons engaged in any phase of saltwater disposal operations shall conduct such operations in a manner which [sic] will not contaminate or pollute the surface of the land, or water on the surface or in the subsurface…” My concerns, substantive and relevant to public health, safety, and environmental conservation, merit a public hearing because Ohio law requires that the Chief grant a public hearing if ANY comments are substantive and relevant to health, safety, or good conservation practices. (OAC 1501:9-3-06 (H)(2) (c)). There is no stipulation that can be added to such a deficient application, governed as it is by an illegally deficiently protective regulatory system, that can effectively address these substantive and regulatory concerns. This application should be withdrawn.