Fracking Waste Injection Well Fails - Why Build Five More Possible Failures in Brookfield Ohio?

News Release:
Frackfree America National Coalition, based in Youngstown, Ohio
 www.frackfreeamerica.org
Buckeye Environmental Network www.buckeyeenvironmentalnetwork.org
Center for Health, Environment and Justice (CHEJ)  www.chej.org
_______________________________________________________
For Immediate Release:  November 27, 2017
Contact: Jane Spies, M.S. Ed.: Phone:  330-619-0730 or   234-201-8007 or
e-mail:  frackfreeamerica@gmail.com
Contact: Teresa Mills: Phone:   614-507-4406 or e-mail:   tmills@chej.org
_______________________________________________________

Groups will hold a public town hall–style, panel discussion meeting in Brookfield, Ohio about five proposed fracking waste injection wells planned to be sited in Brookfield way too near family homes, businesses, and government buildings.

       Concerned Brookfield citizens and groups will hold a town hall-style, panel discussion meeting on Thursday, November 30, 2017 at 7 PM to 9:30 PM at the Brookfield Fire Hall, at 774 State Route 7 NE, Brookfield, Ohio, 44403 to provide information and to let the community voice their concerns regarding five proposed fracking waste injection wells.[1] The wells are planned to be located in the Brookfield community in a highly populated area too close to known epicenters of man-made earthquake activity.[2] The meeting is free and open to the public. Groups helping to coordinate the meeting are Frackfree America National Coalition, based in Youngstown (www.frackfreeamerica.org ), Buckeye Environmental Network (www.buckeyeenvironmentalnetwork.org ), and the Center for Health, Environment and Justice (www.CHEJ.org ).
       Construction of a fracking waste injection well site in Brookfield, Ohio has begun[3] as of about November 13, 2017, but it’s not a “done deal,” say the groups, as additional Ohio Department of Natural Resources (ODNR) permits are required for the company to fully operate and inject fracking waste – much of it to come from out-of-state if the wells are eventually approved.  Highland Field Services, a Seneca Resources subsidiary, is the company planning to site five injection wells in the Brookfield community.[4]
       Citing unanswered questions about an apparently mysteriously abandoned old injection well near the Brookfield high school and other serious public health and safety concerns,[5] groups call for the Ohio Department of Natural Resources (ODNR) to revoke and deny drilling permits and to immediately halt current injection well construction in Brookfield, Ohio, that is reportedly already slowing traffic.

       One would think that if an attempted siting of an injection well near the high school in Brookfield [6] seems to have failed for some reason, that failure should be thoroughly scrutinized, publicized, and scientifically understood before any other company tries to locate five more injection wells in essentially the same geologic area.  It’s just common sense. It’s transparency.

        Why didn’t the older injection well in Brookfield, called the Hray-Mullenax well, become active? Was American Energy Associates’ request to ODNR to plug their injection well ever approved by ODNR? [7]  What’s to prevent the same or a similar situation from reoccurring at the new proposed injection well site near Wyngate Manor in Brookfield if officials just rush ahead without fully understanding or adequately disclosing the history of what might have happened at the older injection well?
       A public records request has been submitted to ODNR, and we eagerly await their answers to some crucial questions about why the old injection well, the Hray-Mullenax, apparently has been abandoned.  (The old injection well is hereafter referred to as Hray in this document.)
      Why would the Hray injection well owner put enormous amounts of money, over a period of perhaps years, into constructing the injection well and then just decide to leave and walk away, if he did, especially after ODNR inspection reports [8] indicate that “most of the surface facility” had been constructed, according to an inspectors’ note of December 19, 2016? [9]
       Furthermore, according to two ODNR inspection report entries of the Hray injection well dated 10/10/2014 and 10/11/14:
“ … Circulation was lost at approximately 155 feet deep. …”   “A mine sting [sic] was set through a suspected mine void at approximately 152 feet deep. …” [10]
       A mine void was encountered?  This is especially troubling in light of the fact that recently discovered “large holes” in the ground (not far from the Hray injection well site) have opened up in Brookfield’s township park because abandoned coal mines from the 1890s collapsed. There are plans for ODNR to seal the mines at the site, which has been fenced in, according to the Tribune Chronicle (11/7/2017).[11]
       Could there be some connection between the old Hray injection well drilling and the opening up of the “large holes” in the northern part of the park - or not?  They could be totally unrelated, but ODNR must show the public the proof. Answers must be provided by ODNR before any other injection well drilling is allowed to proceed, in our opinion, in order to protect the public health and safety.

       The ODNR permit issued on August 4, 2014 for the now-abandoned Hray injection well indicates that ODNR required “microseismicity” monitoring in the permit conditions before the old Hray injection well could inject.[12]  Did microseismic monitoring take place and, if yes, when?  Did they find seismicity (earthquakes), or not?  Where are the seismic records if they exist?  Could seismicity be a reason that the Hray site was abandoned?  The community needs to know.
       According to the June 30, 2016 entry of the ODNR inspection reports on the Hray injection well:
       “At the time of my inspection, American Energy has removed all of the impacted soil and vegetation affected by the leaking frac tanks.  Grass seed and straw has been spread.  The frac tanks are missing 4” plugs. I called Bob Barnett, owner of American Energy.  I instructed Mr. Barnett to install plugs on all of the frac tanks.”[13]
       It is not clear whether or not the plugs were installed because the inspection reports seem incomplete. If there was a leak that impacted soil and vegetation so that it had to be removed, why was this situation not publicized when it happened?  Were the Brookfield Trustees notified? Certainly, the Brookfield community should have been informed if there was a problem of this nature.

       Finally, why are there no inspection reports for 2017 that we can find?  Where are the required inspection reports? The last one we’ve been able to locate was dated December 19, 2016.  ODNR should still be inspecting the old injection well.  When was the most recent inspection?

       Brookfield is an abandoned coal mine area.[14]  According to an article in the Columbus Dispatch (9/2/2008), it is unknown precisely where all of the abandoned coal mines in eastern Ohio might be.”The state’s work is made more difficult because no maps exist for at least 2,300 of Ohio’s estimated 6,600 old mines.” [15]
       Since it is not known where all abandoned coal mines might be or where unmapped faults that could cause earthquakes might lie, it is gambling with the public health and safety to locate five injection wells in Brookfield.  It is unacceptable.  It cannot happen because it is not in the public interest.
       Even if the new proposed five injection well operation is not directly over a known or mapped abandoned coal mine, what could be the possible impacts if a potential man-made earthquake due to fluid injection were to occur? This is not out of the realm of possibility since Brookfield, Ohio is in an area close to known areas of seismic activity.  Many remember the magnitude 4.0 injection well-linked induced earthquake in Youngstown, Ohio in 2011.[16]  In 1986, there was a magnitude 5.0 earthquake in the Painesville, Ohio area that may have been injection well-linked.[17]  These were not tiny tremors.  The risk of creating induced earthquakes is nothing to toy with.

       All of the above are good, valid reasons why this proposed Brookfield injection well operation should not proceed, as we believe that it poses unacceptable risks to public health and safety, and private property rights and values. This is especially true since this is an abandoned coal mine area that is near known areas of man-made earthquake activity and for other reasons outlined in previous documents and press releases.[18]

        If ODNR permits this massive, heavy industrial injection well operation to proceed in the highly populated Brookfield community, it would be irresponsible and reckless, in light of the potential dangers to public health and safety and private property rights, and social costs involved.[19]  ODNR and the company know about these issues, or they should know by now, especially since many in the public have been objecting to these proposed injection wells for a long time.

       The public, especially the Brookfield community, deserves and needs to hear ODNR and Highland Field Services, a Seneca Resources subsidiary, answer these kinds of questions, and more, in a public setting with media in attendance.  It is the fair and transparent thing to do.

        The November 30, 2017 town hall-style, Brookfield panel discussion will also include information about local and regional injection well and fracking-linked, man-made earthquakes, risks to water and air, and other related issues and possible solutions.  Confirmed panelists are Teresa Mills, Executive Director of the Buckeye Environmental Network;  Dr. Ray Beiersdorfer, Ph.D., Youngstown State University Distinguished Professor of Geology; Ted Auch, Ph.D. of The FracTracker Alliance;  and Michele Garman who lives right next door to an operating injection well.
       Representatives from ODNR and Highland Field Services have been invited to participate as panelists, but their possible attendance is not yet confirmed or disconfirmed.

       The groups, FANC, BEN, and CHEJ believe, based upon science[20] and experience, that injection is inherently unsafe and that no amount of regulation can make it safe, especially in a highly populated, earthquake-prone area where Brookfield is located and where there are abandoned coal mines.

       For more information or media inquiries, please see www.frackfreeamerica.org   Email:  frackfreeamerica@gmail.com     or call:  234-201-8007

       For more information about the five proposed Brookfield injection wells, man-made earthquakes, etc. please see:
http://www.frackfreeamerica.org/blog/ohio-citizens-to-odnr-revokedeny-five-fracking-waste-injection-permits-immediately-brookfield-wells-pose-imminent-danger-to-public-health-safety-and-welfare

Visit the November 30th Facebook Event page at:
https://www.facebook.com/events/132776757385463/?active_tab=about
                                                              
Notes:


[1] “Injection-well company applies for 3 more wells on same Brookfield site,” October 11, 2017, Vindicator,     http://www.vindy.com/news/2017/oct/11/injection-well-company-applies-for--more/?newswatch

[2] “Frackfree Mahoning Valley will participate in a prayer service/vigil and hold an informational rally near an injection well site July 12, 2016, “ FMV News release, July 11, 2016,          http://www.frackfreeamerica.org/blog/frackfree-mahoning-valley-will-participate-in-a-prayer-servicevigil-and-hold-an-informational-rally-near-an-injection-well-site-july-12-2016

[3] “Drilling company begins work to construct injection wells,” November 14, 2017,  News on the Green, Facebook page:   https://www.facebook.com/NewsontheGreen/

[4] “Brookfield Residents Worry about 3 More Injection Wells,” by Dan O’Brien, October 4, 2017, Youngstown Business Journal,     http://businessjournaldaily.com/brookfield-residents-worry-about-3-more-injection-wells/

[5] “Frack-waste truck overturns near Coolville,” by Conor Morris, November 21, 2017, The Athens News,    https://www.athensnews.com/news/local/frack-waste-truck-overturns-near-coolville/article_4c0615da-cedd-11e7-82c6-fb0f4cc59baf.html
 “Tanker hauling brine water crashes on SR 800,” by Cathryn Stanley, March 15, 2916, Barnesville Enterprise,          http://www.barnesville-enterprise.com/article/20160315/NEWS/303159060
 “Deadly side effect to fracking boom,” AP, May 5, 2014,     https://www.cnbc.com/2014/05/05/deadly-side-effect-to-fracking-boom.html
“Deadliest Danger Isn’t at the Rig but on the Road,”  by Ian Urbina, May 14, 2012, New York Times,  http://www.nytimes.com/2012/05/15/us/for-oil-workers-deadliest-danger-is-driving.html?pagewanted=all
 “Comment to ODNR re: Brookfield injection wells by BEN  CHEJ  FANC “  http://www.buckeyeenvironmentalnetwork.org/news/2017/6/1/comment-to-odnr-re-brookfield-injection-wells-by-ben-chej-fanc
“Frackfree Mahoning Valley will participate in a prayer service/vigil and hold an informational rally near an injection well site July 12, 2016, “ FMV News release, July 11, 2016,          http://www.frackfreeamerica.org/blog/frackfree-mahoning-valley-will-participate-in-a-prayer-servicevigil-and-hold-an-informational-rally-near-an-injection-well-site-july-12-2016
“Drilling concerns in Bristol  Messick Road residents hit with noise, odor, road woes,” by Bob Coupland, November 27, 2017, Tribune Chronicle,      http://www.tribtoday.com/news/local-news/2017/11/drilling-concerns-in-bristol/

[6] “Injection well planned in Brookfield,” by Robbie Byrd,  January 29, 2014, WKBN 27 First News,  http://wkbn.com/2014/01/29/injection-well-planned-in-brookfield/
“ODNR approves Brookfield injection well,” WYTV, August 19, 2014,      http://wytv.com/2014/08/19/odnr-approves-brookfield-injection-well/

[7] “Firm looks to drill two Brookfield injection wells,” by Virginia Shank, Tribune Chronicle, February 3, 2017,   http://content.tribtoday.com/news/local-news/2017/02/firm-looks-to-drill-two-brookfield-injection-wells/

[8] Inspection reports Hray  http://www.frackfreeamerica.org/uploads/1/2/4/0/12404661/hray-mullenex-injection-well-inspection-reports.pdf

[9] ODNR inspection report, entry dated 12/19/2016,  API_WELLNO 34155240910:
 “As of the time of inspection, the well has not been permitted to operate.  The surface facility plan has not been submitted to the Division.  Even though most of the surface facility has been constructed, the construction has not been approved by the Division. […] “          http://www.frackfreeamerica.org/uploads/1/2/4/0/12404661/hray-mullenex-injection-well-inspection-reports.pdf

[10] ODNR inspection report, entries dated 10/10/2014 and 10/11/2014,  API_WELLNO 34155240910      http://www.frackfreeamerica.org/uploads/1/2/4/0/12404661/hray-mullenex-injection-well-inspection-reports.pdf

[11] “ODNR to seal abandoned mine,” by Bob Coupland, November 7, 2017, Tribune Chronicle http://www.tribtoday.com/news/local-news/2017/11/odnr-to-seal-abandoned-mines/

[12]  “ At least 60 days prior to beginning injection operations, American Energy, Inc. shall begin monitoring for microseismicity in the area of the proposed wellsite with at least one instrument.  American Energy, Inc. shall continue to monitor for microseismicity for at least 180 days after injection operations commence.”  Excerpt is from State of Ohio Department of Natural Resources,  Division of Oil and Gas Resources Management Well Permit, Date Issued 8/4/2014, Permit Expires 8/4/2015,  API Well Number:  34-155-2-4091-00-00

[13]  ODNR inspection report, entry dated 6/30/2016,  API_WELLNO 34155240910      http://www.frackfreeamerica.org/uploads/1/2/4/0/12404661/hray-mullenex-injection-well-inspection-reports.pdf

[14] “Mines in Brookfield Township,” website: “Abandoned Coal Mines, Research by Ann Harris, Professor, Department of Geological and Environmental Sciences, Youngstown State University, accessed November 25, 2017,    http://mines.ysu.edu/township_results.php?state=Ohio&link=Trumbull&township=Brookfield&sort=name

[15] “Old coal mines are risk to homes in eastern Ohio, Columbus Dispatch, September 2, 2008 http://www.dispatch.com/content/stories/local/2008/09/02/ohcoal.ART_ART_09-02-08_B1_GLB70C0.html
“Earthquake concerns: Some Trumbull County residents warned to be prepared,” by Jack Shea, February 16, 2017, Fox 8 Cleveland,      http://fox8.com/2017/02/16/earthquake-concerns-some-trumbull-county-residents-warned-to-be-prepared/

[16] “Earthquake Time Line,” Vindicator, March 16, 2012   http://www.vindy.com/news/2012/mar/16/earthquake-time-line/

[17] James Risen and Stephanie Droll, “Great Lakes Area Jolted by 5.0 Earthquake,” Los Angeles Times, February  01, 1986,      http://articles.latimes.com/1986-02-01/news/mn-2945_1_great-lakes

[18] “Ohio Citizens to ODNR: Revoke/Deny Five Fracking Waste Injection Permits Immediately – Brookfield wells pose imminent danger to public health, safety, and welfare,” News release from FANC, BEN, CHEJ, October 9, 2017,  http://www.frackfreeamerica.org/blog/ohio-citizens-to-odnr-revokedeny-five-fracking-waste-injection-permits-immediately-brookfield-wells-pose-imminent-danger-to-public-health-safety-and-welfare
“Love Canal environmentalist, Lois Gibbs, visits Valley,” By Matt Stone, July 28, 2017, 21 WFMJ TV,    http://www.wfmj.com/story/35998002/love-canal-environmentalist-lois-gibbs-visits-valley

[19]  The following excerpt from Marketplace quotes Youngstown Fire Department Battalion Chief, Silverio Caggiano. “He is also a member of the regional hazardous materials response team“  according to the article: “ “Oil and gas chemical secrecy is unusual, said Caggiano. In every other sector, truck drivers who transport chemicals carry papers, called Material Safety Data Sheets, listing the contents.
“The driver's MSDS sheets, even if he is not alive, I know where his MSDS sheets are. They're within a foot of his right hand,” Caggiano said. “But with the fracking industry, whatever they're hauling there's not going to be one.” He has signed onto the letter asking the EPA for more disclosure on oil and gas chemicals.” “
The above excerpt is from [article and audio]:      “ ‘The public has a right to know’ : Fracking companies don’t have to disclose chemicals linked to health concerns,” by Scott Tong, November 15, 2017,      https://www.marketplace.org/2017/11/15/sustainability/epas-legalized-suppression-fracking-chemical-secrets

[20] “Drilling Reawakens Sleeping Faults in Texas, Leads to Earthquakes,” by Anna Kuchment , November 24, 2017, Scientific American,      https://www.scientificamerican.com/article/drilling-reawakens-sleeping-faults-in-texas-leads-to-earthquakes/

                                                                                        # # #

Ohio Citizens To ODNR: Revoke/Deny Five Fracking Waste Injection Permits Immediately - Brookfield wells pose imminent danger to public health, safety, and welfare

News Release: original at: http://www.frackfreeamerica.org/blog/ohio-citizens-to-odnr-revokedeny-five-fracking-waste-injection-permits-immediately-brookfield-wells-pose-imminent-danger-to-public-health-safety-and-welfare

Frackfree America National Coalition, based in Youngstown, Ohio
 www.frackfreeamerica.org
Buckeye Environmental Network www.buckeyeenvironmentalnetwork.org
Center for Health, Environment and Justice (CHEJ)  www.chej.org
_______________________________________________________
For Immediate Release:  October 9, 2017
Contact: Jane Spies, M.S. Ed.: Phone: 330-619-0730 or   234-201-8007 or e-mail:  frackfreeamerica@gmail.com
Contact: Teresa Mills: Phone:   614-507-4406   or e-mail:   tmills@chej.org
_______________________________________________________

A really bad situation just got much worse, says groups:  Out-of-state company applies for three more fracking waste injection wells in Brookfield, Ohio for a total of five potential injection wells in a highly populated, man-made earthquake-prone region. 

A citizen rally opposing the proposed injection wells will take place on the Brookfield village green on Thursday, October 12, 2017 starting at 5:45 PM to 7 PM.
[ event on facebook https://www.facebook.com/events/139644563434935 ]
Groups say the Ohio Department of Natural Resources (ODNR) should immediately deny the three new permit applications and revoke the two drilling permits that ODNR had already issued because the proposed injection wells are an imminent danger to public health, safety, and welfare.

Ohio, October 9, 2017 –  A really bad situation just got much worse, according to Frackfree America National Coalition, based in Youngtown, Ohio (FANC),  Buckeye Environmental Network (BEN), and the Center for Health, Environment and Justice (CHEJ) and concerned citizens in Brookfield who are continuing their strong opposition to the placement of what they just learned is a total of five proposed fracking waste injection wells to be located way too near family homes, businesses, and government buildings in Brookfield, Ohio.[1]
       FANC’s, BEN’s, and CHEJ’s October 9, 2017 joint statement follows:

       On September 28, 2017, Highland Field Services, a Seneca Resources subsidiary, applied to the Ohio Department of Natural Resources (ODNR) for three new permits for injection wells to be located in the same area as the previous two wells in Brookfield, Ohio.[2]
       Teresa Mills of Buckeye Environmental Network has confirmed that there will be another public comment period for the three new injection well permit applications.
       The groups say this proposed injection well operation is not a done deal.  They and concerned citizens are ramping up their efforts to inform the public of why this massive injection well operation must not be allowed by ODNR and why it is totally unacceptable for ODNR and Seneca Resources to site what the groups believe is a dangerous, risky operation in a populated location near known areas of man-made seismic activity.

        A citizen rally opposing the proposed injection wells will take place on Thursday, October 12, 2017 starting at 5:45 PM to 7 PM at the village green at Brookfield Center, Brookfield Township, Ohio  44403.  All media and the public are urged to please attend.
       Additional rallies or meetings to oppose the injection wells are being planned to take place in October and in the near future.

       Groups say it is astonishing that ODNR and Seneca would even consider siting these injection wells in a highly populated area that is very near known epicenters of man-made earthquakes related to injection wells or fracking wells, including a now-famous magnitude 4.0 Youngstown man-made quake that happened on December 31, 2011.  That quake and others were linked to the Northstar 1 injection well.[3]
       The groups, FANC, BEN, and CHEJ, believe the drilling and operation of the injection wells pose an imminent danger to public health, safety, and welfare, and therefore, ODNR should revoke the two drilling permits already issued, and immediately deny the applications submitted by Seneca on September 28, 2017.
       They hope Seneca will see the light, realize that this is an extremely bad business decision, and withdraw their plans for all five proposed injection wells so unbelievably and unacceptably close to family homes.

       The groups are also renewing their call for immediate public meetings in Brookfield, Ohio with ODNR and Seneca, both of whom seem to be resisting meeting with the public even though these wells, if allowed to operate, will have profound effects upon the region and residents’ quality of life, their property values and rights, and public health and safety.
       Although Highland Field Services (subsidiary of Seneca Resources) wrote to the Brookfield Township Trustees that they’re not opposed to participating in a public forum, Highland prefers a private meeting with “elected officials only” first.[4] ODNR apparently simply declined to meet with the public.
       We insist that there should be no meeting about the proposed Brookfield injection wells with “elected officials only” behind closed doors that bars the public and media from attending.[5]  This would be completely unacceptable and a disservice to the Brookfield community and the entire region.  Ohio Sunshine Laws apply.[6]

       The Brookfield Trustees are doing the right thing by requesting a public meeting (which in a July 17, 2017 letter they requested to take place in August, 2017), and we thank them for that. The public deserves a high level of transparency and to be able to have a dialogue or conversation with ODNR and Seneca that happens in real time, preferably televised, where follow-up questions, objections, and comments can occur in a public forum. An ODNR website posting inadequate answers to the public’s comments or Seneca’s FAQ document is not good enough to keep the public fully informed of what is being planned for their neighborhood practically in some residents’ backyards.

       Why won’t ODNR and Seneca meet with the public in Brookfield?  They were asked to do so in July, 2017.[7]  It’s now October. What are they afraid of?  What might they be trying to hide? To us, their behavior has the appearance of trying to unfairly evade or avoid public scrutiny. Why would they do this?

       Adding these three new wells to the first two injection wells that already have drilling permits is going to add an unacceptable volume of fracking waste (much of it coming from out-of-state) to be injected into the ground.  We believe this enormous volume of waste will increase the risk of man-made earthquakes even more than just the first two wells that may be injecting at the rate of around 300,000 barrels of fracking waste per month.[8]

       Science and common sense tell you that having five injection wells injecting with pressure at the same time in essentially the same place could pose very serious issues.  If each of the five wells injects the maximum of 10,000 barrels per day, it could be that each well could inject at the rate of 300,000 barrels per month.  Amazingly, for all five wells, this would be one million five hundred thousand barrels, which translates to 63 million gallons of fracking waste injected per month under pressure. This is totally unacceptable and unconscionable.
       ODNR must not allow this outrageous situation to happen. Isn’t this a recipe for potentially causing man-made earthquakes, especially in a locality that is so close to areas of known seismic activity?

       This injection rate may be highly problematic in light of an injection well study led by Matthew Weingarten, “The scientists found that disposal wells were 1.5 times more likely to be associated with earthquakes, although the region contains far more enhanced recovery wells. The link was strongest at higher injection rates, above about 300,000 barrels per month.”[9]
       There is that number again – 300,000 barrels.
       According to a front-page article in the Vindicator, quoting Vienna, Ohio Township Trustee Phil Pegg regarding the first two proposed Brookfield wells,
        "Pegg said one concern about the Highland applications is that both wells call for injection of an average of 5,000 barrels per day of wastewater and a maximum of 10,000 barrels per day. If both wells injected 10,000 barrels of wastewater per day, that would be considerably more than the D&L Energy well on Ohio Works Drive in Youngstown injected in the months leading to a 4.0-magnitude earthquake attributed to the well in 2011. Vindicator archives indicate the Northstar well was injecting about 2,000 barrels of waste per day just before the earthquake.”[10]

       In our opinion, injecting this amount of waste and at such high pressure is dangerous and must not be allowed, especially in an earthquake-prone region.   It cannot happen.  ODNR and Seneca should know this, and they should know better than to introduce this kind of unacceptable risk into this community and earthquake-prone region.

       According to the Dallas Morning News (9/25/17) referring to a new study by Southern Methodist University scientists including seismologist Heather DeShon who led the study:
 “… Until May 2015, earthquake magnitudes increased in step with injection volumes, according to the study. To DeShon, that means turning off individual wells is not likely to affect earthquake sizes or rates. ‘From a mitigation standpoint, you need to start thinking in terms of the cumulative history of injection in regions,’ she said.” [11]

       We already have other injection wells in our region, for example, in Vienna, North Lima, Youngstown, and the Warren area that have injected enormous amounts of waste.  What are the possible cumulative effects of having so much fluid waste injection in the region?[12]  What kinds of pressures may have built up already and could be migrating?

       Regulators cannot control or prevent earthquakes with one hundred percent certainty.  If they could, they would have done so by now. For example, the numerous, damaging man-made earthquakes in Oklahoma have not stopped, and lawsuits are being filed. Increased seismic regulations and seismic monitoring are not working and cannot work. Earthquakes are still happening. It is not known where all of the faults are that might cause a quake if activated by injection or fracking. In fact, it is usually an unknown fault that is associated with many of the man-made quakes.[13]

       We believe that it is Brookfield’s and the region’s health, safety, private property values and private property rights that will suffer and will be violated if ODNR permits this huge injection well operation in this residential area. There will be virtually no jobs or financial benefits for the community associated with this proposed injection well operation.  There are only potential costs for neighborhood families and local government.

        It is our local economies that will take a hit if a Vienna, Ohio-type spill or underground release of waste fluids happens in Brookfield or other localities.  What if there is a large induced earthquake or water and air contamination? Who will pay for any damage or clean-up if clean-up will even be possible?  Many people in Brookfield are concerned about their well water if the injection well operation is allowed to proceed.

       Road damage from heavy injection well truck traffic can be substantial and expensive to correct.  Road agreements are not required for injection wells, as they are for horizontal wells. According to The Athens Messenger, the county engineer’s department estimated that repairs to their road due to injection well truck traffic would cost $195,365.[14]   Who will pay for potential road damage in Brookfield?  Most likely, if there is no prior agreement worked out, the community and the taxpayers will be left with the bill or a potential, big, long drawn out, expensive lawsuit for the community to try to recover money for damages done.  Of course, if ODNR wisely chooses to deny and revoke the permits, this issue will be moot, and that would be a good thing for the community.

       At a Brookfield Township Trustee meeting on October 2, 2017, Trumbull County Emergency Management Agency Director Linda Beil addressed safety plans. According to a WKBN - TV news report,
“Since Brookfield is a township, their safety plan falls under the county EMA. But Linda Beil with Trumbull EMA says, right now, no official emergency plan is in place. ‘Normally that’s more of an ODNR,’ Beil said. ‘And then it also comes down to the health department getting involved with that — with the wells in the area.’  Beil says injection wells are a new concern for them. … “.[15]
       Injection wells are a new concern? This reported, apparent lack of preparedness in itself should be enough for ODNR to put this entire reckless and immoral injection well plan on hold - at least.

       We are not lawyers, but we believe this injection well operation is not a legitimate business activity or land use especially as it would be inappropriately located so near residential family homes, which makes it abnormally dangerous or ultra-hazardous. The site of the proposed operation is also close to multiple epicenters of man-made earthquakes in the region due to injection wells or fracking operations. The science of induced seismicity is quickly evolving, and increasingly shows that too many variables, such as where faults lie, are unknown.  Earthquakes in the magnitude 5.0 range are happening, or have happened, in or near Ohio or in other states such as Oklahoma, whose largest quake that scientists link to injection wells is a magnitude 5.7 (Prague, Oklahoma) and possibly a magnitude 5.8 (The Pawnee quake - Oklahoma).
       Therefore, it is irresponsible, reckless, and immoral for ODNR to proceed as though it is a safe operation without the state or company having to absolutely prove its alleged safety to health and the public. This needs to be done before any drilling or injection begins. We believe that waste injection is inherently unsafe.
        Furthermore, we don’t think other types of businesses would be allowed to operate in this area so close to family homes without fully disclosing potentially dangerous chemicals being used on their site.  So, why is the oil and gas industry getting a pass over all other businesses, especially in light of the fact that waste from oil and gas is treated differently, legally, than waste from other industries?[16]  This is unfair to other businesses in addition to being unfair to human beings.
       Additionally, first responders must be given full information about all of the chemicals used in the oil and gas industry.[17]  In the interest of protecting public health, safety, and welfare, ODNR must revoke the already issued drilling permits and deny the three new permit applications.

       As many concerned citizens have said regarding injection wells:  We are not going away.  Ohio is not a toxic fracking waste dumping ground.  We are not expendable.  No one is expendable. These are our family homes.  Our livelihoods have been invested in them.  We have private property rights, too.  ODNR must halt this permitting process now in order to protect the public health, safety, and well-being of Brookfield and the entire region.

       For more information or media inquiries, please see www.frackfreeamerica.org
                                Email:  frackfreeamerica@gmail.com     or call:  234-201-8007
       For more information about the proposed Brookfield injection wells and injection wells, man-made earthquakes, etc. please see:
       Our March 28th, 2017 comment to ODNR regarding the proposed Brookfield injection wells, that discusses induced seismicity and other risks, can be seen at:
http://www.buckeyeenvironmentalnetwork.org/news/2017/6/1/comment-to-odnr-re-brookfield-injection-wells-by-ben-chej-fanc
       Our open letter can be seen at:
http://www.buckeyeenvironmentalnetwork.org/news/2017/7/4/openjoint-letter-re-brookfield-injection-wells
       Please see a previous press release regarding injection wells and induced seismicity, etc. at:
http://frackfreemahoning.blogspot.com/2016/07/prayer-service-rally-july-12-2016.html

       Please also see:
““Injection Wells:  The Poison Beneath Us:  Lax oversight, uncertain science plague program under which industries dump trillions of gallons of waste underground,” by Abrahm Lustgarten, June 21, 2012,  Propublica:
 http://www.propublica.org/article/injection-wells-the-poison-beneath-us

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Notes:


[1] “Brookfield Residents Worry about 3 More Injection Wells,” by Dan O’Brien, October 4, 2017, Youngstown Business Journal,     http://businessjournaldaily.com/brookfield-residents-worry-about-3-more-injection-wells/

[2] “Brookfield Residents Worry about 3 More Injection Wells,” by Dan O’Brien, October 4, 2017, Youngstown Business Journal,     http://businessjournaldaily.com/brookfield-residents-worry-about-3-more-injection-wells/

[3] “Earthquake Time Line,” Vindicator, March 16, 2012   http://www.vindy.com/news/2012/mar/16/earthquake-time-line/

[4] Letter to Brookfield Township Trustees from Robert Boulware of Highland Field Services dated August 22, 2017.

[5] “Officials seek injection well moratorium,” by Bob Coupland, Tribune Chronicle, October 3, 2017 http://www.tribtoday.com/news/local-news/2017/10/officials-seek-injection-well-moratorium/

[6] Ohio Attorney General Mike DeWine:  Sunshine Laws Frequently Asked Questions (FAQ)s: http://www.ohioattorneygeneral.gov/FAQ/Sunshine-Laws-FAQs#FAQ336

[7] “Brookfield set to meet on emergency plan for township,” by Bob Coupland, Tribune Chronicle, September 14, 2017  http://www.tribtoday.com/news/local-news/2017/09/brookfield-set-to-meet-on-emergency-plan-for-township/  

[8]  “Residents, officials express concerns regarding proposed Brookfield injection wells,” By Ed Runyan, February 19, 2017, Vindicator    http://www.vindy.com/news/2017/feb/19/plans-for-injection-wells-spur-concerns/

[9] “Huge study links wastewater injection wells to earthquakes,” by Julia Rosen, June 18, 2015, Science http://www.sciencemag.org/news/2015/06/huge-study-links-wastewater-injection-wells-earthquakes

[10] “Residents, officials express concerns regarding proposed Brookfield injection wells,” By Ed Runyan, February 19, 2017, Vindicator    http://www.vindy.com/news/2017/feb/19/plans-for-injection-wells-spur-concerns/

[11] “The fault that produced  North Texas’ largest quake could produce an even bigger one, study says,” by Anna Kuchment, Dallas Morning News, September 25, 2017         https://www.dallasnews.com/news/science-medicine/2017/09/25/fault-produced-north-texas-largest-quake-produce-even-bigger-one-study-says

[12] “Huge study links wastewater injection wells to earthquakes,” by Julia Rosen, June 18, 2015, Science  http://www.sciencemag.org/news/2015/06/huge-study-links-wastewater-injection-wells-earthquakes

[13] Quakeland:  On the Road to America’s Next Devastating Earthquake, by Kathryn Miles, Dutton: Penguin Publishing Group:  2017,  page 107 ;  “Earthquakes Can Happen in More Places Than You Think: We still don’t know where all the faults lie,” by Simon Worrall, August 26, 2017,  National Geographic.:   http://news.nationalgeographic.com/2017/08/earthquake-fault-quakeland-kathryn-miles/

[14] “County asking injection well owner to pay for road damage,” by Steve Robb, July 16, 2015, The Athens Messenger      https://www.athensmessenger.com/news/county-asking-injection-well-owner-to-pay-for-road-damage/article_719bdfb7-c249-5b63-ab17-1106b3bf1016.html
And for information about Trumbull County Ohio Road Use Maintenance Agreements (RUMA), and road weight limits, etc., see “Officials look to RUMAs to control injection wells,” Tribune Chronicle, May 24, 2015 at  http://content.tribtoday.com/news/local-news/2015/05/officials-look-to-rumas-to-control-injection-wells/

[15] “With 5 injection wells, Brookfield wants safety plan for residents. Township trustees said there are over 300 residents living where the wells are located,” by Molly Reed, October 2, 2017, updated October 3, 2017,  http://wkbn.com/2017/10/02/with-nearly-20-injection-well-sites-brookfield-wants-safety-plan/

[16]  Excerpt from:  “The Trillion-Gallon Loophole:  Lax Rules for Drillers that Inject Pollutants Into the Earth:  As the boom in oil and gas drilling sends a surge of waste into underground injection wells, safeguards for disposing of these materials are sometimes being ignored or circumvented,” by Abrahm Lustgarten, September 20, 2012, Propublica,  Excerpt follows:
“Bentsen had won the industry a temporary reprieve in 1980 by persuading Congress to redefine any substance that resulted from drilling – or “producing” – an oil or gas well as “non-hazardous,” regardless of its chemical makeup, pending EPA study.  In 1988, the EPA made it permanent, handing oil and gas companies a landmark exemption.  From then on, benzene from the fertilizer industry was considered hazardous, threatening health and underground water supplies; benzene derived from wells for the oil and gas industry was not. “
https://www.propublica.org/article/trillion-gallon-loophole-lax-rules-for-drillers-that-inject-pollutants

[17] See Interested Party Testimony, May 23, 2017, Sil Caggiano, Deputy Chief Mahoning County Hazardous Materials Response Agency to the Senate Finance Subcommittee on General Government and Agency Review, Am. Sub. HB 49 ; and also May 23, 2017 Interested Party Testimony of John Slavik, Fire Chief, Mark Sommers, Assistant Chief, Tim Hall, Assistant Chief, Cumberland Trail Fire District to the same Subcommittee at the following url:  http://ohiosenate.gov/committee/finance-general-government-and-agency-review-subcommittee#

waste injection well next to home, Vienna , Ohio
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