Thursday, October 12, 2017

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:

Frackfree America National Coalition, based in Youngstown, Ohio
Buckeye Environmental Network
Center for Health, Environment and Justice (CHEJ)
For Immediate Release:  October 9, 2017
Contact: Jane Spies, M.S. Ed.: Phone: 330-619-0730 or   234-201-8007 or e-mail:
Contact: Teresa Mills: Phone:   614-507-4406   or e-mail:
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 ]
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
                                Email:     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:
       Our open letter can be seen at:
       Please see a previous press release regarding injection wells and induced seismicity, etc. at:

       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:

                                                                   # # #

[1] “Brookfield Residents Worry about 3 More Injection Wells,” by Dan O’Brien, October 4, 2017, Youngstown Business Journal,

[2] “Brookfield Residents Worry about 3 More Injection Wells,” by Dan O’Brien, October 4, 2017, Youngstown Business Journal,

[3] “Earthquake Time Line,” Vindicator, March 16, 2012

[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

[6] Ohio Attorney General Mike DeWine:  Sunshine Laws Frequently Asked Questions (FAQ)s:

[7] “Brookfield set to meet on emergency plan for township,” by Bob Coupland, Tribune Chronicle, September 14, 2017  

[8]  “Residents, officials express concerns regarding proposed Brookfield injection wells,” By Ed Runyan, February 19, 2017, Vindicator

[9] “Huge study links wastewater injection wells to earthquakes,” by Julia Rosen, June 18, 2015, Science

[10] “Residents, officials express concerns regarding proposed Brookfield injection wells,” By Ed Runyan, February 19, 2017, Vindicator

[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

[12] “Huge study links wastewater injection wells to earthquakes,” by Julia Rosen, June 18, 2015, Science

[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.:

[14] “County asking injection well owner to pay for road damage,” by Steve Robb, July 16, 2015, The Athens Messenger
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

[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,

[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. “

[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:

waste injection well next to home, Vienna , Ohio
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