November 4, 2018
Via electronic mail:
To: Ohio Department of Natural Resources (ODNR), ODNR Director James Zehringer, Public Information Officers, Adam Schroeder and Steven Irwin.
From: Buckeye Environmental Network (www.buckeyeenvironmentalnetwork.org ); Center for Health, Environment and Justice (www.chej.org) ; Frackfree America National Coalition, based in Youngstown, Ohio (www.frackfreeamerica.org )
RE: Public comment/ objection to proposed Bobcat Hubbard #1 injection well in Hubbard Township, Ohio. And request for ODNR to hold a public hearing in Hubbard regarding the well.
Permit Application aPATT032666 - Bobcat Hubbard#1 well
For more information:
Contact Teresa Mills at 614-539-1471, tmills@chej.org or Jane Spies at 234-201-8007 or e-mail at frackfreeamerica@gmail.com
We hereby submit this public comment to object to the proposed Bobcat Hubbard #1 injection well planned to be located in Hubbard Township, Ohio. We object to ODNR’s possible permitting of a toxic fracking waste injection well way too near family homes, businesses, government buildings, and an important waterway. This is a highly populated area. We are calling for ODNR to deny the drilling permit for the Bobcat Hubbard # 1 injection well proposed to be sited in Hubbard Township due to public health, safety, and welfare issues.
Also, we hereby request that ODNR come to Hubbard, Ohio within the next month for a public hearing regarding the proposed Hubbard Township injection well since there are valid public health, safety, and welfare issues associated with the potential permitting of this injection well.
This is a layperson’s interpretation as we are not lawyers or geologists. We are basing our interpretation on discussions with geologists or other scientists or experts, our reading of scientific studies and literature, documents, and the experience of those living near injection well related infrastructure and related processes.
We believe that the same or similar logic that ODNR applied in court filings that ODNR wrote regarding the AWMS well in Weathersfield, Ohio should also apply to the proposed Bobcat Hubbard injection well. ODNR should not issue a drilling or injection permit to Bobcat Hubbard #1 injection well, due, in part, to similar reasons why ODNR suspended operations at the AWMS injection well in the Weathersfield/ Niles, Ohio area.
Wisely arguing in an appellee brief of the Division of Oil and Gas Resources Management, dated September 22, 2016 (on the court docket) in the case involving the Weathersfield, Ohio injection well that has been suspended for over four years, the Division wrote:
“Should the Chief of the Division of Oil and Gas Resources Management (“Chief”) have to wait for a damaging earthquake to hit a community before issuing a chief’s order suspending operations? Of course not. Nonetheless, the implications of Appellant, American Water Management Services, LLC’s (“AWMS”) arguments would lead to this absurd result.”[1]
Furthermore, according to The “Findings, Conclusions and Order of the [Oil & Gas] Commission” that ruled on the AWMS injection well [p. 12, 8/12/15]:
“While science may aid us in understanding the geophysics and lithostratigraphies associated with injection operations, to a certain extent both the industry and the Division are ‘working with their eyes closed.’ “[2]
Distances and “unknowns” were addressed in the latter document as well. According to the document:
“We cannot directly visualize the ‘terrain’ that exists thousands of feet below the Earth’s surface. And, it is possible that geologic connections exist at these great depths that we cannot readily anticipate. There simply are many unknowns regarding the complexities of deep geology in eastern Ohio. 12
The AWMS #2 Well is located seven miles northwest of the Northstar #1 Well. Seismic events of magnitudes ML 2.7 and ML 4.0 were attributed to injections at the Northstar #1 Well, suggesting the existence of an ‘energized’ fault in the area. While seven miles distance may not seem ‘close’ to us on the surface, in geological terms that distance is not so great. Testimony at hearing revealed that it is entirely possible that the AWMS #2 Well has ‘tapped into’ the same geologic fault system that plagued the Northstar #1 Well. Again, we are dealing in many unknowns. Yet, the fact that data is lacking or uncertain, does not relieve the Division Chief of his responsibility to protect public health and safety.” [3]
Could the Bobcat Hubbard #1 injection well also be in the same geologic fault system referenced above? Since there are many “unknowns,” does ODNR really know if there is a fault that could cause induced seismicity? Probably not, based on their own reasoning. ODNR and the company should have to prove there is no fault. More on that idea is below.
In another filing by ODNR in the AWMS case where ODNR was trying to get a stay to keep the well closed, it is written that:
…”Allowing AWMS to resume operations up to its permitted level may induce seismic activity. Even if the AWMS #2 Well were to be shut down and plugged after it induced a large scale earthquake shaking the Mahoning Valley after resuming operations, it would be too little too late. The only way to ensure no seismic activity is to maintain the status quo. Without maintaining the status quo, the threat of escalating seismic activity from AWMS resuming operations is real.” [4]
By the latter passage, we can see that ODNR leaves open the possibility that our area could have “a large scale earthquake” that could shake the Mahoning Valley under the right conditions.
The Weathersfield AWMS injection well is also located in a populated area and near an important dam.
We believe that ODNR also has the duty and legal authority to deny this Hubbard Township injection well based upon “the Chief’s duty to protect the public under R.C. Chapter 1509.”[5]
This proposed Bobcat Hubbard injection well is in the same area where a seven-mile moratorium on injection well activity was placed after the now-famous magnitude 4.0 Youngstown quake. According to scientist Won -Young Kim referring to the Youngstown, Ohio magnitude 4.0 earthquake of 2011:
“Although we do not know the WSW-ENE extent of the fault(s) in the Youngstown area, it is possible that continued injection of fluid at Northstar 1 well could have triggered potentially large and damaging earthquakes.”[6]
Was the seven-mile moratorium ever lifted, and where are the official documents that prove that? If the moratorium was never officially lifted, how can ODNR issue a drilling permit to Bobcat Hubbard # 1 since it is located within the designated moratorium area? Citizens need to see the documents if they exist.
By calling for a 7-mile moratorium in 2012, that included the site of the present Hubbard Township proposed well, after the magnitude 4.0 Youngstown quake, ODNR is admitting that there is substantial risk of induced seismicity at the proposed Hubbard Township injection well. Because of the increased volume of fracking waste injected since 2011 and additional injection wells in Trumbull County, the risk of quakes must be even higher than in 2011.
Furthermore, Chief Simmers denied an injection permit in 2014 on a proposed Khalil injection well in Mahoning County where, very notably, no earthquakes were reported to the public as having occurred. Even though there were no earthquakes that ODNR has made the public aware of, ODNR’s Chief denied the permit to inject, presumably because of the proposed injection well’s close proximity to other induced earthquakes in the local area.
ODNR set a precedent by ordering that the Khalil injection well, to be sited in Mahoning County, would not be allowed to inject. The ODNR Chief found that “the Khalil #3 saltwater injection well is located in close proximity to an area of known seismic activity.”[7] The Chief’s Order regarding the Khalil injection well also indicates:
“The Khalil #3 saltwater injection well is located approximately 3.8 miles from the Northstar #1 saltwater injection well, 6 miles from seismic events that occurred in 2014 near the Hilcorp Energy Company wells in Poland Township, 11.4 miles from the seismic event that occurred in 2014 near the American Water Management Services’ saltwater injection wells.”[8]
We think that the same logic and resulting denial of an injection permit to R.E. Disposal by ODNR should apply to the Bobcat Hubbard #1 injection well proposed for Hubbard Township.
Compare the distances as reported in the Khalil Chief’s Order denying an injection permit above to the Bobcat Hubbard #1 approximate distances from the same sites:
Khalil #3 is approximately 3.8 miles from Northstar 1 which is linked to an injection well-related magnitude 4.0 earthquake
The proposed Bobcat Hubbard #1 proposed injection well is approximately 7.1 miles away from Northstar 1 injection well which is linked to the magnitude 4.0 quake.
(Remember that the Oil and Gas Commission wrote that, in geological terms, seven miles is not a long distance, to paraphrase their statement quoted on page 2 above.)
Khalil #3 is 6 miles from the epicenter of earthquakes in Poland Township. Bobcat Hubbard #1 is 11.3 miles from the Poland epicenter.
Khalil #3 is 11.4 miles from the Weathersfield AWMS injection well associated with earthquakes in 2014 and shut down by ODNR. (The case is now in court).
Bobcat Hubbard #1 is only 11 miles away from the now-closed Weathersfield injection well.
Bobcat Hubbard is only 6.2 miles from the Khalil well – now plugged and not in use.
These distances are all very close, and one would think that ODNR would deny the permit to drill and/or inject even for this reason alone in order to protect public health, safety, and welfare and in the public interest. This situation cannot be corrected by ODNR issuing permit conditions.
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.” [9]
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?[10] What kinds of pressures may have built up already and could be migrating?
ODNR just recently issued a permit to inject in Brookfield, Ohio for the number five injection well. If this well injects waste at the requested 5,000 to 10,000 barrels a day, this will add greatly to the cumulative volume of toxic waste injected into our region, which, of course, includes Hubbard Township.
Here are approximate distances of the proposed Bobcat Hubbard #1 injection well from other operating injection wells. If Dr. DeShon’s reasoning about the need to consider cumulative history of injection in regions is applied, ODNR should be concerned about the growing amount of toxic waste being injected in Ohio, and in the northeast region of Ohio.
Also, scientists have written that earthquakes can occur, in some cases, many miles from the point of injection. See the following case where it was about 21.7 miles. See K.M. Keranen, et al, who wrote: “The injection-linked seismicity near Jones occurs up to 35 km away from the disposal wells, much further than previously considered in existing criteria for induced seismicity (13). Modern, very high-rate injection wells can therefore impact regional seismicity and increase seismic hazard.” , Sciencexpress, “Sharp increase in central Oklahoma seismicity since 2008 induced by massive wastewater injection, July 3, 2014, page 2. [11]
The approximate distance of Bobcat Hubbard #1 to Brookfield where an injection well has just been permitted by ODNR to inject is only 4.96 miles.
The distance of the proposed Hubbard well to the Vienna, Ohio KTCA injection well, that is currently operating, is only 7.3 miles.
The distance of the Hubbard injection well to the injection well operation in North Lima where large amounts of toxic waste are being injected is only 15.4 miles.
Even wells that are not active have previously injected waste that still should be considered for cumulative volume, such as the waste already injected at Northstar 1 in Youngstown and Weathersfield’s AWMS number two well, both of which are now shut down by ODNR due to previous man-made earthquakes. And, the Vienna, Ohio KDA injection wells that are now shut down had injected waste, as well. Those Vienna wells are linked to a devastating spill in 2015.
Clearly, if not done already, ODNR should consult with seismologist Dr. DeShon about her views on cumulative history of injection in regions, Dr. Katie Keranen, Dr. Barbour, Dr. McGarr, and other seismologists and scientists who are studying induced seismicity.
In Brookfield, Ohio, Highland Field Services/ Seneca Resources is trying to put a total of five injection wells way too near family homes and businesses, each with 5000 to 10,000 barrels per day injection. If ODNR permits this, it will greatly contribute to the risk of induced seismicity in our region, in our opinion. (One of Seneca’s drilling permits has expired).
There are other injection wells in our region that are not mentioned here.
To repeat, this proposed Hubbard Township injection well was in the seven-mile moratorium area established after the magnitude 4.0 Youngstown quake. To us it seems that there is even more reason now to disallow injection at this proposed Bobcat Hubbard injection well since there has been much more injected waste placed under the ground in our local area and region.
For example, a November 1, 2018 WFMJ TV 21 news investigative report by Danielle Cotterman, titled “Is Ohio a ‘Dumping Ground?’” said that since 2012, 7.3 billion gallons of waste has been injected in Ohio from injection wells.
Doesn’t that enormous volume of injected waste increase the risk of induced seismicity in our area?[12]
With the nearby injection wells that are already operating, the injected volume is increasing every day, therefore, in our laypersons’ opinion, increasing the potential for man-made earthquakes. This is an unacceptable level of risk, and a large number of Hubbard Township and local-area citizens strongly object to the placement of the injection well at the Hubbard Township proposed site.
What might a potential moderate or large quake do to potentially adversely affect the integrity of the injection well? Might damage to the well itself, or changes in the ground from a quake, occur that could lead to leakage, spills, or air emissions? What might even small, repeated tremors do to potentially affect the integrity of the injection well?
The proposed well will be only 130 feet from an important waterway. It is close to an aquifer in Hubbard. Any spills, releases, or leakage could potentially affect a water source. This is unacceptable.
We believe, based upon science and others’ experience with earthquakes, that man-made earthquakes cannot be regulated. Trying to regulate or monitor, is just pretending that humans can control earthquakes, which is absurd. Once a fault is activated it cannot be “un-activated.”
Oklahoma is still experiencing man-made earthquakes related to injection wells and hydraulic fracturing wells. Regulators cannot get them stopped. Will Ohio suffer the same fate, especially if ODNR keeps permitting more and more injection wells in our region? ODNR must be proactive and learn from Oklahoma’s experience. ODNR must deny the Hubbard permit as part of its protection of public health, safety, and welfare locally and in our entire region.
According to seismologist, Dr. Won-Young Kim, who has studied the Youngstown quakes and others, “ “In the future, "we need to find better ways to image hidden subsurface faults and fractures, which is costly at the moment," Kim said. "If there are hidden subsurface faults near the injection wells, then sooner or later they can trigger earthquakes."
In the future, operators of such wells may look for earthquakes for about six months after the beginning of operations, Kim said.
"However, there are cases when triggered earthquakes occurred nearly 10 years after the injection," he noted.” “ [13]
Clearly, earthquakes are nothing to toy with.
Scientist Michael C. Hansen wrote: “On the basis of historic seismic activity, it is likely that large earthquakes with epicenters in the state would occur in the western Ohio seismic zone or in northeastern Ohio; there is a lesser possibility of a large earthquake in southeastern Ohio. Some researchers have suggested that northeastern Ohio is capable of a maximum magnitude 6.5 earthquake, whereas western Ohio may be capable of producing an event in the 6 to 7 magnitude range (maximum MMI of IX). These suggestions are speculations at best, because there are inadequate data to accurately judge the extent of the area available for rupture on any earthquake – generating fault.” [14]
Hansen said that northeastern Ohio may be capable of a magnitude 6.5 quake, in theory. Obviously, this is not a small tremor. To the extent that it is possible, preventing the increased risk of this kind of event should be paramount.
In a paper with implications for our entire region, and that we highly recommend, Dr. Ray Beiersdorfer wrote about proposed Brookfield, Ohio injection wells and said that ODNR and the company should have to establish that there are no faults.
Dr. Beiersdorfer wrote: “Injection of fluids underneath Brookfield Township will subject the community to seismic risks comparable to the damaging earthquakes in Oklahoma and Arkansas.”
[and]
“The scientifically established relationship between injection volumes and cumulative seismic moment indicates that the proposed volumes for Brookfield are capable of triggering a magnitude 5 or greater earthquake. “ [15]
We are not human subjects for what sometimes appears to be a man-made earthquake prevention experiment. We do not consent to any research on how to “perhaps” mitigate induced seismicity in an area known as the eastern disturbed zone due to all of the faults. No one knows where all of the faults are, therefore, ODNR is gambling with the public health, safety, and welfare if they permit this injection well. This is unacceptable and a violation of human rights, in our opinion.
We also object to the proposed Hubbard Township injection well due to many unresolved or unsolvable issues related to potential air emissions, potential lightning-strike problems, potential man-made earthquakes, damage to local roads from an unacceptable level of “brine” truck travel to and from the injection well, unresolved potential spill, leakage, or release of toxic waste into the community due to mechanical failures or human error, potential risks to drinking water, unfairness to the local population and potential violations of private property rights and decreased property values due to the potential permitting of the injection well.
This is not a legitimate business activity, in our laypersons’ opinion, in part, because it is too near a residential, populated area in an area with abandoned coal mines and other nearby epicenters of induced earthquakes related to injection wells or hydraulic fracturing.
ODNR must deny Bobcat’s application for the injection well being planned in Hubbard Township, Ohio, in order to protect the public health, safety, and welfare of Hubbard and the entire region, and to maintain private property rights of citizens and other businesses in the local area.
We are requesting that ODNR consider the Brookfield public comments that we previously submitted as part of our current objection to the Bobcat Hubbard #1 injection well. Those comments can be found at: http://www.frackfreeamerica.org/blog/public-comment-odnr-should-denyrevoke-permits-of-5-fracking-waste-injection-wells-in-brookfield-ohio-december-2017
Would you please also consider, as part of our objections to the Hubbard Township injection well, Dr. Ray Beiersdorfer’s article about potential induced seismicity in Brookfield at:
“Merry Christmas Brookfield: Here’s Five Salt Water Injection Wells, “ December 23, 2017, by Dr. Raymond Beiersdorfer, Distinguished Professor of Geology
Department of Geological and Environmental Sciences
Youngstown State University, published on Columbus Free Press at:
https://columbusfreepress.com/article/merry-christmas-brookfield-here%E2%80%99s-five-salt-water-injection-wells
Direct link to PDF: https://columbusfreepress.com/sites/default/files/associated/Merry%20Christmas%20Brookfield.pdf
Thank you for considering this objection to Bobcat Hubbard #1 injection well. We hope that you will do the right thing and deny the injection well permit for Bobcat Hubbard #1.
Notes:
[1] Brief of Appellee, Division of Oil and Gas Resources Management, In the Court of Common Pleas Franklin County, Ohio, Case No. 16 CV 006218, September 22, 2016, page 1.
[2] “Before the Oil & Gas Commission,” American Water Management Services, LLC vs Division of Oil & Gas Resources Management; Appeal Nos. 889 & 890, Review of Chief’s Orders 2014-372 & 2014 – 374 (AWMS #2 Well); FINDINGS, CONCLUSIONS AND ORDER OF THE COMMISSION, Date Issued: August 12, 2015, page 12.
[3] “Before the Oil & Gas Commission,” American Water Management Services, LLC vs Division of Oil & Gas Resources Management; Appeal Nos. 889 & 890, Review of Chief’s Orders 2014-372 & 2014 – 374 (AWMS #2 Well); FINDINGS, CONCLUSIONS AND ORDER OF THE COMMISSION, Date Issued: August 12, 2015, page 13.
[4] “APPELLANT DIVISION OF OIL & GAS RESOURCES MANAGEMENT’S REPLY TO AWMS’S RESPONSE TO MOTION FOR STAY PENDING APPEAL OF THE DECEMBER 23, 2016 ORDER FROM THE FRANKLIN COURT OF COMMON PLEAS, February 7, 2017, American Water Management Services, LLC, Appellee, v. Division of Oil & Gas Resources Management, Appellant, Case No. 17-AP-45, Page 3-4.
[5] Brief of Appellee, Division of Oil and Gas Resources Management, In the Court of Common Pleas Franklin County, Ohio, Case No. 16 CV 006218, September 22, 2016, page 1.
[6] Won-Young Kim, “Induced seismicity associated with fluid injection into a deep well in Youngstown, Ohio,” July 19, 2013, Journal of Geophysical Research, Solid Earth, Volume 118, Issue 7, July 2013, Pages 3506-3518, http://onlinelibrary.wiley.com/doi/10.1002/jgrb.50247/full
[7] PDF uploaded document: RE: Northstar Kahlil #3 Well – Mahoning County; Ohio Department of Natural Resources, ORDER BY THE CHIEF, September 24, 2014, “Denial of Permit to Inject Brine or Other Waste Substances pursuant to Ohio Revised Code 1509.22: http://www.frackfreeamerica.org/uploads/1/2/4/0/12404661/2014_421_r.e._disposal_llc_denial_of_permit_to_inject.pdf
[8] PDF uploaded document: RE: Northstar Kahlil #3 Well – Mahoning County; Ohio Department of Natural Resources, ORDER BY THE CHIEF, September 24, 2014, “Denial of Permit to Inject Brine or Other Waste Substances pursuant to Ohio Revised Code 1509.22: http://www.frackfreeamerica.org/uploads/1/2/4/0/12404661/2014_421_r.e._disposal_llc_denial_of_permit_to_inject.pdf
[9] “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
[10] “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
[11] See K.M. Keranen, et al, “The injection-linked seismicity near Jones occurs up to 35 km away from the disposal wells, much further than previously considered in existing criteria for induced seismicity (13). Modern, very high-rate injection wells can therefore impact regional seismicity and increase seismic hazard.” , Sciencexpress, “Sharp increase in central Oklahoma seismicity since 2008 induced by massive wastewater injection, July 3, 2014, page 2.
[12] See Weingarten and others cited in the following post at: http://www.frackfreeamerica.org/blog/archives/10-2017 ; also see a new study that found according to the below url: “The cumulative volume of wastewater injected into the earth in Oklahoma is also higher than in the other oil-producing areas, and can also be linked to increased rates of seismicity in the state, the researchers said.” Science Daily, “Location of wastewater disposal drives induced seismicity at US oil site,” October 31, 2018, Source: Seismological Society of America,
https://www.sciencedaily.com/releases/2018/10/181031141454.htm
[13] “Confirmed: Fracking practices to blame for Ohio earthquakes by Charles Q. Choi, November 2, 2015, updated September 4, 2013, NBC News, https://www.nbcnews.com/sciencemain/confirmed-fracking-practices-blame-ohio-earthquakes-8C11073601
[14] “Earthquakes in Ohio,” by Michael C. Hansen, Updated 2015, EL 9., ODNR Division of Geological Survey, Educational Leaflet (EL) Series, page 8, http://geosurvey.ohiodnr.gov/publications-maps-data/free-downloads/educational-leaflets
[15] “Merry Christmas Brookfield: Here’s Five Salt Water Injection Wells, “ December 23, 2017, by Dr. Raymond Beiersdorfer, Distinguished Professor of Geology
Department of Geological and Environmental Sciences
Youngstown State University, published on Columbus Free Press at:
https://columbusfreepress.com/article/merry-christmas-brookfield-here%E2%80%99s-five-salt-water-injection-wells
Direct link to PDF: https://columbusfreepress.com/sites/default/files/associated/Merry%20Christmas%20Brookfield.pdf
Retrieved November 3, 2018.
Via electronic mail:
To: Ohio Department of Natural Resources (ODNR), ODNR Director James Zehringer, Public Information Officers, Adam Schroeder and Steven Irwin.
From: Buckeye Environmental Network (www.buckeyeenvironmentalnetwork.org ); Center for Health, Environment and Justice (www.chej.org) ; Frackfree America National Coalition, based in Youngstown, Ohio (www.frackfreeamerica.org )
RE: Public comment/ objection to proposed Bobcat Hubbard #1 injection well in Hubbard Township, Ohio. And request for ODNR to hold a public hearing in Hubbard regarding the well.
Permit Application aPATT032666 - Bobcat Hubbard#1 well
For more information:
Contact Teresa Mills at 614-539-1471, tmills@chej.org or Jane Spies at 234-201-8007 or e-mail at frackfreeamerica@gmail.com
We hereby submit this public comment to object to the proposed Bobcat Hubbard #1 injection well planned to be located in Hubbard Township, Ohio. We object to ODNR’s possible permitting of a toxic fracking waste injection well way too near family homes, businesses, government buildings, and an important waterway. This is a highly populated area. We are calling for ODNR to deny the drilling permit for the Bobcat Hubbard # 1 injection well proposed to be sited in Hubbard Township due to public health, safety, and welfare issues.
Also, we hereby request that ODNR come to Hubbard, Ohio within the next month for a public hearing regarding the proposed Hubbard Township injection well since there are valid public health, safety, and welfare issues associated with the potential permitting of this injection well.
This is a layperson’s interpretation as we are not lawyers or geologists. We are basing our interpretation on discussions with geologists or other scientists or experts, our reading of scientific studies and literature, documents, and the experience of those living near injection well related infrastructure and related processes.
We believe that the same or similar logic that ODNR applied in court filings that ODNR wrote regarding the AWMS well in Weathersfield, Ohio should also apply to the proposed Bobcat Hubbard injection well. ODNR should not issue a drilling or injection permit to Bobcat Hubbard #1 injection well, due, in part, to similar reasons why ODNR suspended operations at the AWMS injection well in the Weathersfield/ Niles, Ohio area.
Wisely arguing in an appellee brief of the Division of Oil and Gas Resources Management, dated September 22, 2016 (on the court docket) in the case involving the Weathersfield, Ohio injection well that has been suspended for over four years, the Division wrote:
“Should the Chief of the Division of Oil and Gas Resources Management (“Chief”) have to wait for a damaging earthquake to hit a community before issuing a chief’s order suspending operations? Of course not. Nonetheless, the implications of Appellant, American Water Management Services, LLC’s (“AWMS”) arguments would lead to this absurd result.”[1]
Furthermore, according to The “Findings, Conclusions and Order of the [Oil & Gas] Commission” that ruled on the AWMS injection well [p. 12, 8/12/15]:
“While science may aid us in understanding the geophysics and lithostratigraphies associated with injection operations, to a certain extent both the industry and the Division are ‘working with their eyes closed.’ “[2]
Distances and “unknowns” were addressed in the latter document as well. According to the document:
“We cannot directly visualize the ‘terrain’ that exists thousands of feet below the Earth’s surface. And, it is possible that geologic connections exist at these great depths that we cannot readily anticipate. There simply are many unknowns regarding the complexities of deep geology in eastern Ohio. 12
The AWMS #2 Well is located seven miles northwest of the Northstar #1 Well. Seismic events of magnitudes ML 2.7 and ML 4.0 were attributed to injections at the Northstar #1 Well, suggesting the existence of an ‘energized’ fault in the area. While seven miles distance may not seem ‘close’ to us on the surface, in geological terms that distance is not so great. Testimony at hearing revealed that it is entirely possible that the AWMS #2 Well has ‘tapped into’ the same geologic fault system that plagued the Northstar #1 Well. Again, we are dealing in many unknowns. Yet, the fact that data is lacking or uncertain, does not relieve the Division Chief of his responsibility to protect public health and safety.” [3]
Could the Bobcat Hubbard #1 injection well also be in the same geologic fault system referenced above? Since there are many “unknowns,” does ODNR really know if there is a fault that could cause induced seismicity? Probably not, based on their own reasoning. ODNR and the company should have to prove there is no fault. More on that idea is below.
In another filing by ODNR in the AWMS case where ODNR was trying to get a stay to keep the well closed, it is written that:
…”Allowing AWMS to resume operations up to its permitted level may induce seismic activity. Even if the AWMS #2 Well were to be shut down and plugged after it induced a large scale earthquake shaking the Mahoning Valley after resuming operations, it would be too little too late. The only way to ensure no seismic activity is to maintain the status quo. Without maintaining the status quo, the threat of escalating seismic activity from AWMS resuming operations is real.” [4]
By the latter passage, we can see that ODNR leaves open the possibility that our area could have “a large scale earthquake” that could shake the Mahoning Valley under the right conditions.
The Weathersfield AWMS injection well is also located in a populated area and near an important dam.
We believe that ODNR also has the duty and legal authority to deny this Hubbard Township injection well based upon “the Chief’s duty to protect the public under R.C. Chapter 1509.”[5]
This proposed Bobcat Hubbard injection well is in the same area where a seven-mile moratorium on injection well activity was placed after the now-famous magnitude 4.0 Youngstown quake. According to scientist Won -Young Kim referring to the Youngstown, Ohio magnitude 4.0 earthquake of 2011:
“Although we do not know the WSW-ENE extent of the fault(s) in the Youngstown area, it is possible that continued injection of fluid at Northstar 1 well could have triggered potentially large and damaging earthquakes.”[6]
Was the seven-mile moratorium ever lifted, and where are the official documents that prove that? If the moratorium was never officially lifted, how can ODNR issue a drilling permit to Bobcat Hubbard # 1 since it is located within the designated moratorium area? Citizens need to see the documents if they exist.
By calling for a 7-mile moratorium in 2012, that included the site of the present Hubbard Township proposed well, after the magnitude 4.0 Youngstown quake, ODNR is admitting that there is substantial risk of induced seismicity at the proposed Hubbard Township injection well. Because of the increased volume of fracking waste injected since 2011 and additional injection wells in Trumbull County, the risk of quakes must be even higher than in 2011.
Furthermore, Chief Simmers denied an injection permit in 2014 on a proposed Khalil injection well in Mahoning County where, very notably, no earthquakes were reported to the public as having occurred. Even though there were no earthquakes that ODNR has made the public aware of, ODNR’s Chief denied the permit to inject, presumably because of the proposed injection well’s close proximity to other induced earthquakes in the local area.
ODNR set a precedent by ordering that the Khalil injection well, to be sited in Mahoning County, would not be allowed to inject. The ODNR Chief found that “the Khalil #3 saltwater injection well is located in close proximity to an area of known seismic activity.”[7] The Chief’s Order regarding the Khalil injection well also indicates:
“The Khalil #3 saltwater injection well is located approximately 3.8 miles from the Northstar #1 saltwater injection well, 6 miles from seismic events that occurred in 2014 near the Hilcorp Energy Company wells in Poland Township, 11.4 miles from the seismic event that occurred in 2014 near the American Water Management Services’ saltwater injection wells.”[8]
We think that the same logic and resulting denial of an injection permit to R.E. Disposal by ODNR should apply to the Bobcat Hubbard #1 injection well proposed for Hubbard Township.
Compare the distances as reported in the Khalil Chief’s Order denying an injection permit above to the Bobcat Hubbard #1 approximate distances from the same sites:
Khalil #3 is approximately 3.8 miles from Northstar 1 which is linked to an injection well-related magnitude 4.0 earthquake
The proposed Bobcat Hubbard #1 proposed injection well is approximately 7.1 miles away from Northstar 1 injection well which is linked to the magnitude 4.0 quake.
(Remember that the Oil and Gas Commission wrote that, in geological terms, seven miles is not a long distance, to paraphrase their statement quoted on page 2 above.)
Khalil #3 is 6 miles from the epicenter of earthquakes in Poland Township. Bobcat Hubbard #1 is 11.3 miles from the Poland epicenter.
Khalil #3 is 11.4 miles from the Weathersfield AWMS injection well associated with earthquakes in 2014 and shut down by ODNR. (The case is now in court).
Bobcat Hubbard #1 is only 11 miles away from the now-closed Weathersfield injection well.
Bobcat Hubbard is only 6.2 miles from the Khalil well – now plugged and not in use.
These distances are all very close, and one would think that ODNR would deny the permit to drill and/or inject even for this reason alone in order to protect public health, safety, and welfare and in the public interest. This situation cannot be corrected by ODNR issuing permit conditions.
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.” [9]
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?[10] What kinds of pressures may have built up already and could be migrating?
ODNR just recently issued a permit to inject in Brookfield, Ohio for the number five injection well. If this well injects waste at the requested 5,000 to 10,000 barrels a day, this will add greatly to the cumulative volume of toxic waste injected into our region, which, of course, includes Hubbard Township.
Here are approximate distances of the proposed Bobcat Hubbard #1 injection well from other operating injection wells. If Dr. DeShon’s reasoning about the need to consider cumulative history of injection in regions is applied, ODNR should be concerned about the growing amount of toxic waste being injected in Ohio, and in the northeast region of Ohio.
Also, scientists have written that earthquakes can occur, in some cases, many miles from the point of injection. See the following case where it was about 21.7 miles. See K.M. Keranen, et al, who wrote: “The injection-linked seismicity near Jones occurs up to 35 km away from the disposal wells, much further than previously considered in existing criteria for induced seismicity (13). Modern, very high-rate injection wells can therefore impact regional seismicity and increase seismic hazard.” , Sciencexpress, “Sharp increase in central Oklahoma seismicity since 2008 induced by massive wastewater injection, July 3, 2014, page 2. [11]
The approximate distance of Bobcat Hubbard #1 to Brookfield where an injection well has just been permitted by ODNR to inject is only 4.96 miles.
The distance of the proposed Hubbard well to the Vienna, Ohio KTCA injection well, that is currently operating, is only 7.3 miles.
The distance of the Hubbard injection well to the injection well operation in North Lima where large amounts of toxic waste are being injected is only 15.4 miles.
Even wells that are not active have previously injected waste that still should be considered for cumulative volume, such as the waste already injected at Northstar 1 in Youngstown and Weathersfield’s AWMS number two well, both of which are now shut down by ODNR due to previous man-made earthquakes. And, the Vienna, Ohio KDA injection wells that are now shut down had injected waste, as well. Those Vienna wells are linked to a devastating spill in 2015.
Clearly, if not done already, ODNR should consult with seismologist Dr. DeShon about her views on cumulative history of injection in regions, Dr. Katie Keranen, Dr. Barbour, Dr. McGarr, and other seismologists and scientists who are studying induced seismicity.
In Brookfield, Ohio, Highland Field Services/ Seneca Resources is trying to put a total of five injection wells way too near family homes and businesses, each with 5000 to 10,000 barrels per day injection. If ODNR permits this, it will greatly contribute to the risk of induced seismicity in our region, in our opinion. (One of Seneca’s drilling permits has expired).
There are other injection wells in our region that are not mentioned here.
To repeat, this proposed Hubbard Township injection well was in the seven-mile moratorium area established after the magnitude 4.0 Youngstown quake. To us it seems that there is even more reason now to disallow injection at this proposed Bobcat Hubbard injection well since there has been much more injected waste placed under the ground in our local area and region.
For example, a November 1, 2018 WFMJ TV 21 news investigative report by Danielle Cotterman, titled “Is Ohio a ‘Dumping Ground?’” said that since 2012, 7.3 billion gallons of waste has been injected in Ohio from injection wells.
Doesn’t that enormous volume of injected waste increase the risk of induced seismicity in our area?[12]
With the nearby injection wells that are already operating, the injected volume is increasing every day, therefore, in our laypersons’ opinion, increasing the potential for man-made earthquakes. This is an unacceptable level of risk, and a large number of Hubbard Township and local-area citizens strongly object to the placement of the injection well at the Hubbard Township proposed site.
What might a potential moderate or large quake do to potentially adversely affect the integrity of the injection well? Might damage to the well itself, or changes in the ground from a quake, occur that could lead to leakage, spills, or air emissions? What might even small, repeated tremors do to potentially affect the integrity of the injection well?
The proposed well will be only 130 feet from an important waterway. It is close to an aquifer in Hubbard. Any spills, releases, or leakage could potentially affect a water source. This is unacceptable.
We believe, based upon science and others’ experience with earthquakes, that man-made earthquakes cannot be regulated. Trying to regulate or monitor, is just pretending that humans can control earthquakes, which is absurd. Once a fault is activated it cannot be “un-activated.”
Oklahoma is still experiencing man-made earthquakes related to injection wells and hydraulic fracturing wells. Regulators cannot get them stopped. Will Ohio suffer the same fate, especially if ODNR keeps permitting more and more injection wells in our region? ODNR must be proactive and learn from Oklahoma’s experience. ODNR must deny the Hubbard permit as part of its protection of public health, safety, and welfare locally and in our entire region.
According to seismologist, Dr. Won-Young Kim, who has studied the Youngstown quakes and others, “ “In the future, "we need to find better ways to image hidden subsurface faults and fractures, which is costly at the moment," Kim said. "If there are hidden subsurface faults near the injection wells, then sooner or later they can trigger earthquakes."
In the future, operators of such wells may look for earthquakes for about six months after the beginning of operations, Kim said.
"However, there are cases when triggered earthquakes occurred nearly 10 years after the injection," he noted.” “ [13]
Clearly, earthquakes are nothing to toy with.
Scientist Michael C. Hansen wrote: “On the basis of historic seismic activity, it is likely that large earthquakes with epicenters in the state would occur in the western Ohio seismic zone or in northeastern Ohio; there is a lesser possibility of a large earthquake in southeastern Ohio. Some researchers have suggested that northeastern Ohio is capable of a maximum magnitude 6.5 earthquake, whereas western Ohio may be capable of producing an event in the 6 to 7 magnitude range (maximum MMI of IX). These suggestions are speculations at best, because there are inadequate data to accurately judge the extent of the area available for rupture on any earthquake – generating fault.” [14]
Hansen said that northeastern Ohio may be capable of a magnitude 6.5 quake, in theory. Obviously, this is not a small tremor. To the extent that it is possible, preventing the increased risk of this kind of event should be paramount.
In a paper with implications for our entire region, and that we highly recommend, Dr. Ray Beiersdorfer wrote about proposed Brookfield, Ohio injection wells and said that ODNR and the company should have to establish that there are no faults.
Dr. Beiersdorfer wrote: “Injection of fluids underneath Brookfield Township will subject the community to seismic risks comparable to the damaging earthquakes in Oklahoma and Arkansas.”
[and]
“The scientifically established relationship between injection volumes and cumulative seismic moment indicates that the proposed volumes for Brookfield are capable of triggering a magnitude 5 or greater earthquake. “ [15]
We are not human subjects for what sometimes appears to be a man-made earthquake prevention experiment. We do not consent to any research on how to “perhaps” mitigate induced seismicity in an area known as the eastern disturbed zone due to all of the faults. No one knows where all of the faults are, therefore, ODNR is gambling with the public health, safety, and welfare if they permit this injection well. This is unacceptable and a violation of human rights, in our opinion.
We also object to the proposed Hubbard Township injection well due to many unresolved or unsolvable issues related to potential air emissions, potential lightning-strike problems, potential man-made earthquakes, damage to local roads from an unacceptable level of “brine” truck travel to and from the injection well, unresolved potential spill, leakage, or release of toxic waste into the community due to mechanical failures or human error, potential risks to drinking water, unfairness to the local population and potential violations of private property rights and decreased property values due to the potential permitting of the injection well.
This is not a legitimate business activity, in our laypersons’ opinion, in part, because it is too near a residential, populated area in an area with abandoned coal mines and other nearby epicenters of induced earthquakes related to injection wells or hydraulic fracturing.
ODNR must deny Bobcat’s application for the injection well being planned in Hubbard Township, Ohio, in order to protect the public health, safety, and welfare of Hubbard and the entire region, and to maintain private property rights of citizens and other businesses in the local area.
We are requesting that ODNR consider the Brookfield public comments that we previously submitted as part of our current objection to the Bobcat Hubbard #1 injection well. Those comments can be found at: http://www.frackfreeamerica.org/blog/public-comment-odnr-should-denyrevoke-permits-of-5-fracking-waste-injection-wells-in-brookfield-ohio-december-2017
Would you please also consider, as part of our objections to the Hubbard Township injection well, Dr. Ray Beiersdorfer’s article about potential induced seismicity in Brookfield at:
“Merry Christmas Brookfield: Here’s Five Salt Water Injection Wells, “ December 23, 2017, by Dr. Raymond Beiersdorfer, Distinguished Professor of Geology
Department of Geological and Environmental Sciences
Youngstown State University, published on Columbus Free Press at:
https://columbusfreepress.com/article/merry-christmas-brookfield-here%E2%80%99s-five-salt-water-injection-wells
Direct link to PDF: https://columbusfreepress.com/sites/default/files/associated/Merry%20Christmas%20Brookfield.pdf
Thank you for considering this objection to Bobcat Hubbard #1 injection well. We hope that you will do the right thing and deny the injection well permit for Bobcat Hubbard #1.
Notes:
[1] Brief of Appellee, Division of Oil and Gas Resources Management, In the Court of Common Pleas Franklin County, Ohio, Case No. 16 CV 006218, September 22, 2016, page 1.
[2] “Before the Oil & Gas Commission,” American Water Management Services, LLC vs Division of Oil & Gas Resources Management; Appeal Nos. 889 & 890, Review of Chief’s Orders 2014-372 & 2014 – 374 (AWMS #2 Well); FINDINGS, CONCLUSIONS AND ORDER OF THE COMMISSION, Date Issued: August 12, 2015, page 12.
[3] “Before the Oil & Gas Commission,” American Water Management Services, LLC vs Division of Oil & Gas Resources Management; Appeal Nos. 889 & 890, Review of Chief’s Orders 2014-372 & 2014 – 374 (AWMS #2 Well); FINDINGS, CONCLUSIONS AND ORDER OF THE COMMISSION, Date Issued: August 12, 2015, page 13.
[4] “APPELLANT DIVISION OF OIL & GAS RESOURCES MANAGEMENT’S REPLY TO AWMS’S RESPONSE TO MOTION FOR STAY PENDING APPEAL OF THE DECEMBER 23, 2016 ORDER FROM THE FRANKLIN COURT OF COMMON PLEAS, February 7, 2017, American Water Management Services, LLC, Appellee, v. Division of Oil & Gas Resources Management, Appellant, Case No. 17-AP-45, Page 3-4.
[5] Brief of Appellee, Division of Oil and Gas Resources Management, In the Court of Common Pleas Franklin County, Ohio, Case No. 16 CV 006218, September 22, 2016, page 1.
[6] Won-Young Kim, “Induced seismicity associated with fluid injection into a deep well in Youngstown, Ohio,” July 19, 2013, Journal of Geophysical Research, Solid Earth, Volume 118, Issue 7, July 2013, Pages 3506-3518, http://onlinelibrary.wiley.com/doi/10.1002/jgrb.50247/full
[7] PDF uploaded document: RE: Northstar Kahlil #3 Well – Mahoning County; Ohio Department of Natural Resources, ORDER BY THE CHIEF, September 24, 2014, “Denial of Permit to Inject Brine or Other Waste Substances pursuant to Ohio Revised Code 1509.22: http://www.frackfreeamerica.org/uploads/1/2/4/0/12404661/2014_421_r.e._disposal_llc_denial_of_permit_to_inject.pdf
[8] PDF uploaded document: RE: Northstar Kahlil #3 Well – Mahoning County; Ohio Department of Natural Resources, ORDER BY THE CHIEF, September 24, 2014, “Denial of Permit to Inject Brine or Other Waste Substances pursuant to Ohio Revised Code 1509.22: http://www.frackfreeamerica.org/uploads/1/2/4/0/12404661/2014_421_r.e._disposal_llc_denial_of_permit_to_inject.pdf
[9] “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
[10] “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
[11] See K.M. Keranen, et al, “The injection-linked seismicity near Jones occurs up to 35 km away from the disposal wells, much further than previously considered in existing criteria for induced seismicity (13). Modern, very high-rate injection wells can therefore impact regional seismicity and increase seismic hazard.” , Sciencexpress, “Sharp increase in central Oklahoma seismicity since 2008 induced by massive wastewater injection, July 3, 2014, page 2.
[12] See Weingarten and others cited in the following post at: http://www.frackfreeamerica.org/blog/archives/10-2017 ; also see a new study that found according to the below url: “The cumulative volume of wastewater injected into the earth in Oklahoma is also higher than in the other oil-producing areas, and can also be linked to increased rates of seismicity in the state, the researchers said.” Science Daily, “Location of wastewater disposal drives induced seismicity at US oil site,” October 31, 2018, Source: Seismological Society of America,
https://www.sciencedaily.com/releases/2018/10/181031141454.htm
[13] “Confirmed: Fracking practices to blame for Ohio earthquakes by Charles Q. Choi, November 2, 2015, updated September 4, 2013, NBC News, https://www.nbcnews.com/sciencemain/confirmed-fracking-practices-blame-ohio-earthquakes-8C11073601
[14] “Earthquakes in Ohio,” by Michael C. Hansen, Updated 2015, EL 9., ODNR Division of Geological Survey, Educational Leaflet (EL) Series, page 8, http://geosurvey.ohiodnr.gov/publications-maps-data/free-downloads/educational-leaflets
[15] “Merry Christmas Brookfield: Here’s Five Salt Water Injection Wells, “ December 23, 2017, by Dr. Raymond Beiersdorfer, Distinguished Professor of Geology
Department of Geological and Environmental Sciences
Youngstown State University, published on Columbus Free Press at:
https://columbusfreepress.com/article/merry-christmas-brookfield-here%E2%80%99s-five-salt-water-injection-wells
Direct link to PDF: https://columbusfreepress.com/sites/default/files/associated/Merry%20Christmas%20Brookfield.pdf
Retrieved November 3, 2018.
Public Objections: ODNR, do not permit fracking waste injection well in Hubbard Twp, Ohio
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