Deny Permits for the K&A Oil and Gas Injection Well near Sardis, OH

Chief Eric Vendel, Ohio Department of Natural Resources Division of Oil and Gas Resources Management

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A new injection well proposed for construction in Monroe County, Ohio threatens local residents with hazardous air pollution, radioactive groundwater contamination, and the risk of earthquakes.

K.A. Brown Oil & Gas, LLC, is applying to permit a brine waste injection well near Sardis, Ohio. The proposed well will inject at a depth of 12,200 to 12,900 feet. The average injection is estimated to be 2,500 barrels per day, and the maximum injection pressure is estimated to be 2,810 psi.

Local residents have serious concerns about the safety and integrity of the facility, which cannot be guaranteed by Ohio's regulatory agencies.

Ohio law and regulations provide:

  • No air monitoring of volatile organic compounds venting from waste storage tanks
  • No limits on air emissions venting from the waste storage tanks
  • No vapor recovery requirements for waste storage tanks, one of which holds 2.5 million gallons
  • No lightning arrestors on the 2.5 million gallon tank or any others at the site
  • No ground water monitoring for potential contamination of private wells
  • No mapping of aquifers in the region or consideration of aquifer locations for siting of wells
  • No testing for possible migration of contamination through fissures created by high-pressure injection
  • No testing for radioactive material in the waste
  • No seismic monitoring for potential earthquake activity
  • No local control or honoring of community officials’ objections or concerns
  • No monetary, job, or other economic benefits to local communities

Groundwater contamination

This injection well site is less than a mile south of the Monroe Water Systems water plant. Any unknown fissures in the underlying formations could and would lead to contamination of the aquifer utilized by the water plant.  This would leave a large portion of Monroe County with a contaminated drinking water supply.  This site is also in very close proximity to Deadhorse Run,  a direct tributary of the Ohio River.  Spills from this operation would easily make their way to the Ohio River likely before remediation efforts could take effect. This site will also be a safety hazard due to the increased truck traffic it will cause on Route 7.  There will be truck traffic both day and night during drilling and injection operations.

Moreover, the map included with the permit application does not identify the area of review as required by OAC 1501:9-3-06. The application does state that there are no wells in the geologic formation of the proposed injection zone. However, there are at least 5 plugged gas wells within a half mile of the proposed injection well. In addition, there is a producing oil and gas well within 261 feet of the proposed injection well. The application also makes no mention of active water wells in the affected zone.

Air pollution

There is reasonable concern that with increasing numbers of brine injection wells in the State of Ohio that there will be increasing volumes of volatile organic compounds emitted into the air from vented tanks associated with the injection well process. Some of the chemicals of concern found in oil & gas wastewater include benzene, toluene, xylene, ethylbenzene, radium, and barium. ODNR must explain these chemical hazards in a public hearing to ensure Monroe County's residents are properly informed of these dangers.

Earthquakes

The depth and pressure of the proposed injection well raises grave concerns about the possibility of dangerous seismic activity. The recent breach of 28 oil and gas wells in Washington County at the Red Bird #4 SWIW well was determined to have been caused by increased injection pressure, as was documented in the Washington County Produced Water Investigation Report of August 2020. The depth of this proposed well cannot guarantee that there will not be fractures in the formations prior to the targeted injection formation. This concern is only exacerbated when considering such a high injection pressure. One additional piece of information worthy of note is the fact that the Monroe Water Systems water plant and wells which supplies drinking water to much of Monroe County lies approximately 7 tenths of a mile north of the proposed  injection well site. Any breach of the aquifer utilized by Monroe Water System will leave a significant portion of Monroe County without a public drinking water supply.  

We deserve a say!

Local residents deserve a chance to voice their concerns about the proposed injection well. The permit notice was published in the Marietta Times, a newspaper based in Washington County. Therefore, residents of Monroe County did not receive proper notice of this proposed injection well as required by OAC 1501:9-3-06 H.

Please join us in demanding the Ohio Department of Natural Resources deny all permits associated with the Johnson Township injection well. We deserve an extended comment period and a public hearing to ensure transparency about the risks this project poses to Monroe County residents.

To: Chief Eric Vendel, Ohio Department of Natural Resources Division of Oil and Gas Resources Management
From: [Your Name]

Subject: Guy Brown #1 aPATT033932 SWIW

To: Eric Vendel, Ohio Department of Natural Resources Division of Oil and Gas Resources Management

Dear Chief Vendel,

I'm writing to submit a public comment on the injection well located in Jackson Township, Monroe County, OH; Guy Brown #1 aPATT033932 SWIW.

I urge the Ohio Department of Natural Resources Division of Oil & Gas Resources Management to deny all permits associated with this injection well facility.

The facility poses a grave and immediate threat to local residents and the natural resources upon which their health and livelihoods depend. The Jackson Township injection well could cause immeasurable and unforeseeable damage to local air quality and groundwater supplies. Injection wells are known to spew hazardous, potentially carcinogenic air pollutants into the local atmosphere during the venting process, which could seriously harm the health of residents living near the well. The injection of oil and gas wastewater also poses an enormous threat of groundwater contamination. This injection well site is less than a mile south of the Monroe Water Systems water plant. Any unknown fissures in the underlying formations could and would lead to contamination of the aquifer utilized by the water plant. This would leave a large portion of Monroe County with a contaminated drinking water supply. This site is also in very close proximity to Deadhorse Run, a direct tributary of the Ohio River. Spills from this operation would easily make their way to the Ohio River likely before remediation efforts could take effect. This site will also be a safety hazard due to the increased truck traffic it will cause on Route 7. There will be truck traffic both day and night during drilling and injection operations.

Moreover, the map included with the permit application does not identify the area of review as required by OAC 1501:9-3-06. The application does state that there are no wells in the geologic formation of the proposed injection zone. However, there are at least 5 plugged gas wells within a half mile of the proposed injection well and a producing oil and gas well within 261 feet of the proposed injection well. The application also makes no mention of active water wells in the affected zone.

OAC 1501:9-3-06 B requires an area of review spanning a half-mile radius from the location of the injection well for wells with an average injection volume above 200 barrels per day, unless otherwise designated by the chief for good cause. As the chief has not issued any specific designation and the proposed well meets the requirements for a half-mile radius area of review, further evaluation, including an analysis of the impact of drilling such a well near existing well infrastructure, must be conducted before any permits can be legally issued.

There is reasonable concern that with increasing numbers of brine injection wells in the State of Ohio that there will be increasing volumes of volatile organic compounds emitted into the air from vented tanks associated with the injection well process. Some of the chemicals of concern found in oil & gas wastewater include benzene, toluene, xylene, ethylbenzene, radium, and barium. ODNR must explain these chemical hazards in a public hearing to ensure Monroe County's residents are properly informed of these dangers.

The depth and pressure of the proposed injection well raises grave concerns about the possibility of dangerous seismic activity. The recent breach of 28 oil and gas wells in Washington County at the Red Bird #4 SWIW well was determined to have been caused by increased injection pressure, as was documented in the Washington County Produced Water Investigation Report of August 2020. The depth of this proposed well cannot guarantee that there will not be fractures in the formations prior to the targeted injection formation. This concern is only exacerbated when considering such a high injection pressure. One additional piece of information worthy of note is the fact that the Monroe Water Systems water plant and wells which supplies drinking water to much of Monroe County lies approximately 7 tenths of a mile north of the proposed injection well site. Any breach of the aquifer utilized by Monroe Water System will leave a significant portion of Monroe County without a public drinking water supply.

Local residents deserve a chance to voice their concerns about the proposed injection well. The permit notice was published in the Marietta Times, a newspaper based in Washington County. Therefore, residents of Monroe County did not receive proper notice of this proposed injection well as required by OAC 1501:9-3-06 H. This oversight must be rectified with an extension of the public comment period to allow unaware residents of Monroe County to voice their concerns.

We also demand a public hearing with additional information about the potential threats posed by this facility. At the very least, local residents deserve transparency about the deleterious effects an injection well could have on the local community.

The evidence against fracking waste injection is ample and irrefutable. Please take seriously our concerns and deny all permits associated with the Jackson Township injection well facility.