Anti-Drilling Letter to OH Gov. John Kasich Requesting He Shut Down Injection Wells
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Anti-Drilling Letter to OH Gov. John Kasich Requesting He Shut Down Injection Wells



A letter authored by the misnamed (and anti-drilling) group Food & Water Watch, signed by 33 "groups" (mostly individuals) requesting Gov. Kasich immediately issue an executive order shutting down all ...

A letter authored by the misnamed (and anti-drilling) group Food & Water Watch, signed by 33 "groups" (mostly individuals) requesting Gov. Kasich immediately issue an executive order shutting down all of Ohio's deep injection wells used to dispose of frack wastewater. Don't expect any action on the recommendation from these "helpful" folks.



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Anti-Drilling Letter to OH Gov. John Kasich Requesting He Shut Down Injection Wells Document Transcript

  • 1. October 18, 2013 The Honorable John Kasich Governor of Ohio Riffe Center, 30th Floor 77 South High Street Columbus, OH 43215-6117 Dear Governor Kasich: We are writing to request that you issue an executive order to immediately halt the underground injection of drilling and fracking waste in Ohio. For too long, Ohio has served as the regional dumping ground for the oil and gas industry, with more than half of the waste disposed in Ohio coming from neighboring states. As you may know, Ohio injected nearly 600 million gallons of toxic fracking waste just last year, an unprecedented amount that stands to increase further if oil and gas development expands in our region. By serving as a regional dumping ground for the oil and gas industry, Ohio is taking an unacceptable risk, one that could haunt the state for generations. The below summarizes our concerns:     Underground injection disposal wells are causing earthquakes, and regulation can’t guarantee prevention, in part because scientists cannot predict when and where these earthquakes might occur, or how strong they might be; Fracking fluids, and thus fracking waste, typically contain undisclosed chemicals, many of which may be hazardous, yet the chemical composition of waste is not evaluated before injecting into oil and gas waste wells for disposal; Additionally, toxic heavy metals and radioactive material are present in liquid drilling and fracking waste; The casing and cementing of disposal wells do degrade over time, as wells age and are abandoned.i This creates new potential pathways for contamination of underground sources of drinking water, possibly by connecting with already existing faults or fissures through which injected fluids can flow, driven by variable and unpredictable geological pressure. We maintain that regulations cannot eliminate this risk, and that the long-term risk to Ohio taxpayers and communities outweigh short-term profit for companies. We commend your quick response to the earthquakes in Youngstown linked to the disposal of drilling and fracking waste by issuing an immediate moratorium on any new injection wells until rules were set in place to address seismic activity. Unfortunately, the rules that have since been developed cannot guarantee the prevention of future earthquakes. Indeed, the only way to guarantee that underground injection will not cause earthquakes is to cease underground injection.
  • 2. It is well known that many of the chemicals used to make fracking fluid, and that return to the surface in the liquid waste from fracking, are far from safe. Naphthalene, benzene and acrylamide are just a few of the known or suspected carcinogens identified as included in many fracking fluids.ii Indeed, sampling results from the Ohio Dept. of Natural Resources (ODNR) found alarming levels of environmental toxins at class II injection well sites in Ohio, including high levels of benzene, a known carcinogen.iii Other environmental toxins used in some fracking fluids, such as toluene, ethylbenzene and xylenes, can result in nervous system, kidney and/or liver problems.iv And because the oil and gas industry succeeded in getting fracking exempted from the Safe Drinking Water Act (except when diesel is used in the fracking fluid), operators do not always have to report the chemicals they are injecting underground.v As a consequence, the full extent of the public health threat from the chemicals in fracking waste remains Compounding the concern over the chemical components of fracking waste, we have grave concerns about the radioactive materials contained in the waste being disposed of in Ohio. Liquid waste from fracking is a varying mix of fracking fluid and other toxic fluids that would otherwise have remained trapped deep underground, well below fresh water aquifers.vii This liquid waste brings to the surface potentially extreme levels of harmful contaminants, including arsenic, lead, hexavalent chromium, barium, strontium, benzene, polycyclic aromatic hydrocarbons, toluene, xylene, corrosive salts and radioactive material, such as radium-226.viii Reports from the U.S. Geological Survey showed that waste imported to Ohio for disposal from Pennsylvania indeed contained radium-226.ix Radium-226 has a half-life of 1600 years, meaning that it will remain a hazard to human health and the environment for much longer than any of these injection wells will be monitored. Radium-226, it should be noted, is highly water-soluble and according to the U.S. EPA, when it is “inhaled or ingested radium increases the risk of developing such diseases as lymphoma, bone cancer, and diseases that affect the formation of blood, such as leukemia and aplastic anemia. These effects usually take years to develop. External exposure to radium's gamma radiation increases the risk of cancer to varying degrees in all tissues and organs.” Under the Safe Drinking Water Act, the U.S EPA established an Underground Injection Control (UIC) program for permitting the disposal of toxic wastes by injecting them underground into designated wells. These wells are now a primary means of disposing of fracking waste.x However, a lengthy investigation by ProPublica has exposed the shortsightedness of such disposal, highlighted how the federal rules under which the UIC program operates are outdated, and noted that some aquifers are being “exempted” so as to allow these injections.xi In essence, Ohioans are being made the subjects of a large, uncontrolled scientific experiment on the fate and transport of the chemicals injected. As Stefan Finsterle, a federal scientist, told ProPublica, “There is no certainty at all in any of this… You have changed the system with pressure and temperature and fracturing, so you don’t know how it will behave.”xii
  • 3. You are certainly aware that the Ohio Department of Natural Resources (ODNR) is currently being audited by the U.S. Environmental Protection Agency to maintain its primacy over the UIC program. ODNR inspection records of injection wells reveal cases of leakage, and even wells ordered to immediately cease operation that continue to operate today with no explanation to the public on how the violations were remedied or whether or not the well was brought back into compliance.xiii Simply hiring more inspectors will not be adequate to address the dangers inherent to injecting toxic, radioactive and hazardous waste underground. It only takes one accident to ruin an underground source of drinking water for a generation. Such a case of contamination, or a destructive earthquake in the future, could easily outweigh any of the short-term economic gains from allowing this toxic waste to flood into Ohio. And of course these short-term gains are only being enjoyed by a wealthy few, while Ohio taxpayers carry all the risk. Governor Kasich, you have expressed concerns about Ohio being labeled as a dumping ground for the oil and gas industry. We understand that Commerce Clause of the U.S. Constitution restricts your options, but we see a clear path forward that will not violate that clause. Ohio must ban injection wells, and by doing so, we would apply the law fairly and protect Ohioans from the impacts of drilling and fracking waste, regardless of where it was generated. In fact, other states have implemented similar bans without being declared unconstitutional. Therefore we urge you to immediately issue an executive order to ban injection wells used for oil and gas waste. Sincerely, Alison Auciello Food & Water Watch Bret Thompson Progress Ohio Patrick Kennedy Ohio Student Environmental Coalition Rev. Monica Beasley-Martin Defenders of Earth Outreach Mission Elyse Hirsch Stark-Summit Coalition Vickie Hennessy Green Environmental Coalition Bill Baker Frack Free Ohio Mary Z. Greer Concerned Citizens Ohio/Shalersville Dr. Joseph Cronin Ohio Alliance for People and Environment Katie McChesney Nick Teti Coshocton Citizens for Truth About Fracking Carol Apacki & Allen Schwartz Licking County Concerned Citizens for Public Health and Environment
  • 4. Caitlin Johnson Ohio Organizing Collaborative Teresa Mills Center for Health, Environment & Justice Cheryl Johncox Buckeye Forest Council Sherry Fleming Williams County Alliance Jonathan Smuck Jefferson County Ohio Citizens for Environmental Truth Leatra Harper FreshWater Accountability Project Ohio John M. Morgan Raven Rocks, Inc. John R. Rockwell Ohio Valley PEACE Patricia Jacobson FaCT – OV Rosemerry Rudesal & Kathy Schumann Concerned Citizens Ohio Ed & Mary Ellen Noss, Judith & David Hill, Jaime Sitko CCO/Hiram Vanessa Pesec NEOGAP (Network for Oil and Gas Accountability and Protection Madeline ffitch Appalachia Resist! Dorothy Faller West Shore FACT (Faith Communities Together for Fracking Awareness) Kristina Kistler FaCT (Faith Communities Together for Fracking Awareness) Sandra Bilek & Kathie Jones Concerned Citizens of Medina County Kathryn Hanratty Frack Free Geauga Jan Teaford Western Ohio Fracking Awareness Coalition Fran Teresi, Elected Trustee Garrestville Board of Public Affairs Donna Carver Morrow County POWER Heather Cantino Athens County Fracking Action Network Carolyn Harding Rad Waste Alert Molly Shea Frac Action Columbus i Dusseult, M., et al., “Why Oilwells Leak: Cement Behavior and Long-term Consequences,” Society of Petroleum Engineers, conference paper given November 2000. ii U.S. House of Representatives. Committee on Energy and Commerce. [Minority Staff Report]. “Chemicals used in hydraulic fracturing.” April 2011 at 9.
  • 5. iii Ohio Department of Natural Resources, Division of Mineral Resources Management. Random sampling of waste water from pits, a brine truck, and storage tanks. Public Record. June to September 2012. iv U.S. House of Representatives. Committee on Energy and Commerce. [Minority Staff Report]. “Chemicals used in hydraulic fracturing.” April 2011 at 10. v U.S. House of Representatives. Committee on Energy and Commerce. [Minority Staff report]. “Chemicals used in hydraulic fracturing.” April 2011 at 3 to 4. vi United States House of Representatives. Committee on Energy and Commerce. [Minority Staff report]. “Chemicals used in hydraulic fracturing.” April 2011 at 4. vii Nagy, Claudia Zagrean. Department of Toxic Substances Control, Maryland Environmental Protection Agency. “Oil exploration and production wastes initiative.” May 2002 at 6 and 10; United States Environmental Protection Agency. “Plan to study the Potential Impacts of Hydraulic Fracturing on Drinking Water Resources.” (EPA/600/R-11/122). November 2011 at 43. viii Urbina, Ian. “Regulation lax as gas wells’ tainted water hits rivers.” The New York Times. February 26, 2011; 76 U.S. Fed. Reg. 66286, 66296 (October 26, 2011); Mall, Amy and Dianne Donnelly. Natural Resources Defense Council. “Petition for Rulemaking Pursuant to Section 6974(a) of the Resource Conservation and Recovery Act.” September 8, 2010 at 8 to 9. ix Rowan, E.L., Engle, M.A., Kirby, C.S., and Kraemer, T.F., 2011, Radium content of oil- and gas-field produced waters in the northern Appalachian Basin (USA)—Summary and discussion of data: U.S. Geological Survey Scientific Investigations Report 2011–5135, 31 p. x U.S. EPA. [Progress report]. “Study of the potential impacts of hydraulic fracturing on drinking water resources.” December 2012 at 19. xi Lustgarten, Abrahm. “Injection wells: the poison beneath us.” ProPublica. September 20, 2012; Lustgarten, Abrahm. “The trillion-gallon loophole: Lax rules for drillers that inject pollutants into the earth.” ProPublica. September 20, 2012; Lustgarten, Abrahm. “Poisoning the well: how the feds let industry pollute the nation’s underground water supply.” ProPublica. December 11, 2012. xii Lustgarten, Abrahm. “Injection wells: the poison beneath us.” ProPublica. June 21, 2012. xiii Ohio Department of Natural Resources, Division of Resources Management. Inspection reports for wells API numbers 34009218990000 and 34009218990000. Public Record.