[Green] ODNR responds to questions at injection well meeting

[gbanz42 at suddenlink.net]

Thanks, Dawn

Below are my comments to the ODNR document...

   I have reviewed the document. Here are my thoughts: 
 
   1. I think the Division (Oil & Gas Resources Management) is positioning 
itself for approving the application from Arrowhead Road Services LLC. The 
document mentions in several places that if all rules/regulations are met in the 
application, they are obligated to approve it. This leads to my first question. 
Why isn't  the reaction of the local community, as expressed in a  public 
meeting, part of the permitting process? If it were in this case of Arrowhead 
Road Services, the application would certainly be denied or delayed. 
 
   2. Several of the responses of the Division in this document are mere 
deflections of responsibility. In response to the question raised at the meeting 
about air emissions, they write that air emissions are Ohio EPA's 
responsibility. I have a similar reaction to the one above--why can't the 
criterion of assurance about air emissions be part of the permitting process? 
Ohio EPA should sign off on every application when it comes to this criterion of 
impact on air quality. 
 
   3. Same issue when it comes to their response about truck transport of brine 
waste. They deflect this concern  by writing that truck routes and spills on 
roads are ODOT's responsibility. Again, why isn't this item part of the 
permitting process? ODOT should sign off on all these applications, especially 
since so much of this brine waste is being transported by truck. 
 
   4. In response to the question about why  so much brine waste is coming from 
other states (PA & WV primarily), the document states that each state's rules on 
brine waste depend on  their "regulatory set up."  Why do these two neighboring 
states have a stricter "regulatory set up" than Ohio does? 
 
    5. The pressing question about what brine waste is got an interesting 
response. The document referred the reader to the Frac Focus database. In that 
database it is mentioned that 0.5-2% of brine waste is comprised of chemicals 
(of course, with millions of barrels involved this is not a trivial amount). 
That database does NOT identify the chemicals in brine waste--merely their 
function, e.g., "corrosion inhibitor" This is an egregious evasion of 
fact--chemicals like arsenic, lead are, in fact,  the toxic substances in brine 
waste. 
 
    6. There was a question raised at the meeting about the lack of an emergency 
response plan in the application. The Division's response  is that this is not 
required--all the applicant has to do is identify local first responders. Why 
isn't such a plan part of the permitting process? 
 
    7. The Division has stated numerous times, as they have in this document, 
that  the Division responds to requests for public meetings only from public 
officials. Where in the regulations that apply to the Division's activities is 
that mentioned? Why can't a resident of the township or county where the 
proposed injection well is to be located request a public meeting and ODNR grant 
such a request? 
 
    I would be curious about your reactions to this document. 
 
 
 
---- Dawn Hewitt via Green <green at fuusm.org> wrote: 
> I assume my Green friends who attended the ODNR meeting also received this, but for those who didn’t, the ODNR responses to questions is worth reading. Nothing revelatory, but probably something we should pay attention to. If you can’t open the PDF attachment, there is also a website link. —dawn
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> 
> > ---------- Forwarded message ---------
> > From: oilandgas at dnr.ohio.gov <mailto:oilandgas at dnr.ohio.gov> <oilandgas at dnr.ohio.gov <mailto:oilandgas at dnr.ohio.gov>>
> > Date: Fri, Jul 1, 2022 at 2:59 PM
> > Subject: Arrowhead Road Services #2 Comments and Responses
> > To: Mark.Bruce at dnr.ohio.gov <mailto:Mark.Bruce at dnr.ohio.gov> <Mark.Bruce at dnr.ohio.gov <mailto:Mark.Bruce at dnr.ohio.gov>>, Adam.Schroeder at dnr.ohio.gov <mailto:Adam.Schroeder at dnr.ohio.gov> <Adam.Schroeder at dnr.ohio.gov <mailto:Adam.Schroeder at dnr.ohio.gov>>
> > 
> > 
> > Good Afternoon,
> > 
> > Your email was provided at the ODNR Division of Oil and Gas Resources Management Public Meeting held June 2, 2022 in Belpre Township, Washington County or upon submittal of a comment regarding the Arrowhead Road Services #2 well.
> > 
> > The Division has compiled responses to the comments submitted regarding the Arrowhead Road Services #2 well. The responses are attached to this email and are posted on the following page: https://ohiodnr.gov/discover-and-learn/safety-conservation/about-ODNR/oil-gas/oil-gas-resources/dogrm-public-notice <https://ohiodnr.gov/discover-and-learn/safety-conservation/about-ODNR/oil-gas/oil-gas-resources/dogrm-public-notice>
> >  
> > 
> > Thank you for your comments. A decision regarding the permit application has not been made.
> > 
> >  
> > 
> > Please respond to this email if you have any questions.
> > 
> >  
> > 
> > Regards,
> > 
> > Mark Bruce
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> > Mark Bruce
> > 
> > Ohio Department of Natural Resources
> > 
> > Division of Oil and Gas Resources Management
> > 
> > 2045 Morse Road, Building F-3
> > 
> > Columbus, Ohio 43229
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--
George Banziger
202 Lawton Road
Marietta, OH 45750-1111
740-434-5685
cell: 740-434-3354