Letter to Editor 02

I write as a longtime property owner in Montgomery Township and an experienced oil and gas operator to correct Mike Butler’s letter concerning East Run, published May

28.

Mr. Butler mischaracterizes the litigation brought by neighboring Grant Township to halt injection of brine into an old natural gas well.

He characterizes the litigation as “environmental extremism” brought about by “radical, deep-pocketed, so-called environmental groups.”

The litigation is nothing of the kind, as I suspect Mr. Butler well knows.

The litigation was brought because the company proposing the disposal refused to correct significant defects in its plan that pose serious and unacceptable risks to human health and habitat in and around Grant Township.

Among the defects:

• The well proposed for brine disposal was drilled and completed for the production of natural gas; it was not designed for the injection of brine. The two uses are not interchangeable.

• The steel piping in that well does not have a pressure rating sufficient to handle the pressures under which the brine is to be injected.

• No emergency spill and

containment response plan was prepared.

• No performance bond is in place or proposed to provide financial

assurance that a spill can be managed.

• The geological formation into which the operator proposes to inject brine has not been mapped, and its connectivities with other formations, including upper fresh-water aquifers, are therefore unknown.

• Grant Township is a rural, agricultural area, dependent on well water for livestock and humans.

• Surface and subsurface spills of brine would likely flow into East Run itself, a freshwater brook with connection to the Little Mahoning, a trout stream.

• The disposal operation of briny wastes is proposed to be around the clock, 365 days per year, without on-site supervision.

So, a 24/7 unsupervised disposal operation of bulk liquids many more times salty than the ocean, into an unmapped formation, through an old, played-out well not designed for the purpose, with steel not rated to take the injection pressure, owned by someone without experience in deep-well injection, who also refuses to post financial surety and a remediation plan in case something goes wrong, located in an area completely dependent on well water.

Frankly, it would have been derelict for Grant Township not to have filed suit against such reckless disregard of health and safety.

Rick Kellogg

Cherry Tree