Updated Mon, Dec 2, 2013 6:29 pm
Violations that have occurred in the past at the Ginsburg injection well on Ladd Ridge Road have not posed a risk of contamination to underground drinking water, according to a state official.
In a letter dated Monday, Deputy Chief Robert Worstall of the Division of Oil and Gas Resources Management responded to a resolution from the Athens County Commissioners that called for shutdown of the well.
The resolution stated that the Ginsburg well “has a 25-year history of violations, well failures, notices to be shut down and incomplete inspection reports.” Among the concerns expressed in the resolution are that:
• There is an unfenced, open pit that receives "toxic, radioactive waste."
• There have been "reports of evidence" that the pit has overflowed or leaked.
• That "people spending time on the public road near the well have consistently experienced headaches, nausea and burning eyes within 10 minutes."
• That used filters at the well are handled by workers without protection.
The resolution, approved last month, also asserts that the well does not meet Ohio permitting standards, "which are also inadequate to protect drinking water and communities from toxic, radioactive contamination."
Worstall acknowledged that violations have occurred at the well.
"During the 30-year lifespan of the well, violations and chief's orders have been issued to the various operators of record," Worstall wrote. "However, the frequency or severity of the violations have never been, and are not now considered, excessive or abnormal.''
The majority of violations, according to Worstall, have dealt with the condition of equipment, the mechanical integrity of the isolation packer located on the base of the injection tubing or the well not being actively in use.
"None of these instances would lead to the contamination of the underground drinking water sources," Worstall wrote.
He said there is a "common misconception" that when the isolation packer loses integrity, fluid escapes from a well into the environment.
There have been instances when surface contamination occurred, Worstall indicated.
"When cited by ODNR inspectors for violations regarding surface pollution or contamination, the operator has corrected all issues," Worstall wrote. "The corrective action included removal and proper disposal of all impacted soil, followed by seeding and mulch."
He said that the concrete settling pond is allowed by law.
"There has never been any indication that the pit has experienced leakage and on the occasions that the containment has been observed near capacity by division inspectors, the situation has been remedied by the operatior," he wrote.
Since 2000 (when electronic reporting of inspections began), the Ginsburg well has been inspected 118 times.
"For comparison, the U.S. EPA would have required only 14 inspections for that same period," Worstall wrote.
He said the United States EPA has "long recognized and stated" that properly constructed and regulated injections wells are the safest way of disposing of oil and gas well waste.
"The Ginsburg well is currently in compliance with Ohio's laws and regulations and any order to cease operations would be without basis and illegal," Worstall concluded.