Ohio Environmental Council, March 25, 2013
We appreciate this opportunity to comment on the Ohio EPA’s draft model general permits for oil and gas well-site production operations and unpaved roadways and parking areas.
“Fracking” impacts many aspects of our environment; potential aquifer contamination, river, streams, wetland impacts, land use impacts, and air emissions. All of which impact our health, wildlife, environment, and communities.
These comments will focus on the air emissions from deep shale oil and gas operations. It has been documented that each of the phases of deep shale oil and gas operations degrade
We appreciate efforts to support efficiency. For example, eliminating the road inspections on days that the roadway is not used will eliminate a few unneeded trips to the well.
However, we encourage the Agency to work with industry to establish appropriate protocols to determine when a roadway will be in use/not in use. If roadway dust becomes an issue we encourage environmentally friendly ways to treat it. This does not include using brine waters from fracking operations, which can include toxins to people and wildlife.
The Agency should conduct more frequent inspections to enforce the current regulations. As more and more fracking operations come on line, the Agency needs to stay ahead of the curve.
Inspections of sites once a year, or even once every six months, is not effective given that so much of the total emissions occurs during the short, intensive well completion period. The Agency should ensure that, to the greatest extent possible, inspectors who are capable of identifying common and significant air emissions problems are present during the well completion phase.
Whether this means coordinating with ODNR to cross-train inspectors or hiring more EPA staff, it is essential to monitor emissions during well completion and flowback.
The Agency now has the authority to regulate the flowback from the completion stage. If the Agency regulates this under the General Permit, applicants should have to apply for a separate coverage for each individual well rather than have a broad permit for each well site.
Given that many wells can be drilled on one site, the Agency should explore ways in which each well flowback is regulated.
Click below to read OEC’s full comments.