The letter requests that the Governor of Ohio issue an executive order to immediately halt the underground injection of drilling and fracking waste in Ohio due to various environmental and public health concerns. Specifically, it notes that Ohio has become the regional dumping ground for fracking waste, injecting nearly 600 million gallons last year. Underground injection disposal wells have been linked to earthquakes and the casing and cementing of wells degrade over time, creating potential pathways for underground water contamination. The waste also contains harmful and carcinogenic chemicals as well as radioactive materials like radium-226 that will remain hazardous for generations. Regulations cannot eliminate these risks to local communities and taxpayers.

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:
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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
unknown.vi
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
350.org
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.