Viewpoint: Request for Information – Class II Disposal Voluntary Well Shutdown, Washington County

Washington County for Safe Drinking Water has sent this list of questions to ODNR regarding the injection well issue.

Dear Chief Vendel and Division Staff,

We write on behalf of Washington County for Safe Drinking Water regarding the voluntary shutdown of injection well operations at four Class II injection wells in Washington County: Redbird No. 4, Redbird No. 5, American Growers No.1, and Nichols No. 1-A, which ceased operations on July 1 and 2, 2026.

As residents whose drinking water and property may be affected, we are seeking prompt and clear answers to the following questions and ask that the Division respond in writing:

Duration and Status of Shutdown:

Because the shutdown is voluntary rather than ordered, what are the implications if the owners do not comply, or resume injection before the Division considers the matter resolved? Will ODNR issue formal suspension orders if that occurs, and what would trigger that decision?

Is ODNR prepared to immediately issue formal suspension in the event that Deeprock Disposal Solutions LLC resumes injection?

Has the Nichols injection well actually ceased operations? According to WTAP on July 10: “Charlotte Nichols, who said she owns Nichols No. 1-A, reported to WTAP that the well had not ceased operations. When asked to clarify its status, ODNR Communications Chief Andy Chow reasserted that it was supposed to have ceased operations. "The Division Chief is under the impression that the well owner agreed to cease operations," he said.

Pressure and fluid monitoring

As pressure in the production wells decreases, where is the displaced fluid going?

If pressure continues to decline, does that indicate the threat to water resources has been eliminated, or only reduced? What measurement or threshold would the Division use to make that determination?

Will the Division establish and publish an upper limit on injection volume or pressure that the formations in this area can safely accept? If so, how will that limit be determined?

Water protection and testing

We are requesting long-term water quality monitoring at sources near the wells, not a single snapshot. Will the Division commit to ongoing, periodic water testing rather than a one-time assessment?

The consultant study is currently scoped to private drinking-water well owners only. Given that it has been confirmed that this waste can migrate, why is the scope limited? We request that your agency provide resources to monitor our public water sources as well.

If our public water sources become contaminated by these wells due to the Divisions failed permitting decisions, how will safe drinking water be provided to our community?

Will constituents and affected residents have a voice in selecting the consultant who will conduct the monitoring study? If not, we request that the Division share the scope of work and Quality Assurance Project Plan (QAPP) for the study before it begins.

When is the request for proposals (RFP) for the third-party study expected to be finalized and released?

As an agency that has received primacy from US EPA for Class II wells, does the Division have a Quality Assurance Officer (QAO) in place? Does the Division have a Quality Management Plan (QMP) in line with EPA's quality assurance guidelines? Does the Division require contractors to develop Quality Assurance Project Plans (QAPPs) and use accredited laboratories?

Cumulative and neighboring impacts

With these four wells shut down, where is the wastewater slated for injection in these wells being diverted? Is there a risk that injection at other Washington County nearby wells will increase, shifting waste migration to other production wells or areas? How is the Division monitoring for that?

Why is the Division limiting the continuous pressure monitoring to nearby oil and gas wells to the injection wells listed? What is the Division doing to ensure the Heinrich #1 and #2 and Vocational School wells are not migrating brine waste also?

The 2020 Redbird investigation concluded that impacts would subside once injection into the Ohio Shale formation stopped, yet impacts have now reoccurred. What has the Division learned about why the earlier conclusion did not hold, and how does that inform the current response?

Why wasn't the Redbird #2 well included in the list of wells that were voluntarily shut down?

Terminology and communication

We request that the Division consistently refer to the injected material as "production waste" in its communication rather than "salt water" or "brine," to reflect its actual composition and known hazards.

We request that the Division share a clear communication plan regarding these shutdowns so that residents can receive timely and direct information.

The history of “unprecedented migration of brine” has already been established by ODNR. The Redbird #4 well in Washington County, the Warren and Travis Wells in Noble County, the K&H wells and the Reliable Resources Wells in Athens County have all been documented to have impacted oil and gas wells from miles away. We request that the Division completes a comprehensive investigation of the geology, brine migration and potential impacts to drinking water sources in Washington, Noble, and Athens Counties. This is the only way to know the true impacts to our geology and threats to drinking water, rather than a piecemeal approach.

Given these new concerns of ODNR of brine migration in the same vicinity, the ODNR should notify DeepRock that the 2 wells, the Stephan 1 and American Growers 4, that ODNR permitted to drill in 2025 will not be granted a permit to inject should the wells be drilled. A comprehensive investigation of the geology of Southeastern Ohio should be completed and in the mean time there should not be any further injection of fluids injected and no additional wells should be drilled while the investigation is ongoing. These are the same requests that a group of water authorities along with the City of Marietta and other municipalities requested be done in their resolutions passed earlier this year. Those resolutions were never responded to by the ODNR or the state. It is time to enact what the entities have requested, given the renewed concern of brine migration in Washington County.

We respectfully request a written response within 30 days and would welcome a public meeting to discuss these matters.