On April 11, 2014 the Ohio Department of Natural Resources (ODNR) published on its website a press release stating that “recent seismic events in Poland Township (Mahoning County) … show a probable connection to hydraulic fracturing.” This finding is of both scientific and political significance. People in cities like Youngstown are voting on ballot issues to permit fracking within their communities, with wells as close as 150 feet of their homes.

According to ODNR spokesperson Mark Bruce no report will be issued and a public records request must be filed to look at the data. The conclusions of ODNR's study, as described in the press release, are very significant. Yet the ODNR is not creating a report and not making this data readily available on-line for the scientific community to review. I have made a public records request for all available data related to the Mahoning County 2014 earthquakes. This includes all geologic, geophysical (incl. Seismic) and all petrophysical (well logs), drilling, fracking and production data by Hilcorp in ODNR's possession and can be made available. These public records requests have not be fulfilled.

The press release states that "ODNR Director James Zehringer announced new, stronger permit conditions for drilling near faults or areas of past seismic activity." The press release did not specify what the new conditions are. My understanding is that conditions are not the same as rules. "The new policies are in response to recent seismic events in Poland Township (Mahoning County) that show a probable connection to hydraulic fracturing near a previously unknown microfault." The ODNR does not explain the meaning of the word microfault. This is not a common geological term. The Glossary of Geology (3rd edition with over 34,700 terms) does not include microfault. Structural geology textbooks (such as the one written by my former graduate school professors Robert Twiss and Eldridge Moores) state that microfaults can only be visible under a microscope. How did ODNR identify the microfault? The five seismic stations located within 8 miles of the epicenter of the March 10th Magnitude 3.0 quake sure will not provide high enough resolution to do it.

What data did ODNR use to make the probable connection between the seismicity and hydraulic fracturing? This is a very significant conclusion. After the announcement I was interviewed by journalists from Reuters and the Los Angeles Times, and from a radio news program as far away as Ballarat Australia. As I understand it, Hilcorp collected densely spaced seismic reflection data (3-D seismic) prior to drilling. It is not clear how this data was used nor are the faults, if any, identified by this data mapped.

Other than seismic data from the Ohio Seismic Network, it is not clear if the Ohio Geological Survey was involved with making this determination or if it was strictly within the ODNR Division of Oil and Gas Resources (DOGR). After the "Frackgate" incident from 2012 where ODNR developed a plan to promote shale gas fracking in Ohio's state parks and the more than eight month's of denial between a connection between the 2011 Youngstown earthquakes and a nearby injection well, ODNR, especially DOGR has been called a "Captured Agency" by many, including myself.

In 2011 it took ODNR from March 17th until December 30th to make the probable connection between the earthquakes in Youngstown and the injection well. On October 30th, 2011 in the Youngstown Vindicator, ODNR spokesperson Heidi Hetzel-Evans was quoted as saying, “ODNR has not seen any evidence that shows a correlation between localized seismic activity and deep injection well disposal.” What changed at ODNR that such a determination was made within one month is not clear.

ODNR's new conditions will impact future permit applications for "horizontal drilling within 3 miles of a known fault or area of seismic activity greater than a 2.0 magnitude" They will "require companies to install sensitive seismic monitors. If those monitors detect a seismic event in excess of 1.0 magnitude, activities would pause while the cause is investigated. If the investigation reveals a probable connection to the hydraulic fracturing process, all well completion operations will be suspended."

It is important to realize that none of these new permit conditions will prevent earthquakes. If they will not prevent earthquakes, how can they "help to ensure public health and safety ?" They just define new policies to pause activities and possibly suspend well completion activities. Hydrocarbon production from the wells will continue, like in the recent Hilcorp case. The new conditions do not define what a “known fault” is or by whom the “fault” is “known.” What if a company has proprietary seismic reflection data that can be interpreted to include a fault that is not known by the ODNR but is now known by the company. It is not clear if they are required by law to identify this fault to the ODNR. There would be an incentive to not report such faults because it will add extra scrutiny and costs. Can a company be required to prove there are no faults nearby by providing ODNR with ALL available seismic reflection data?

Why was a distance of "within 3 miles (15,840 feet) of a known fault" chosen and does this apply vertically as well as horizontally? By my estimates the lateral leg of the Hilcorp wells in Poland Ohio are about 1,500 feet above the PreCambrian basement. Preliminary results from a US Department of Energy funded study from 2013 indicated that a fracture was propped open for 1,800 feet.

Why was magnitude 2.0 chosen as the cut off? This is near the boundary between where humans can feel the earthquake. The observed seismicity due to fracking in the Horn River Basin of British Columbia, Canada were from Magnitudes 2.2 and 3.8. These quakes were strong enough to deform the well casings in the lateral portions of nearby wells.

The idea of “known” faults based on seismic reflection data brings up the question regarding the mapping of faults in the PreCambrian basement. Because of the large difference in seismic velocities between the overlying sedimentary rocks and the igneous and metamorphic rocks of the basement this contact be a strong reflector that may prevent any detailed mapping of deeper faults. The 109 injection-inducted earthquakes in Youngstown occurred in this basement rock.

In addition to his debatable claim that the new permit conditions will "ensure public health and safety" the ODNR Director asserts that they will help "to expand our underground maps and provide more information about all types of seismicity in Ohio.” There is presently an abundance of proprietary seismic reflection data belonging to numerous oil and gas companies. The Director should establish rules for companies to make this data available to ODNR prior to drilling and to prove their seismic reflection data shows no identifiable faults. The ODNR should establish a strong working relationship with the EarthScope program to carefully look for evidence of previously unknown faults based on data collected when the Earthscope seismic array was in Ohio.

The press release included platitudes for the ODNR from Gerry Baker, Associate Executive Director of the Interstate Oil and Gas Compact Commission and Mike Paque, Executive Director of the Groundwater Protection Council. ODNR pays dues (The IOGCC website says the dues are $8,500 per year per state) to belong to the Interstate Oil and Gas Compact Commission. What assurances do we have that Associate Executive Director Gerry Baker, is an independent and impartial commentator? On the Groundwater Protection Council (GWPC) website and the web links of associations that “frequently interact with the GWPC” they are almost all Oil and Gas associations. With such strong industry ties there is little to no evidence that the GWPC is independent and impartial.

In the press release Gerry Baker is quoted as saying “These additional standards add even more strength to Ohio’s already comprehensive regulatory program” These standards are less strict than the ones adopted in the UK which have a threshold of Magnitude 0.5 and require microseismic monitoring (which entails hundreds of geophones) for the next fracturing treatment of the shale in question.

ODNR points out that "more than 800 wells have been drilled in Ohio’s Utica and Marcellus shale play, including as many as 16,000 hydraulic fracturing stages from those wells. Regarding the seismic events in Poland Township, Mahoning County, ODNR geologists believe the sand and water injected into the well during the hydraulic fracturing process may have increased pressure on an unknown microfault in the area." The hazardous chemicals used in fracking not mentioned along with the water and sand. The ODNR is aware that fracking cannot be done without using these chemicals. The 800 wells and 16,000 fracking stages include between 4 and 6.4 billion gallons of injection fluid. If only one-half of a percent of this is hazardous that still adds up to 20 to 32 million gallons of toxic chemicals that have been injected underneath eastern Ohio.

Repeatedly calling something a "microfault" without providing any evidence that the fault is microscopic in size (which it isn't) seems more like propaganda to instill a false sense of security from fracking-induced earthquakes. This type of a statement is aligned with the targets of the communication plan exposed in the "frackgate" memo, despite insistence that the plan was never implemented.

Who are these ODNR geologists? It is my understanding that the only part of the Ohio Geologic Survey that was involved in this study was the Ohio Seismic Network. Were these geologists part of the ODNR Oil and Gas Resources? Who are they and what data did they use?

As this shale gas development continues unabated are we learning that there are parts of the state that should be off-limits to fracking and/or injection wells due to their seismic hazards? There are also numerous chemical pollution, radioactive contamination and human health hazards. The ODNR has made no plans to address them.

How does ODNR know that recovering resources from five other wells located on the same pad will have the beneficial effect of reducing underground pressure and decreasing the likelihood of more seismic events? The National Research Council recently published (2012) a report lists 20 cases of pore pressure reduction from hydrocarbon production causing earthquakes. These occurred in CA, IL, NB, OK, TX and the majority of them were less than M 4.0. However, seismically active California suffered at least three large hydrocarbon-withdrawal-induced earthquakes. The biggest was a magnitude 6.5 temblor at Coalinga in May 1983, resulting in $10 million in damages and numerous injuries. Fortunately no one was killed. The Coalinga quake occurred along a buried unknown fault. The Gazli gas field in Uzbekistan had three large earthquakes in an area that was nearly aseismic before gas extraction began.

Based on the data ODNR used to determine the probable connection what can be said about the nature of these occurrences?

Every time there is an earthquake there has been movement along a fault. The spot on the fault within the earth is called the focus (or hypocenter) of the earthquake. In injection induced seismicity the fluid pore pressure at the soon to be active fault is raised by the pumping of the fracking or frack-waste fluid. In the case of the Poland earthquakes that means the frack fluid traveled along pre-existing fractures in the Utica shale all the way to where the fault is located.

Let’s look at two scenarios: the fault being either above or below the Precambrian – Paleozoic Boundary. I estimate that this boundary is 1,500 feet below the lateral portion of the well (8,100 feet) where the fracking was occurring near Poland. The Ohio seismic network lists an assigned depth of 5 km (16,400 feet) for all the earthquakes in Poland. This makes the below the boundary case more likely. This is supported somewhat by the Youngstown earthquakes because they were more precisely located at depths of 3.5 to 4 km.

If the fault is below the boundary, injection fluid would have had to travel over 1,500 feet below the wells to reach the fault. Fractures in other fracked wells have been recorded to be propped opened that far of a distance but usually above (not below) the laterals. If this is the correct case, then there are at least three earthquake faults in the Mahoning valley and it would be reasonable to assume there are probably more. Maybe we shouldn’t frack in the shale when it so close to the basement? Is the Utica Shale located too close to the basement rock and its faults to safely frack it?

The other scenario puts the fault in the Paleozoic, maybe within the Utica Shale itself. This would mean that it is imperative to determine that the Utica Shale (and other stratigraphically nearby geologic formations) is/are fault-free before companies are permitted to drill and frack it in an area that includes the well foot-print plus another buffer distance, maybe three miles. The burden would be on the companies to prove there are no faults there, not just to install monitors after they trigger an earthquake or two.

Since The Ohio Seismic Network was established in 1999, Ohio has experienced 109 events greater than 2.0 magnitude. How many of these were injection induced? In 2011 11 of the 18 earthquakes were in Youngstown. Three in Marietta were proposed to also be injection induced that year. That would make 14 of the 18 quakes (77%) due to the oil and gas industry. Is this the seismic future we should be looking at. The portable seismic stations not under the control of the Ohio Seismic Network. The Underground Injection Control program control the deployment of the portable stations, despite the admission that we now know fracking also caused earthquakes in Ohio.

After fracking- related earthquakes in Canada, England and Oklahoma, government agencies issued reports documenting the occurrences. Ohio has provided a press release. This type of a response in inadequate and demands a detailed report from people whose salary and an agency who's revenue are independent from the results.

Editors Note:  You may download the files associated with a new Frac in Youngstown below