Ryan Hancharick
Source Water & UIC Section
U.S. EPA Region 3
October 16, 2025
Re: Comment on Permit #PAS2D041BBEA, Columbia Gas, Underground Injection Control Authorization to Operate a Class II-D Injection Well.
Dear Mr. Hancharick,
The Beaver County Marcellus Awareness Community (BCMAC) thanks you for the opportunity to submit comments on Underground Injection Control Permit Number PAS2D041BBEA Authorization to Operate a Class II-D Injection Well. BCMAC was founded in 2009 by a group of Beaver County residents concerned about their drinking water being affected from increased fracking activities in the area. BCMAC aims to educate and raise awareness of the dangers of petrochemical build-out in our region. Clean air and water are critical to the health, vitality and economic prosperity of our communities. BCMAC opposes this permit authorizing the Columbia Gas Injection Well due to the risk of both surface and groundwater contamination in Beaver Falls.
The Commonwealth of Pennsylvania promises in its constitution “a right to clean air, pure water, and to the preservation of the natural, scenic, historic and esthetic values of the environment” through its environmental rights amendment. These natural resources are “the common property of all the people,” and it is the duty of the Commonwealth to “conserve and maintain them.” The Columbia Gas Injection Well gambles with Beaver Falls residents’ right to pure water, disregarding their opposition to the project in favor of industrial convenience.
We have concerns with the following:
First, this permit has no mention of PFAS or radiological monitoring. There are no clear, defined monitoring standards, including regular inspections and testing. This permit needs clearly defined and more frequent monitoring requirements—including inspections and sampling to prevent and minimize contamination events.
Notably, there is no indication in the report that the wastewater was tested for PFAS. PFAS chemicals are associated with a range of health effects including reproductive effects for those experiencing pregnancy, developmental effects in children, increased risk of certain cancers, reduced immune system responses, hormonal interference, and increased cholesterol levels.[1] They are commonly known as “forever chemicals” because of how slowly they break down, and for how long they linger in the environment in which they are released.[2] These chemicals are often included in fracking wastewater for a range of reasons including “killing bacteria inside the wellbore, reducing friction during high-pressure fracking, and as gelling agents to thicken the fluid” despite the risks that they pose to human and wildlife health. [3]
In 2021, the group Physicians for Social Responsibility published a report showing that between 2012 and 2020, at least 1200 fracking wells were injected with liquid containing either PFAS or substances that can degrade into PFAS.[4]Because of the health risks and because of how common PFAS use is in fracking wastewater, we ask that the EPA require Columbia Gas to show that the wastewater does not contain PFAS.
The Underground Injection Control (UIC) regulations governing Class II Injection Wells require “[m]onitoring of the nature of injected fluids at time intervals sufficiently frequent to yield data representative of their characteristics.”[5] Additionally, the operator of the well must provide to the EPA once per year “monthly records of injected fluids.”[6] The EPA should require should also require Columbia Gas to monitor the wastewater for radium, radon and PFAS and state it in permit #PAS2D041BBEA.
Second, there are no pollutant limits, threshold values, or incident conditions listed in this permit that require an immediate report to regulatory agencies or the public. This permit needs to clearly define standards, limits and incidents so that it’s understood when immediate reporting is needed and to ensure accountability and timely action in the event of a contamination or system failure.
Finally, the Commonwealth of Pennsylvania promises in its constitution “a right to clean air, pure water, and to the preservation of the natural, scenic, historic, and esthetic values of the environment” through its Environmental Rights Amendment.[7] Pennsylvania residents have a right to clean air and water guaranteed by our constitution. This injection well is 858 feet from dwellings. It’s also 1210 feet from Brush Run, a local stream in the Ohio River Basin that flows into the North Fork Little Beaver Creek, which then flows into the Ohio River. North Fork Little Beaver Creek is also a Pennsylvania tributary to the main Little Beaver Creek, flowing through Beaver County and near the town of Darlington before entering Ohio. It is a designated wild and Scenic River in Ohio. Contamination would be devastating.
Given the proximity of this injection well to residential homes and waterways, the risks are simply too great to overlook. Clean air and water are the foundation of healthy, thriving communities, and once contaminated, they cannot easily be restored. Approving this permit would disregard the Commonwealth’s constitutional duty under Article I, Section 27 to protect these shared natural resources for present and future generations. BCMAC respectfully urges the EPA to deny this permit and to uphold its responsibility to safeguard the health, safety, and environmental integrity of Beaver County residents and the broader Ohio River Basin.
Sincerely,
Hilary O’Toole
Executive Director, BCMAC
[1] 12 U.S. Env. Prot. Agency, Our Current Understanding of the Human Health and Environmental Risks of PFAS, https://www.epa.gov/pfas/our-current-understanding-human-health-and-environmental-risks-pfas (June 7, 2023).
[2] Hiroko Tabuchi, EPA Approved Toxic Chemicals for Fracking a Decade Ago, New Files Show, New York Times (July 2021).
[3] Dusty Horwitt, Fracking with “Forever Chemicals”, Physicians for Social Responsibility, 5, https://psr.org/wp-content/uploads/2021/07/fracking-with-forever-chemicals.pdf (July 2021).
[4] Id. at 3.
[5] 40 CFR § 146.23(b).
[6] 40 CFR § 146.23(c).
[7] Pa. Const. art. I, § 27.