Comments to the OEPA by Coshocton Area Citizens on the Permitting of
Class 1 waste in our communitues.
Coshocton City Council
October 15, 2018

Kristopher Weiss
Ohio Environmental Protection Agency
50 West Town Street, Suite 700,
Columbus, OH 43215

Mr. Weiss and interested parties,
We, the members of Coshocton City Council, wish to submit this letter of concern on behalf of our city and its citizens. As officials elected by the residents of Coshocton to represent them, we feel it is our duty and responsibility to act on their behalf when requested to do so. This letter embodies that obligation.
Regarding the issue of the proposed conversion of Buckeye Brine injection well(s) from Class 2 to Class 1, this council does not support moving forward with that request. It is widely known that an aquifer nearby Buckeye Brine’s current location is Coshocton’s primary water source. If that aquifer became contaminated and our water source compromised, this would certainly be catastrophic to our community. In addition, there are several oil and gas wells and citizen owned water wells in that area that could be affected. We do understand that Buckeye Brine meets and adheres to regulations established by the governing regulatory bodies within our state. However, the issue of what happens underground after the wastewater is introduced to the earth remains largely unknown.
Therefore, we seek to preserve the health and safety of our citizens by respectfully requesting that the Ohio EPA hear the collective voices of the citizens of Coshocton and deny the requested proposal to convert the above-mentioned injection well(s) to Class 1.
Thank You,

Rev. Cliff Biggers
Council President

Mike Gross
1st Ward Councilman

Chad Johnson
2nd Ward Councilman

Jackie Salmans
3rd Ward Councilwoman

Brad Fuller
4th Ward Councilman

Tom Grier
Council at Large

Glenn Mishler
Council at Large

Roger Moore
Council at Large

Jeff Poland
Coshocton County Board of Health
Buckeye Brine
Ohio EPA
Attention:  Jess Stottsberry

I have included several reasons that the Buckeye Brine wells should not be allowed to go from class 2 to class 1:
I toured the Buckeye Brine facility on 6.5.2018 and was given a 90 minute tour by Monty Shell. I later got to meet David Durakovich. I was shown two pipes exiting the high pressure pumps and their secondary concrete containment and 10 feet later were encased in concrete. Unfortunately during that 10 feet, the pipe did not have secondary containment for a pipe carrying fracking waste water at greater than 1000 psi. After discussing this with both Monty and David, they promised me they would “look into it”. I was only there for 90 minutes yet the Buckeye Brine safety team, their design engineer, their supervisors, and even ODNR did not find this obvious flaw. That concerned me, so I examined their website, ODNR requirements, and submissions to the EPA for any additional problems.

ODNR deficiencies were easy to find. ODNR requires owners of oil and gas wells drilled between 2000 and 4000 feet to own a minimum of 20 acres and if greater than 4000 feet they need to own 40 acres. This means that landowners “own” the ground under which the well is located. Buckeye Brine is located on less than 18 acres and the wells are over 7000 feet deep and were allowed to drill very close to their property lines. How much of the already 10,000,000 barrels of wastewater is located just under Buckeye Brine property? Even section VI of Adams # 3 on page 1 states ”ODNR could not conclusively conclude which formation(s) are receiving the injectate or percent of total volume”. The wells were drilled with ODNR oversight, but deficiencies were allowed to exist. Attachment C page 15 Cementing Program of Adam #1 states: ”During the cementing of the long string casing, circulation was lost to the injection interval and returns were not observed at the surface”. Wells which are not built correctly, should immediately be corrected or plugged.

“No core samples or undisturbed formation water samples were collected during the drilling and completion of the well” page 30 #843505. Since we have no core samples then 3745-34-14 of the administrative code for a class 1 permit to drill application has NOT been satisfied.

Part F (2) (b) Laboratory testing results:
(i)     Cores for permeability;
(ii)    Cores for compatibility;
(iii)   Cores for porosity;
(iv)    Analysis of formation water; and
(v)     Descriptive core analysis and sieve analysis

Part (C) Proposed formation testing program to obtain analysis of the chemical, physical and radiological characteristics of the receiving formation including, but not limited to:
     (4)  Physical and chemical characteristics of the injection matrix;
     (5)  Compatibility of the injected fluids with the formation fluids;
     (6)  Corrosiveness; and
     (7) Other applicable information.

Baseline data now is skewed due to 10,000,000 barrels of fracking waste water has entered and diluted what was already there. If sulfides or heavy metal salts or other corrosive products were already present what is this going to do to steel pipe over a period of time? Will the pipe be eroded? We already know we have lost a distal portion of the pipe in one Adams well. Why?
For the EPA to accept ODNR oversight for a class 1 well is a major overstep. It would be like me building a structure with inadequate structural deficiencies and later calling in the state to approve it as structurally sound commercial building. They would not even consider it and neither should the EPA.

Physics show that fluids move from areas of high pressure to areas of low pressure. Old Faithful in Yellowstone National Park is an example. We also know that water always seeks the path of least resistance. On the ODNR website under Industrial-Waste Disposal Wells in Ohio under Geological Considerations in Class 1 Injection under Structural Setting it states:

“In the subsurface environment, the natural flow of fluids, in general, follows the most direct path from areas of higher pressures to areas of lower pressures. Because the amount of overlying rock is the primary pressure-loading factor, this concept translates into flow from deeper environments to shallower environments along the path of least resistance.    …      If the site is located at the top of an arch or anticlinal feature, lateral flow away from the injection site would be impeded by the natural flow (toward the injection well) of native formation fluids. This latter situation is undesirable because the injectate will then be inclined to migrate vertically should vertical routes exist.”

There are 27 oil and gas wells within the Area of Review. Document #843505 table V.C. lists wells > 5200 feet. The 5200 feet is based on the analysis by the geologist representing Buckeye Brine that indicates that the shallowest top of a potential receiving zone for the Adams wells would be expected to be 5500 feet below ground level. Wells drilled to depths greater than 5200 feet would potentially place the bottom of their borehole within 300 feet of the injection interval. None of those oil or gas wells were drilled with class 1 safety measures. When oil and gas are removed, it lowers the pressure in the surrounding area and native water or possibly fracking waste water can take their place. This is not the only vertical transmission possibility.

The Coshocton Fault Zone, the Cambridge Arch, or the Coshocton Fracture Zone are documented but not well understood. If you believe the geologist paid by Buckeye Brine, it is not a normal fault, it is not a reverse fault, it is not a strike-slip fault. It is a growth fault like that found in the Gulf of Mexico Dome Province. A growth fault is a fault which initiates and evolves at the margins of continental plates. We have now injected 10,000,000 barrels of flowback water coming from shale gas wells which is loaded with high concentrations of slickwater chemicals. These chemicals that lubricate and reduce the viscosity of the water so it will not generate friction are being injected into a growth fault. We better hope it is NOT a growth fault.
A compression fracture is more plausible. A compression fracture occurs when one side is forced against another side and compression with micro fissures occur. This would explain the 112 foot discrepancy between the two wells which are only 921 feet apart. This would explain not only the widening of the layers but also the Airport Dome. Compression fractures do not produce a large fault but do produce micro fissures. The wire logs demonstrated micro fissures but no large cracks. It also showed the anomaly with folding and flexures present. In section II Adams # 3 page 81 it states:

“The most notable feature is on the west end of the line where there appears a down-to-the-west flexure     ….     Cannot be determined if the fabric is due to the structure (folding and / or faulting)    …   ”.  As was stated above, water can go vertical if it encounters a structure blocking the flow of water.
Shale gas wells are cleaned with acids. The fracking water also has proprietary ingredients which they are not required to disclose.  Unfortunately acids and CO2 products are problems which have not been adequately explored. Have you ever taken vinegar (acetic acid) and baking soda (NaHCO3) and mixed them together? The baking soda disappears in dramatic fashion. Concrete is made of cement which is limestone (CaCO3), clay, and aggregate. The dolomite cap is composed of CaMgCO3. If an acid is allowed to enter the reservoir it could cause erosion to the concrete around the steel pipe or to the cap rock. Solution caves are caves from limestone erosion with slowly moving water. What if that water is entering at > 1000 psi? It would be like taking salt water and a pressure washer to a concrete driveway 24 hours a day and possibly 365 days a year. The EPA website states that sequestering should last 10,000 years.   
The Ohio EPA has a fact sheet on Requirements for Class 1 Injection Wells and Class 1 Hazardous Waste Wells. It states that “the injection zone must have no economic value.” Section VII Adams #3 page 15 states that there “was a gas show from the Rose Run.” On page 16, “Gas shows were more or less sustained for the next 250 feet.” If the injection wells are allowed to remain then no one will be able to access this important resource. The liability to drill in this area would be too great.
In the administrative Code for a Class 1 Permit Application 3745-34-13 (D) area of Review (3) (f) Springs, they responded with the answer “None identified within the AOR”. He must live in flat country and not in hill country. Of course we have springs within the AOR, we live in hill country. Did he not examine the area? If he lied on this part of his answer, are his other answers suspect?
Under #843505 on page 13, they stated “Buckeye Brine, as a legal entity, currently has not ever owned or operated any Class 1 wells.” This is technically correct but on page 15 they were to list all class 1 injection wells that the owner or operator has operated and is operating. They responded “N/A”. The owner of Buckeye Brine has and does operate class 1 wells. This is a blatant lie. This is a major transgression and should be dealt with a “Denied”.
Since the EPA is responsible for the safety of our drinking water, since the above examples demonstrate the lack of continuity from ODNR to EPA jurisdiction, since the city of Coshocton has their aquifer within one mile of the wells, since vertical penetration of the area of review with 26 gas and oil wells is already present, since it is located over a known anomaly, since the wells are not presently in compliance even with ODNR and should have been plugged, this permit should be denied.
The Coshocton Board of Health opposes Buckeye Brine converting two of the existing class 2 injection wells to class 1 injection waste wells. The board voted unanimously to oppose this. As the Coshocton County Board of Health, we are required to act in the best interests of Coshocton County residents.  I am only one member of this board. I have included our letter.
The best place for a class 1 well is far away from a municipal water source, no current wells close to the class 1 injection well, not located near a ground fault or anomaly, and residents who understand the risk associated with concentrating a large number of trucks transporting this waste.
Thank you for your consideration.

                                                                   Jeff A. Poland
                                                                   Coshocton County Board of Health
Tim Kettler
Professional Waste Water Manager
re: Buckeye Brine Class 1 permit applications.
0ctober 24, 2018
Submitted by: Timothy Kettler
                          29674 Township Road 30
                          Warsaw, Ohio 43844

Due to the brevity of the question and answer session and the time limits imposed on testimony during the public hearing held in Coshocton, Oh on October 18. 2018 I am entering the following comments into the public record. The comments reflect existing deficiencies and potential deficiencies in the permit application and draft permit. The permitting process demands serious consideration of submitted comments before the Director grants a permit.

re: pg. 11 Appendix I, item 10(b) of the Buckeye Brine application: “the facility will only receive waste by truck transport”. As reflected in well inspection reports dated 12/2015 through 11/2017 ODNR personnel observed the rail car site and/or offloading for delivery to the Buckeye Brine facility. Whether or not freight manifests reflect the destination as the Buckeye Brine facility, observation would indicate that rail transportation has been previously used. A remaining question/answer is omitted from the application; “What constitutes rail transportation?”. The draft permit contains no provisions for handling/monitoring of Class 1 wastes at a rail siding.  As is typical in both truck and rail transportation once the freight is loaded for the destination listed in the shipping manifest it becomes the property of the receiver named. If trucks are loaded at the rail siding and hauled across the township and driven into the driveway is that what defines truck transportation? Since no rail siding exists at the well site itself will available rail siding within the township, or anywhere else for that matter be used in any way to off-load Class 1 wastewater for disposal at the Buckeye Brine facility? Will Class 2 wastewater continue to be transported by rail for disposal at the Buckeye Brine site?

re: pg. 11 Appendix I, item 10(e) of the application “other than the two wells Buckeye is seeking to permit there are no solid waste disposal units at the site.” This answer infers that the two wells seeking permits are considered solid waste facilities. What authority has been granted Buckeye Brine to accept, handle, pre-treat and/or dispose of solid waste under Ohio law regulating solid waste?

re: pg. 12 Appendix II, item 1 through pg. 14 item 1(c) of the application: The applicant fails to document qualifications to operate a Class 1 well. Assertion is made that the cumulative experience of operating the Class 2 wells at the site satisfies the experience requirements associated with Class 1 wells. Assuming the actual experience put forth is deemed an appropriate modifier it is undercut by the monitoring records reflecting the maintained annular pressure was continually in non-compliance. The assumed experience of the applicant to operate Class 1 wells is further elaborated on page 155 section III.C.2 of the application. This experience, if considered a qualifier, should accurately reflect the numerous and serious problems associated with Class 1 well operation at Gibraltar Chemical in Winona, Texas while under the supervision of the management team as listed in this section. The application experience qualification is deficient. Hard copy records chronicling the Gibraltar Chemical events were submitted by Phyllis Glazer as part of her testimony during the public hearing of October 18, 2018. It is also part of this submission as an attachment (A). re: Part I, E6 of the draft permit: “Proper Operation and Maintenance” Serious deficiencies in the operation of Adams #1 and Adams #3 exist due to the lack of properly trained and certified operators. Injection well operation in Ohio is overseen by personnel who complete no formal training, are not certified and are not required to complete continuing education. Given that water and wastewater operators under authority of the Ohio EPA must be certified through a rigorous training, testing and certification program that requires extensive understanding of their job duties it is not unreasonable or safe to expect that injection well operators would not be subject to the same standards. Operator competence is a measure with which the public can expect well operations will be conducted in a manner that will protect the environment and public safety.  

re: pg. 17 Appendix II item 4(f) and pg. 143.III.A.9 of the application: The application does not address the potential of migration into any other wells that are considered to be constructed properly in the AOR or any wells outside the AOR where they may interact with the injected fluids in a longer distance migration and cone of influence than the application assumes.  The formations in the injection interval as described in Volume I Section II of the application show a potential for proportionately larger volumes of wastewater than assumed by the application to be directed into proportionately smaller sections of the injection interval. As shown on pg. 171 of the application, in table VI.C.01 the Gull River, Lower Chazy, Wells Creek, Rose Run, Copper Ridge and Copper Ridge B formations in the injection interval will receive no injected wastewater. Some injectability may be attainable in the Lower Copper Ridge, Conasauga, and Rome formations.
Both table VI.C.01 on pg. 171 and table VI.C.01 on pg. 173 of the application record the assumed porosity (no core samples or formation water samples were collected nor are available within the AOR, table I.A item14(F)(2)(b)-14(F)(2)(b)(v), pg. 143 III.A.), thickness and projected reservoir volume of these formations. This data conflicts with data provided on pg. 95-96 Section II.B.6.c of the application.  The descriptions provided in the narrative indicate that the cumulative averages for reservoir volume capacity would be much lower in all formations and segments except the vugular dolomite of the Rome formation. The porosity differential and characteristics and previous operational observations between the vugular dolomite, defined as a Paleo-Karst formation of collapsed limestone caves, and the low-porosity overlaying formations as well as the low porosity underlaying basal formations is substantial, so much so under the widely accepted rule that water seeks it’s easiest path and under pressure even more so, the overlaying and underlaying formations would in effect become confining zones for the vugular dolomite between them. Although the Paleo-Karst formation is thin and interspersed the porosity differential is great enough that higher than assumed volumes noted in Section II.B.6.c will likely be directed into the vugular dolomite. Under these conditions it would be expected that the migration distance will increase as will the cone of influence. Another factor that may have an impact on this Paleo-Karst formation is the results of any acidizing that may have been previously performed on the wells. As a disproportionate amount of wastewater would be directed to the vugular dolomite so would the volumes of acid applied, possibly elevating the porosity and reducing the disparity where the vugular dolomite is interspersed within the sucrosic dolomite. This random/selective loading of the vugular dolomite would be of concern for not just potential interaction with any oil or gas well within the AOR but also those outside the AOR. Indications are that the use of well drilling core data from as far away as 10 miles from the facility should be considered to be the distance of potential migration. Otherwise, harvesting data from a location that far from the well site, if not relevant to the well site would be useless.

re: Attachment E of the application: Corrective action applicable to those wells within the AOR, or outside the AOR, that are considered properly constructed or plugged is omitted.

re:  Appendix II, item 6(f) of the application: “Generalized maps and cross-sections illustrating…carbonate formations that are known to contain or that may contain caverns”. Figure II.B.7.02 through Figure II.B.7.05 of the application are not compliant. Figure II.A.3.02 and Figure II.A.3.03 of the draft permit are not compliant. Appendix II, item 6(f) of the application is deficient.

re: Appendix II 5(a) of the application: “the direction of water movement where known.” Potentiometric groundwater mapping of Coshocton County has not been conducted and assumptions made to determine groundwater flow and direction are based on surface contours that have been refined but not defined, and doubt remains as to how closely groundwater flow will mimic surface topography. Discussion in II.B.3 of the draft permit indicates that much is unknown about groundwater flow. Lack of data and/or accurate date leaves much uncertainty over mapping the USDW to correctly locate the groundwater monitoring well. Simply put, the one groundwater monitoring well is insufficient especially considering the inability to accurately define groundwater flow in the direction of the monitoring well.

re: Section II.B.8 of the draft permit: The discussion of the Coshocton Fault Zone considers an association with deep seated fracture systems but is not well understood. Injection induced seismicity would seem an outright risk.

re: Section II.B.8 of the draft permit: The discussion of the Cambridge Arch: Also in proximity (3 miles east) to the well site, stresses on the structural discontinuity may be elevated by the approximately 17 other injection wells drilled near the structure between Coshocton and Marietta.  

Note: In oral testimony submitted on October 18, 2018 on these two features I mistakenly referred to the “so-called Cambridge Arch” The discussion in Section II.B.8 refers to the “so called Coshocton Fault” in an historical context. I did not correctly quote the reference and incorrectly misinterpreted the intent of the statement in the permit.  

re: Attachment C, III.A.2 of the draft permit: Adams #1 Total Depth. “The obstruction is most likely fill” The applicant describes an obstruction 239 ft. above the total depth as fill. Previous injection and acidizing may have deteriorated the bore hole possibly indicating long-term collapse of the bore hole and eventually affecting the integrity of the long-string casing, packer and injection tubing.

re: Attachment C, III.A.2 of the draft permit: Adams #3 Total Depth. “The obstruction is most likely fill” The applicant describes an obstruction 70 ft. above the total depth as fill. Previous injection and acidizing may have deteriorated the bore hole possibly indicating long-term collapse of the bore hole and eventually affecting the integrity of the long-string casing, packer and injection tubing.

In summary there exists a great potential threat to the safety of the community and the environment from the additional permitting for Adams #1 and Adams #3 wells. The structural integrity of both wells, siting of the facility near faults and municipal water well fields, qualifications of the operators, poorly defined groundwater flow and inadequate number of monitoring wells, and potential interaction between the injected wastewaters and the existing oil and gas wells within the AOR that are drilled into the injection interval are all cause for great concern within our community. All oral testimony and written comments submitted on these draft permits must be given serious consideration and weight prior to the Director’s approval.

Barb Teti
Retired Teacher
My name is Barbara Teti. I am an established resident of Coshocton, having lived in the county for over 38 years.   My home is a farm of 72+acres located in the SW part of the county.  My children were raised and educated in Coshocton before going on to college and careers,  

Although now retired, I have worked for the betterment of the Coshocton community, first, in the field of social services as the Executive Director of the Big Brothers/Big Sisters program, and for over 25 years, as a teacher in the Coshocton City Schools.

 I now volunteer my time and talent, and I donate to a number of community causes.  I attend community events, pay my taxes on time and support local businesses.  I want you to know, as you may have been misled by a recent Letter to the Editor of the Cosh. Tribune, that I DO NOT make a living or a pastime out of protesting waste facilities.  Instead,  I am and have been invested in the progress and future of this county for decades, BUT I feel my personal, financial, and community investments are now under attack.

Often as a teacher I would assure my students that the most important truth they must accept is that things change.  
Minute by minute, hour by hour, day by day we all face change.
Some change can be good, with positive results that might extend our lives or make improvements to the quality of our environment. 

Conversely, change can be destructive, causing harm to the tangible and intangible aspects of life.  
It is my belief that the proposed change in the reclassification of the injection wells on SR 16/36 is an example of pending destructive, harmful change.

I know there are people within the Coshocton community who embrace the change brought on by this business.  They believe the jobs that are offered by the company and the increase of traffic that will haul the waste to be injected are examples of enhancements to the common good of this community.   I do not share their thoughts.

I have grave concerns regarding the reclassification of these wells and the corporation and ownership which operates the business.  I am concerned this    may threaten our community's health and safety and its economic viability.  I am also concerned that reclassification may impact our local and state environment.

The business, Buckeye Brine, like it or not, is tainted by the documented history of egregious violations which surround its owner and the harm done to the people of Texas, most specifically the residents of Winona.  I find frightening the similarity between Mr. Mobley's related businesses; Gibraltar Chemical in Winona and Buckeye Brine in Coshocton as they have developed.   I find the actions of the two corporate entities to be deceptive and threatening.  Add to this my concern with the laissez faire manner in which Ohio's EPA has accepted and facilitated the inclusion of this owner/operator's business model.

I find it difficult to understand the accommodations and inconsistencies within the ODNR and the O-EPA permitting processes.  There seems to be a rote lack of adherence to rules and policies except for what is expected of or applied to the public.  All of this I find to be unfair.

I have concerns about the structural features of the wells to be reclassified.  It is my understanding that both the Adams 1 & 3 wells have structural problems.   As a  result, I find it difficult to accept that these wells could or would be allowed by the OH-EPA to accept the type of waste proposed, and I am fearful that such permitting will end in the Coshocton facility becoming a site for hazardous waste disposal.

I have concerns for the health and safety of the community should a spill occur.  Within the Area of Review there are 3 schools, a shopping center and other independent businesses, many established neighborhoods, recreational and tourist attractions, agricultural operations, an airport, a National Guard facility, and a water treatment plant.  What safety procedures and warnings has the O-EPA mandated for the injection well business to mitigate the harm which will be perpetrated on the community should a spill or leak occur?  The company can spend all day wrapping itself up in glorious rhetoric that relates a 100% record of safety, but when deficient wells are taken offline or listed as shut-in, that impacts the validity of their statistical claims.
The confluence of the Walhonding, Tuscarawas and Muskingum Rivers locates Coshocton at the head of the largest watershed district in the state.  What environmental impact plan is in place should a spill occur in Coshocton and spread to the communities downriver?  What warning system and set of protocols are in place to assure the safety of those who might be harmed?

It is my understanding that the injection facility carries minimal liability coverage. Do you know the level of this coverage, and at what level does the O-EPA consider adequate to recover the harm to person and property should a spill or violation occur?   As the permitting agency, what level of liability does O-EPA have should the wells and facility which it has sanctioned into operation become a hazard to the health and property of the community's residents?  

Another concern that I have is the ground below us.  My understanding is that the geology of the area renders the proposed injection reclassification problematic.  Three miles from the injection facility is a known fault which the mix of injected fluid may impact.  What absolute guarantees of safety will be offered to the citizenry, and in what manners will these guarantees be backed up?  
I am concerned by the personal financial impact this reclassification may impose upon me and the other residents of Ohio.  Will my tax dollars be spent recovering the environmental assault this business may cause?  I DO NOT want to see my tax dollars diverted from already under-funded worthwhile projects and operations which enhance the quality of life or promote the common good.... neither of which I believe defines the operations of this business.  

I am concerned by the reclassification of these wells as this establishes a precedent from which there may be no retraction.  Additionally, I believe it creates a lack of balance between the parties.  Buckeye Brine as a business is interested in making a profit.  It has limited liability as a corporate entity.  Conversely, the people within Coshocton County and the Muskingum Watershed District will be forced by your decision to risk without limitation their homes and property, health and safety, jobs and businesses; all of what they hold dear.  

It is my hope that you will weigh all of my concerns and those related at this hearing and act for the betterment of the common good and not the singular interest of one party.  I think the factual history of the applicant, an acknowledgement of the impact of the number of "unknowns" related to this application,  the impact that may occur as a result of a spill or accident,  the fact that the O-EPA to date has offered no guarantees of success or safety should guide your decision as an environmental protection agency.


Barbara Teti