Created by Lucy Bryan Malenke – September 24, 2023

1.     What is the source of the wastewater that is being sent to Coshocton County?

Since the train derailment in East Palestine on Feb. 3, 2023, there has been an ongoing cleanup effort. Early in the cleanup, contaminated water had to be removed from creeks and storm drains. Most of the wastewater that is currently being produced is collected from drainage ditches and waterways after stormwater has come into contact with contaminated soil, according to information provided to the U.S. Environmental Protection Agency (EPA) by Norfolk Southern Railroad Corporation (the company responsible for the derailment and the cleanup). Norfolk Southern has also stated that a rain event of less than 1 inch of precipitation can generate more than 500,000 gallons of wastewater that must be stored and disposed of. Wastewater may also come from water used to decontaminate trucks leaving the site and groundwater from wells, springs, and seeps that Norfolk Southern is monitoring. As of August, the East Palestine cleanup had generated more than 28 million gallons of hazardous wastewater, according to the Ohio Emergency Management Agency (OEMA).

2.     What was Norfolk Southern doing with the wastewater before it began treating it and sending it to the Buckeye Brine facility in Coshocton County?

Before the current disposal process, Norfolk Southern was sending untreated wastewater, which was classified as a hazardous waste, to deep injection well facilities that accept hazardous wastes. It sent 3,696,140 gallons to the Vickery Environmental facility in Vickery, Ohio and 26,034,837 gallons to Texas Molecular in Deer Park Texas. On Aug. 27, the EPA announced its plan to allow Norfolk Southern to treat wastewater on site, removing vinyl chloride and other contaminants so that it could be reclassified as non-hazardous waste (in EPA-speak, this is called a “contained-in determination”). This would allow it to then be disposed of at Buckeye Brine’s Class I deep injection wells. According to a press release from the Coshocton County Commissioners, Susie Mobley Patterson of Buckeye Brine informed the commissioners that this plan had been in the works for more than six months before she shared it with them on August 29, 2023.

3.     Who is in charge of treating the wastewater before it comes to Coshocton?

The EPA ordered Norfolk Southern to conduct all cleanup operations associated with the East Palestine train derailment. Norfolk Southern hired the environmental engineering consultant Arcadis to design the wastewater treatment plan. Contractors hired by Norfolk Southern built and are operating the temporary water treatment plant at the site of the derailment.

4.     What does the treatment process for the wastewater involve?

In its request to have the wastewater reclassified to nonhazardous waste, Norfolk Southern described the treatment process to the EPA this way: “The wastewater treatment system is a robust multi-component system that includes equipment for removal of particulates, free-phase product or product sheen, and volatile organic compounds from the influent wastewater stream. Air stripping is the primary vinyl chloride treatment process with secondary/backup treatment provided by liquid-phase carbon. The wastewater treatment system has a design operating capacity of 100 gallons per minute.” A much more detailed description is available in the Wastewater Treatment System Operation and Maintenance Plan on the Legal and Other Documents Section of the EPA’s East Palestine website.

5.     What tests are performed to ensure that the treated wastewater is no longer hazardous, and who is conducting them?

Norfolk Southern, under the oversight of the EPA, is responsible for collecting wastewater samples and sending them to an independent laboratory for testing. The process for collecting samples involves:
  • During the first day of processing for each batch, a sample of treated wastewater is collected every 4 hours as it comes out of the treatment system. Each of these samples are analyzed for total vinyl chloride.
  • One or two “composite” samples collected at the end of the day from the tanks holding the treated wastewater—either from the port and or from the top of the tank (or both). These samples are analyzed not only for vinyl chloride but also for volatile organic compounds and metals.
The company conducting the testing is Eurofins Scientific (Cleveland location). They analyze the composite samples for each batch for:
  • Metals (e.g., arsenic, barium, zinc)
  • Volatile organic compounds (e.g., vinyl chloride, benzene, acetone, tuolene)
  • Semi-volatile organic compounds
  • Organochlorine pesticides
  • Polychlorinated Biphenyls (PCBs)
  • Herbicides (TCLP)
  • Mercury

6.     How much treated wastewater has been sent to the Buckeye Brine facility in Coshocton so far?

As of September 24, five batches have been reclassified by the EPA as nonhazardous wastewater and approved for transport to Buckeye Brine in Coshocton for disposal via deep injection well. The first batch began arriving on September 8.


7.     What did the laboratory tests reveal about the wastewater that has been sent to Coshocton?

The laboratory tests are available to the public in the reports pertaining to the requests for contained-in determination. These tests largely convey good news:
  • In all of the batches, every sample had levels of vinyl chloride that were either non-detectable (with method detection limit of 0.001 mg/L) or below the EPA’s maximum contaminant limit for drinking water for vinyl chloride.
  • In the results for the composite samples, concentrations of the eight metals deemed extremely toxic by the Resource Recovery and Conservation Act were below toxicity criteria.
That said, the samples did contain trace amounts of elements or chemicals that have the potential to be harmful in larger quantities. These include:
  • Arsenic
  • Barium
  • Chromium
  • Copper
  • Lead
  • Nickel
  • Zinc
  • Oil and grease
In the samples, most concentrations of tested chemicals were below or close to what is considered safe for drinking water.

8.     Is there anything important for which the laboratory failed to test?

The EPA and Norfolk Southern’s handing of dioxin testing has come under criticism many times since the cleanup efforts began. Dioxins are highly toxic pollutants that can cause cancer. When vinyl chloride is burned (as happened at the site of the derailment) 2,3,7,8-tetrachlorodibenzo-p-dioxin and many other dioxin-like compounds are created.
Recently, the Huffington Post published an investigation that showed how the EPA failed to consult the appropriate experts and track the spread of dioxins early in the days after the disaster. Later, when soil testing for dioxins began, experts said that the methods used to test for dioxin were flawed. One scientist who conducted independent testing of dioxins at the East Palestine site alleged that his results came in much higher than those reported by the EPA.
On the waste profile sheet Norfolk Southern submitted to Buckeye Brine with each batch is a this question "Does this waste contain regulated concentrations of 2,3,7,8-Tetrachlorodibenzodioxin (2,3,7,8-TCCD), or another dioxin as defined in 40 CFR 261.31?" For every batch, Norfolk Southern answers “No.” However, the only dioxin I could find in the analytical summary of lab results was dibenzofuran. No testing for 2,3,7,8-TCCD appeared in those results, so it is unclear as of present how that determination was made.

9.     Isn’t it a conflict of interest that Norfolk Southern is responsible for testing the treated wastewater?

The short answer? Yes. The longer answer: It is a common practice to put the companies responsible for environmental disasters in charge of cleanup efforts. This often includes monitoring.
Sonya Lunder, the Sierra Club’s Senior Toxics Advisor for the Clean Water, Toxic Chemicals, and Climate Resilience Program told me that she thought the testing was most likely accurate and that it was highly unlikely that there was any conspiracy on the part of Norfolk Southern to interfere with wastewater samples.

10.            How much more treated wastewater does Norfolk Southern plan to send to Buckeye Brine in Coshocton?

According to Norfolk Southern’s correspondence with the EPA in September, “The wastewater treatment water recovery operations will continue for 6 to 12 months. Based on the current rates of generation, another 30 to 60 million gallons of U043 listed hazardous wastewater could be generated during this time.” The current plan is to send that wastewater to Buckeye Brine’s facility in Coshocton.

11.            Where can I find more information?

In addition to monitoring the news for investigations about the cleanup efforts, you can find in depth information in these locations:
This portal allows you to access documents submitted to and created by the Ohio EPA. While the interface can be a bit intimidating, I suggest selecting a date range of interest and using the search terms Buckeye Brine, Norfolk Southern, and/or Coshocton. This is how I found the reports with data on each batch of wastewater.
  • The Legal Documents page of the EPA’s East Palestine website
Here, you can find all sorts of in-depth information, including sampling and monitoring plans for the wastewater.
  • The Operational Updates page for the EPA’s East Palestine website
The EPA publishes operational updates and a newsletter about the East Palestine Cleanup every other week.