ON THE RECORD
CECA sent the following letter to
Former OEPA Director Craig Butler:

                                                                                                                                       October 17, 2018


                                                                                                     Nick Teti
                                                                                                     Coshocton Environmental and
                                                                                                     Community Awareness
                                                                                                     18998 CR 3
                                                                                                      Warsaw, OH 43844

Director Craig Butler
Ohio EPA - Directors Office
P.O. Box 1049
Columbus, OH 43216-1049

Dear Mr. Butler,

I am writing to you in regard to the meeting and comment period scheduled by the OEPA in Coshocton on October 18th. We are in a unique situation because wells are being converted, not drilled. The conversion is from Class 2 to Class 1. These wells were licensed and operated as Class 2 wells but supposedly built to Class 1 standards. Because of this the citizens of Coshocton were denied the information meeting we would normally have received on Class 1 operations before drilling began.

Now, eight days after the only scheduled information meeting, the OEPA will close the comment period and go forward with the permit to operate. That gives us just over a week to process all the information that will be presented at the meeting on this technical 194 page application. Our community has had little opportunity to learn about or understand class 1 operations other than what we have been told by Buckeye Brine. We have had no information from our regulatory agencies into the establishment of this Class 1 infrastructure that will have the potential to bring hazardous waste into our county. Eight days is not enough time to for us to review and process the information the OEPA will present at their meeting on October 18th.

We are requesting a 30 day extension from the current October 26th closing date for comments. In the interest of fairness to the residents of Coshocton County we would like to be able to submit comments and questions until close of business on November 26th, 2018. I am enclosing signatures from 1906 area residents who are in support of this action.

            

                              Yours truly,

                              Nick Teti

                              Coshocton Environmental and Community Awareness

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On October 18th CECA met with State Senator Jay Hottinger at the OEPA Meeting and asked that he send a letter to Craig Butler in support of our request to extend our comment period 30 days. This is his letter:
====================
Former OEPA Director Butler's
response to our request:
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Click the red text on the right to see the a copy of the permit the OEPA has drafted that will let Buckeye Brine inject Class 1 Waste in Coshocton County.
Buckey Brine permit.pdf Buckey Brine permit.pdf
Size : 27172.336 Kb
Type : pdf
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What is Class 1 Waste?

It's complicated.

Class 1 waste is divided into two categories; Hazardous and Non-Hazardous. Hazardous waste is dangerous even in storage and must be carefully monitored. It is also much more likely to cause mortality in the event of accidents or contact. Although the categories are different, the wells that they inject into are identical in construction whether they are permitted for Hazardous or Non-Hazardous waste. The only difference is the permit. A Class 1 Non-Hazardous well can obtain a permit to become a Class1 Hazardous well.  

Certain very toxic chemicals are identified and listed as Hazardous and must go into a Class 1 well that is permitted for hazardous waste. The EPA sets standards for maximum contaminant levels for chemicals in drinking water which are usually expressed in ppm, (parts per million).  1 ppm  =  (1 / 1,000,000), is about 1 drop in 40 gallons of water. Some extremely deadly chemicals like Dioxin are listed at 30 ppq, (30 parts per quadrillion. (30 / 1,000,000,000,000,000.) These are Hazardous wastes based on TOXICITY.

A substance must also be injected into a Class 1 Hazardous well if it is a low level RADIOACTIVE waste. (High level radioactive waste is disposed of in special facilities.)

Any BIOLOGICAL waste like blood, surgical drainage or body fluids is Hazardous waste.

What about waste that doesn’t fall into these three categories? Any other waste that is not listed as Hazardous, is not Radioactive, and not Biological must be classified into Hazardous or Non-Hazardous waste. A set of criteria has been established that is used to analyze the waste to determine its classification. A waste specialist uses the following broad guidelines to make the determination:

CONCENTRATION – Is a there chemical or substance present in the waste in a strong intense state that would require injection into a Hazardous well or is it in a weaker less active condition allowing disposal in a Non-Hazardous well?

COMBINATION – Can a chemical in the waste be mixed with other substances that are injected without causing chemical reactions? Is it compounded or mixed with other substances that make it unstable?

VOLATILITY – Can a chemical or substance in the waste combust, explode, or react to create a gas?

CORROSIVENESS – Can a chemical or substance in the waste reduce or oxidize other components of the waste or the well infrastructure to cause reactions or damage?

Chemicals that are not a listed Hazardous toxin, not Radioactive, and not Biological can be injected into either a Class1 Hazardous well or a Class 1 Non-Hazardous well depending on how it is analyzed and classified using the above criteria.

It seems that Class 1 Non-Hazardous waste can contain more than just curds and whey, and soap bubbles, and pickle juice.

CECA has approached the Coshocton County Commissioners and informed them of their ability to pursue the appeals process as agents of our local government should the wells be permitted. They have standing to appeal any decision by the OEPA before the ERAC tribunal, (Environmental Review Appeals Commission.) They have decided not to file an appeal. If the wells are permitted the clock begins ticking. An appeal to ERAC must be filed and completed within 30 days of the permit being granted.  They have received the concerns brought to them by  local residents and forwarded them to the EPA. They have not taken a position on the injection wells.
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The Coshocton City Council took a position on the injection well issue and wrote the following letter: 
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
CECA Resolution and Signature Page
CLICK Red Text BELOW TO VIEW AND DOWNLOAD
CECA resolution For VOLUNTEERS (1 pg).pdf CECA resolution For VOLUNTEERS (1 pg).pdf
Size : 374.045 Kb
Type : pdf
CLASS 1 WELLS
CAN and DO FAIL
Click on the Red Text Above to Read
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