UPDATES
CECA Planning Meeting
"Looking Forward"
Thursday, November 8th
6:00 PM
Coshocton Career Center
23640 Airport Rd.
Coshocton

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Website Updates
Comment Page Added
Readers are sending us  the comments they have submitted  to the OEPA  about the Class 1 Permit.
Click on the red button to the right to see the comments.
Library Page Updated

Important new articles, reports, and videos have been added to the LIBRARY PAGE.
Click on the red button to visit the page and see the new information. 
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ON THE RECORD
CECA sent the following letter to 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:
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Director Butler's response to our request:
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NEW DEADLINE FOR COMMENTS
We now have until November 26th to submit comments to the OEPA. They are also considering holding a new new Information Meeting. Please take advantage of this. Submit comments and urge them to grant us a new meeting. It is the only opportunity we will have to register our opposition. Numbers do matter. Let those who are supposed to represent your best interests know that you are not happy with policies they have put in place that force you to risk your family's health, your home and property values, the water in your well and the future of children. Send your message to:

Ohio EPA, Div. of Drinking and Groundwaters
Attn: UIC Unit Supervisor
PO Box 1049
Columbus, Oh. 43216-1049

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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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

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.

Substances 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.

CLASS 1 WELLS
CAN and DO FAIL
Click on the Red Text Above to Read
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
 Contaminated Water
Wells?

We have heard disturbing reports of water well problems that have developed around the injection wells on Airport Road. We hope this is not the case but we must find out if this is true before the OEPA meeting.
 
   
If you have information about a drinking water source that  may have evidence of oils, chemicals or odors that did not appear before 2012 please contact us by clicking this button -
Must See Videos
Reports on the record of the Class 1 Well operations in Winona, Texas by Gibraltar Chemical Resources, a company
run during the 1990's by the owners and operators of Buckeye Brine.
The Fight for
Local  Community Control
in OHIO
Environmentalists raise alarms over proposed billion dollar Asian petrochemical complex along the Ohio River. Politicians involved will reap huge profits.
OTHER  NEWS

*Update (Scroll Down to Terry's Letter) 
CECA challenges unregulated oil and  wastewater use for road treatment in testimony before
Ohio House of Representatives.


Testimony to The Ohio House of Representatives     
January 30, 2018


Testimony by:
Tim Kettler
Warsaw, Ohio 43844

Testimony given before:
Ohio House Resource Committee
Rep. Al Landis Chairman
Rep. Christine Hagan Vice Chair
Rep. Michael O’Brien Ranking Member
Committee Persons: Mr. Antani, Mr. Boccieri, Ms. Cyde, Mr. Edwards,
Mr. Leland, Mr. Schaffer, Mr. Stein, Mr. Thompson, Mr. Wiggam

Subject:
Ohio House Bill 393

Good Afternoon Mr. Chairman, thank you for this opportunity to enter testimony on sub HB 393 concerning the impact of this legislation to allow the sale of oil and gas wastewater as a marketable commodity.

My name is Tim Kettler and I am testifying as a board member of Coshocton Environmental and Community Awareness Inc. (CECA), a non-profit Coshocton County environmental advocacy and education organization.  I am a resident of Monroe Township, Coshocton County where I have been a property owner for the past 32 years.  I am an Ohio EPA Certified Wastewater Operator and have been in business in the wastewater handling and treatment field for 32 years serving residential, commercial and industrial clients. Because of my professional and community activities, I have the daily opportunity to speak with residents and homeowners, friends and family from around the state about environmental issues.  The most common feedback I hear is that folks generally don’t know anything about the issue of “brine” spreading nor do they understand the impacts of this undesirable disposal practice and the potential and immediate health and safety risks.

The geology and soil structure of Coshocton County is like that of many rural Ohio counties in that it is problematic for domestic wastewater treatment systems and much of our approach to recognizing and resolving these treatment and disposal issues also apply to the surface disposal of oil and gas wastewater. As you may know Household Sewage Treatment Systems (HSTS) are recognized as Class V injection wells,and present a real challenge as these injection wells generally discharge partially treated and treated effluent above the deepest most Underground Source of Drinking Water (USDW) and in fact, above the uppermost Underground Source of Drinking Water. We must control these discharges to ensure that the treated and partially treated effluents do not short circuit the treatment process and dangerously find their way into our fresh water resources many of which are springs, ponds, artesian wells and old, shallow, hand-dug and drilled water wells. Coshocton County is subject to seasonally high ground water tables as well as permeable rock and shallow bed rock with major fissures, all of which are limiting conditions when considering surface disposal of any wastewater including oil and gas wastewater.  Many of the county’s rural residents, including my family utilize surface water for their water supply. We also live on a dirt road, built on exposed bed rock with major fissures and the township does not spread oil and gas wastewater along our property frontage at our request. The Ohio Department of Health (ODH), The Ohio Environmental Protection Agency (OEPA) and Local Health Departments (LHD) have instituted stringent regulations to deal with HSTS treatment and disposal problems on a case by case basis. The casual and indiscriminate application of oil and gas wastewater from potentially unknown sources, made up of unknown constituents, with little control over migration and applied directly to problematic surfaces flies in the face of the progress already made and the need for future protections to safeguard fresh water resources from any type of surface contamination. This contamination becomes more likely as surface applications are encouraged to increase, driven by a marketed commodity designed to create and increase a potential profit to the dumpers.

Concern about surface application of oil and gas wastewater is not directed solely to applications on problematic surfaces. As with deep well injection, municipal wastewater treatment, industrial pre-treatment or future treatment and disposal methods a major concern is migration from containment. Oil and gas wastewater whether used to mitigate dust or as a de-icer has the potential for vast and wide spread migration and unavoidably or incidentally become a threat to fresh water resources. When it is spread on a dirt surface it will ultimately be carried away as run-off, dust in the air or on vehicles. When spread on hard surfaces direct run-off potential increases. Spread over and along water courses, culverts, storm ditches, catch basins and sewers run-off is concentrated in systems designed to collect and direct the surface flows to the Waters of the State of Ohio. We find this an unreasonable and unjustified risk just to generate a profit for a specific group of corporations and is contrary to the suggestion that oil and gas wastewater used to mitigate dust or as a de-icer is a beneficial use. This legislation may result in nothing more than an attempt to convert what it is a known wastewater disposal cost to a windfall disposal profit at the expense of the public health and safety.

The use of oil and gas wastewater as a deicer in portable restrooms is a direct conduit for Naturally Occurring Radioactive Material (NORM) and Technically Enhanced Naturally Occurring Radioactive Material (TENORM) to be discharged to the Waters of the State of Ohio. Additional unknown constituents of oil and gas wastewater are also of great concern for conventional wastewater treatment processes. This legislation is sure to alarm any operator of a treatment plant who must know what constituents or pollutants make up the wastewater profile. Introducing influents of unknown origin and content into municipal, private or semi-public wastewater treatment facilities is not feasible nor responsible. Ohio EPA Operators of Record assume responsibility to control what wastewater comes into and out of the treatment facilities they oversee. Allowing unknown wastewater constituents to enter the treatment process not only threaten the receiving waters used but also threaten the professional licenses and reputations of those municipalities, businesses and Certified Operators who are willingly or unwillingly forced to accept contaminated wastewater into those treatment facilities under their control.

 In closing we ask the chairman and committee to consider the work done by the Ohio Department of Health, the Ohio Environmental Protection Agency and Local Health Departments to improve the safety and standards of Class V injection wells. These same concerns apply to oil and gas wastewater, generally disposed of in Class II injection wells and not suited for surface disposal under less oversight than Class V injection wells. It is not acceptable to allow practices that will increase the reality that Ohio is willing to become the dumping ground for the oil and gas industry. When homeowners take the responsibility to ensure that their Class V injection wells, their septic systems, do not endanger the public health and safety it is reasonable to expect that the generators of oil and gas wastewater do the same. It is up to this committee to protect Ohioans, but this bill will not contribute to that effort.

On behalf of Coshocton Environmental and Community Awareness Inc.,

  Timothy Kettler

UPDATE
A Message from
Attorney Terry Lodge


Friends, I want to tell you the very disturbing news of a new corporate-driven scheme to poison you, your family and your pets with radioactive waste.
    Aqua Salina is a product you can purchase by the gallon at Lowe’s or a hardware store right now. It’s also sold in huge quantities to department of transportation regional garages for use as a de-icer. It’s bottled in the Cleveland area by an owner of several oil and gas wells.  Aqua Salina has been sold for several years.
    It is called "brine," marketed as “ancient sea water;” and it is bottled radioactive waste. Depending on the concentrations of radioactive toxins in this "ancient sea water," it is called "NORM" (naturally-occurring radioactive material) or "TENORM" (technologically-enhanced naturally-occurring radioactive material). Here's a page from the website of the seller and distributor of this poisonous stuff:
    Here's how I know Aqua Salina is radioactive waste.  Scientists at the Ohio Department of Natural Resources - an agency generally viewed as owned by Ohio's oil and gas industry, analyzed Aqua Salina in 2017.  I’ve attached their report. Samples of Aqua Salina bought right off the shelf ranged as high as 500 times background radiation in Radium-226 and -228.  The average of the samples tested by ODNR were 300 times federal drinking water limits for Radium-226.
     Why is any of this significant?  Well, those of you who know me know that I’ve litigated against fracking for years. And I've learned that oil and gas drilling, using fracking pulls enormous amounts of radium to the surface, mostly in liquid form.  Radium-226 is a major radioisotope in the liquid and solid drilling wastes brought to surface to get natural gas and oil. Ra-226 is especially dangerous because unlike a lot of radioactive isotopes, it dissolves readily in water. If you drink water containing Ra-226, the body incorrectly recognizes it is as dissolved calcium and deposits it in bone tissue. Ra-226 is an “alpha particle emitter,” meaning that an atom of it is energetic enough that it will electrically bombard surrounding cell tissues and cause cell mutations.  Cell mutations often become cancers, also called blastomas.  Ra-226 causes bone cancer. In fact, radon gas - radium in gas form - is the second leading cause of lung cancer in the U.S.  We all know the first leading cause of lung cancer is smoking, but few people know that the tobacco plant concentrates Ra-226 as it takes up nutrients from the soil.  Smoking involves inhalation of Radium-226.

    On May 15, 2018, a committee in the Ohio House of Representatives voted House Bill 393 out of committee for a floor vote. HB 393 would prohibit any regulation whatsoever of the sales of “ancient seawater” aka cancer causing brine if the seller makes a one-time paperwork filing showing that this radioactive waste has been approved for use elsewhere. And it has, so the approval by ODNR is a given.

    But this legislation not only would legalize sales of radioactive waste as a commodity; it also would give bulletproof protection to the drilling industry against liability. They already sell fracking waste by the hundreds of thousands, even millions of gallons, for use as a dust control device on hot country roads in the summer, and as a de-icer on highways in the winter.  And for those who don’t understand that they are purchasing radioactive waste, it is used, right now, on residential driveways, patios and sidewalks as a deicer.
  
     And when people finally wake up to the fact that we're drowning in radioactive deicer and dust control, they will have a huge roadblock to filing suit, courtesy of the Ohio General Assembly. Unless we do something now.

    This is not just a matter of diluting a little radium in a lot of water. It will take roughly 11,000 years, give or take a decade or so, for all the Ra-226 in Aqua Salina being applied today to roads and sidewalks and driveways to disintegrate down to background levels.  And it only takes a few atoms of radium in your drinking water - which, incidentally, cannot for the most part successfully be filtered to remove radium - for the body to deposit Ra-226 in your bone tissues and commence the process of destroying you and your family. So lots and lots of Ra-226 will be washing through Ohio's surface and subsurface water for the next 11,000 years or so, plenty of time to kill and destroy the health and lives of millions.

    The oil and gas industry is eager for HB 393 to pass because fracking creates an enormous amount of liquid and solid waste, most of it radioactive.  And it costs a lot to get rid of it. The frackers don’t like to pay to get rid of radioactive waste if they can get away with poisoning you and your family for free. Indeed, some of them profit, now, from selling it.
    When your city or township or state highway garage buys this stuff for ice control, the recommended spray is 30 to 50 or so gallons per lane/mile. Understand? If you’re driving on a six-lane Ohio Turnpike, there are 180 to 300 gallons sprayed on the roadway per mile.  This radioactive waste then unavoidably washes into streams, wetlands, rivers and lakes. And we all live downstream.
    Attached are the ODNR laboratory results, the Sierra Club testimony against the use of this radioactive waste, and House Bill 393. Don’t be put off by the length of HB 393. Only the underlined part, beginning on page 4/11 of the pdf, is the new change.  You can see for yourself that once a good housekeeping seal of approval is filed with ODNR, the agency is flatly prohibited from regulating this radioactive waste any furthe
r.
    Our political system, once again, contrives to poison and kill us to make a buck - actually, millions of them.

     And while I thank and respect the Sierra Club for its opposition to HB 393, we don’t need “better regulation” or “ODH regulation” of this poisonous radwaste. It should be flatly and completely illegal to sell it as a commodity at all, with serious criminal penalties. We will not consent to a little poisoning. A little poisoning is more than enough to kill.
   
  Whether we work together to stop this - by initiating local and state laws to neutralize the General Assembly and voting the political thieves, brigands and corporate poisoners out of office and by sitting down and sitting in at the Statehouse - whether any of that happens or not is up to you and me.
   
Please feel free to pass this message along. How much longer will we let corporations and their hack politicians poison us for profit?


      Terry