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OEPA Draft of Proposed Class 1 Permit
in Coshocton County for Buckeye Brine
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Link To Ohio Revised Code:
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OEPA Notice of Deficiency 10-3-17
OEPA Notice of Deficiency 5-11-18
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Reports and Articles
Pro Publica Investigative Reports
Pro Publica
Investigative Reports

Click the Red Button to open a series of reports on injection wells by the journalists at Pro Publica.

Recommended:
1. Injection wells:
    The poison beneath us.

2. A whiff of phenol spells
     trouble
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The Center for Health
Environment and Justice
A report by CHEJ

Deep Well Injection:
An Explosive Issue
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A Toxic Tour Through Underground Ohio

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VIDEOS
WELL CASING FAILURE 
Dr. Anthony Ingraffea
Dr. Anthony Ingraffea is a Professor Emeritus from Cornell University where he trained engineers for over 30 years. He has developed and contributed to cutting edge oil and gas development technologies and is an  expert in rock fracture mechanics. 

Both of the Buckeye Brine injection wells that the OEPA is preparing to grant Class 1 permits have serious problems with their casing. One is missing 900 ft. of its cement safety seal around the metal casing that carries waste down to the injection zone and the other has a metal casing that has separated. In this video Dr. Ingraffea talks about the problem of well casing failures.
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RED BUTTON TO
SEE THE VIDEO.

Dr. Anthony Ingraffea

On Aging Leaking Wells

Within the 2 mile radius surrounding Buckeye Brine's wells we know of 27 oil and gas wells that are drilled deep enough to provide a potential conduit to the surface for the waste they will be injecting. Some of these wells are no longer producing and have been abandoned. Dr. Ingraffea addresses the problem of these old wells in this video.
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SEE THE VIDEO.
List of Concerns Updated
As we learn more about the issue our concerns can change. Please update your list of concerns to reflect the latest thinking and contact us if you have heard or seen something about the proposed well conversions that you are concerned about.

CECA has concerns over proposed changes to the waste disposal operations involving the three waste injection wells on Airport Road:

·       Buckeye Brine is applying to the Ohio EPA to convert two Class 2 Waste Wells to Class1 Waste Wells. Converting injection wells to dispose of a different class of waste has never been permitted before. It means that a new class of chemicals is going to be mixed into a site that has already accepted over a half-billion gallons of Class 2 chemical waste.

·       If the permit is allowed the new Class 1 wells will be injecting into the same site with an existing active Class 2 well. This will set up a continual mixing of different classes of chemical waste. 

·       The operators of Buckeye Brine were formerly officers and owners of Gibraltar Chemical in Winona, Texas. According to a letter from Winona resident, Phyllis Glasser, the company had a number of toxic gas releases from its facilities due to mixing chemical wastes that reacted and spread corrosive clouds across the community damaging the health of many residents. The gas releases continued until government regulators intervened.  Her account of their history and behavior is corroborated by the article Chemical Warrior, published on September 10, 1998 by Ann Zimmerman in the Dallas Observer. 

·       There are 27 oil and gas wells in the Area of Review that are deep enough to be affected by migration of injected fluids.(The Area of Review is a circular 2 miles radius area around the well designated in the permit application that that must meet OEPA site regulations for an injection well.)     

·       The Coshocton City well fields are shallow water wells that are within the Area of Review, and supply the residents of Coshocton with drinking water.

·       The waste industry gained a foothold in Ohio through the ill-considered policy of allowing our state to be the major disposal site for fracking and gas extraction waste in Utica and Marcellus shale region. Neighboring states generated and exported billions of gallons of fracking waste to Ohio but prohibited the import and disposal of waste in their own communities. There are currently 238 injection wells in Ohio, 7 of which are in Coshocton County and the well operators are looking for new waste streams now that the bloom is off the rose in the gas fields. If the OEPA begins permitting them to operate Class1 wells Ohio could be accepting larger volumes and a greater variety of waste from a wide array of waste generators from anywhere in the nation. 

·       If the permit is allowed it will set a precedent that could be national in scope. Buckeye Brine is making modifications to a Class 2 well while claiming it was built to Class 1 standards.

·       If the permit is allowed Buckeye Brine will be able to use its status as a Class 1 well to apply to the OEPA for a No Migration Petition. This would allow the injection of yet another class of waste – Class 1 Hazardous; (Hazardous = proximity danger, dangerous even in storage, increased danger of mortality, poison on contact.)

·       Flowback water is the liquid that comes out of a shale gas well right after the well has been fracked. It is loaded with high concentrations of slickwater chemicals. These are chemicals that lubricate and reduce the viscosity of the water so that it will not generate friction and lose the force needed to fracture the shale as it is driven through miles of underground pipe. It is engineered to migrate and is loaded with toxic compounds. Because of a loophole in the 2005 Energy Act  this dangerous waste is permitted to be injected into both Class 2 and Class 1 wells and can be mixed with all of the other chemicals that will be injected under our aquifers.

Useful Information
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CONTACT
Governor John Kasich
CONTACT
OEPA Chief  Craig W. Butler
OFFICE
Craig W. Butler
Ohio EPA - Director’s Office
P.O. Box 1049
Columbus, Ohio 43216-1049
PHONE
(614) 644-2782.

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.

Should you test your Water Well?