I always thought that it was considered haz mat by what was in it or potentially in it, no requirement to test the flowback or cuttings to determine the toxicity before disposing...
-----Original Message-----
From: Frank Young fyoung@mountain.net Sent: Jul 12, 2011 9:19 PM To: ec@osenergy.org Cc: wyro@appalight.com, DSGJr@aol.com, jbc329@earthlink.net Subject: Re: [EC] Fwd: Tomblin's Executive Order
Beth,
By what legal determination are these drilling cuttings "hazardous materials"? Somehow I doubt that they have been legally determined to be hazardous materials.
I think I'd rather see them taken to a legal landfill than disposed of on site by the usual "fold the liner into the hole and bury" method.
Frank
----- Original Message ----- From: "Beth Little" blittle@citynet.net To: "'James Kotcon'" jkotcon@wvu.edu; ec@osenergy.org Cc: wyro@appalight.com; DSGJr@aol.com; jbc329@earthlink.net Sent: Tuesday, July 12, 2011 8:29 PM Subject: Re: [EC] Fwd: Tomblin's Executive Order
Furthermore, Leslee and I are trying to track down the facts behind hearing that the Greenbrier landfill is taking cuttings from wells in Greenbrier Co. Leslee said she heard they have a permit. If it's a permit from the DEP, then they are allowing hazardous materials in regular landfills.
-----Original Message----- From: ec-bounces@osenergy.org [mailto:ec-bounces@osenergy.org] On Behalf Of James Kotcon Sent: Tuesday, July 12, 2011 5:12 PM To: ec@osenergy.org Cc: wyro@appalight.com; DSGJr@aol.com; jbc329@earthlink.net Subject: [EC] Fwd: Tomblin's Executive Order
Thank you Jonathon. Not sure how you got this, but it makes interesting reading.
At first glance this seems like a major step forward, but the cynic in me read it again.
Nothing in here requires permits for or limits air emissions.
Nothing requires a permit for water withdrawals. This order give the
operator the authority to submit a plan, and as long as the plan meets the methods approved by DEP, DEP can not deny or reject a plan submitted by the operator.
- Nothing prohibits on-site burial of pit wastes. It says pits can be
"managed on site in a manner otherwise approved by the Secretary of the WVDEP", and DEP currently approves on-site burial?
So I am wondering if it is time to blast this proposal as too little, too late, and a prescription for continued outrage among citizens and uncertainty for industry. It is a classic example of Tomblin's continuing failure to provide leadership.
JBK
Jonathan Rosenbaum freesource@cheat.org 7/12/2011 4:10 PM >>>
Attached is Tomblin's executive order concerning gas drilling.
-Jonathan
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