[Green] Fwd: Re LRH-2020-293-OHR

[Darryl Ting]

Copy of my letter to USACE.
Darryl


---------- Forwarded message ---------
From: Darryl Ting <darrting1 at gmail.com>
Date: Sat, Apr 25, 2020 at 3:48 PM
Subject: Re LRH-2020-293-OHR
To: <kayla.n.adkins at usace.army.mil>






United States Army Corps of Engineers, Huntington District

502 Eighth Street

Huntington, West Virginia 25701-2070



Dear Ms. Adkins,



My name is Darryl Ting, and I live in Marietta, Ohio.  I am writing
regarding Public Notice:  LRH-2020-293-OHR.  I have 5 significant
objections to the granting of this permit.



*First*, the Public Notice did not appear in the local Marietta, Ohio
newspaper.  For an issue of this importance, no notification was made to
the citizens most affected by the proposed facilities.  I found out about
it only after a watchdog group brought it to my attention.  But most of the
people of Marietta are still unaware of this Public Notice and the
approaching closing of the public comment period.



*Second*, the description of the material to be off-loaded is false.  It
says “traditional well waste”, but let’s not kid ourselves, it is fracking
waste.  Fracking is where the oil and gas boom is, fracking waste disposal
is a huge problem, and that is where the money is to be made.  The permit
application says “traditional well waste” to make it sound less hazardous,
but this barge unloading facility is really about fracking waste.  Barges
are the cheapest, high volume, long distance transportation mode.  And it
is obvious that the high volumes will be fracking waste.



The difference is significant.  Fracking waste contains as many as 157
chemicals known to be toxic, such as benzene, arsenic, lead, cadmium,
chlorine, mercury, and formaldehyde, in addition to radioactive materials
and high salt brine.  By a legal loophole, fracking waste is not legally
hazardous.  But by every health and pollution standard it clearly is.
Consider this common sense test.  Spray it on a football or soccer field.
Then ask yourself, would it be dangerous for your kids’ health to play
there?



*Third*, from the information given, there is no evidence that a process
safety review has been made.  Such reviews are necessary for all facilities
handling hazardous materials to assure that their design and operation will
be safe.  They are especially critical where existing facilities are to be
re-purposed.  I am a retired chemical engineer, and some specific questions
I have that such a review should address are …



What is the match between barge capacity to be unloaded and the receiving
shore tank capacity?  The barge size shown on the drawing implies a barge
capacity of 30,000 barrels or 1.26 million gallons.  Shore tank working
capacity would typically be more than that, so a whole barge could be
unloaded even if the shore tank were not empty.  If the shore tank capacity
is less than that, there is greater risk of overflowing the shore tank.



What is the control and prevention instrumentation?  Instrumentation is
often used for control of process operations.  But what robustness has been
designed in to prevent system failure if there is individual component
failure?  If the shore tank capacity is less than barge capacity, that
means the control systems will be challenged on a regular basis to prevent
overflows … and must correspondingly be more robust.



What is the shore storage tank containment capacity in the event of tank
overflow or rupture?  Besides instrument failure, there is also risk of
operator error and material failure (especially with used and potentially
corroded tanks).  Containment capacity is the ultimate backstop to
widespread contamination.  In particular, the natural drainage pattern for
the area of this tankage is toward the Ohio River.  So adequate containment
capacity is necessary.



Truck loading operations will be significant.  A barge load will require
about 250 standard 5000 gallon tanker trucks.  So again questions about the
control and prevention instrumentation and design robustness.  And with
such high usage, the probability of spills increases to the point where
design for spill containment and recovery/disposal becomes necessary.



*Fourth*, the truck traffic associated with this facility’s operation will
be quite high ...  250 tanker loads going out and 250 empties coming in per
barge.  The safety impact of that additional traffic (there is already
Shelly & Sands truck traffic) at the entry/exit to OH route 7 is something
I cannot assess.  But I object to the granting of a permit until the
appropriate body can make such an assessment.  And beyond the impact on OH
route 7 traffic, there is the considerable additional truck traffic through
Marietta city itself.  Both the safety impact and the nuisance impact of an
additional 500 trucks per barge through the city needs to be assessed
before a permit is granted.



*Fifth*, the impact of this facility will reach far beyond Marietta.  This
facility is an enabler of much larger health and environmental impacts.
Those tanker trucks are headed for waste injection wells … more fault
destabilization, earthquakes and earthquake damage, contaminated water
aquifers, and health hazards.  I object to these facilities because they
are a part of a system of transportation and disposal of hazardous fracking
waste that will impact the health and well-being of my neighbors in Ohio
and West Virginia.



Those are my objections to granting this permit.



I am also very concerned that, because of the way the Public Notice was
made, my fellow Mariettans are not aware of this proposed facility and thus
have no opportunity to comment.  Fracking waste disposal is a big and
contentious issue.  This facility’s permit application should be given the
light and attention it deserves, not processed in the under-the-radar way
it has been so far.



So I have the following recommendation … re-issue the Public Notice in the
Marietta Times newspaper (that’s the one the people in Marietta read) and
extend the public comment period for this permit application.  Better yet,
hold a public meeting in Marietta to get peoples comments and extend the
comment period until such a meeting can be held (current covid-19
restrictions).



Thank you for listening,



Darryl Ting

108 Sylvan Way

Marietta, OH 45750

darrting1 at gmail.com
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