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

Sat Apr 25 15:59:29 CDT 2020

Agreed!

On Sat, Apr 25, 2020 at 4:55 PM Joe Baker via Green <green at fuusm.org> wrote:

> Thank you, Darryl! Your letter is extremely well written!
>
> On Sat, Apr 25, 2020 at 4:01 PM Darryl Ting via Green <green at fuusm.org>
> wrote:
>
>> 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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