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

Sat Apr 25 16:15:48 CDT 2020

Thank YOU Daryl!!

Joan

On Sat, Apr 25, 2020 at 5:00 PM Kelcey Jacobs via Green <green at fuusm.org>
wrote:

> 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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