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

Sat Apr 25 20:40:59 CDT 2020

Darryl,

Your analysis of the risks involved in your letter to USACE does a great
job of encompassing the risks and is very succinct.  Thank you for doing
this.

Vic

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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