[Green] LTTE

[gbanz42 at suddenlink.net]

Excellent letter, Rebecca. 


---- Rebecca Phillips via Green <green at fuusm.org> wrote: 
> I have submitted the attached letter to the Parkersburg and Marietta papers.
> 
> Rebecca
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> "If you have a garden and a library, you have everything you need."-- Cicero
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> ________________________________
> From: Green <green-bounces at fuusm.org> on behalf of Rebecca Phillips via Green <green at fuusm.org>
> Sent: Sunday, April 26, 2020 4:44 PM
> To: Green Sanctuary List for Environment Issues <green at fuusm.org>
> Cc: Rebecca Phillips <bennphil at hotmail.com>
> Subject: Re: [Green] Daryl's letter
> 
> Wow! Great letter, Daryl.
> 
> "If you have a garden and a library, you have everything you need."-- Cicero
> 
> ________________________________
> From: Green <green-bounces at fuusm.org> on behalf of Darryl Ting via Green <green at fuusm.org>
> Sent: Saturday, April 25, 2020 4:01 PM
> To: Green Sanctuary List for Environment Issues <green at fuusm.org>
> Cc: Darryl Ting <darrting1 at gmail.com>
> Subject: [Green] Fwd: Re LRH-2020-293-OHR
> 
> Copy of my letter to USACE.
> Darryl
> 
> 
> ---------- Forwarded message ---------
> From: Darryl Ting <darrting1 at gmail.com<mailto: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<mailto:kayla.n.adkins at usace.army.mil>>
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> United States Army Corps of Engineers, Huntington District
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> 502 Eighth Street
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> Huntington, West Virginia 25701-2070
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> Dear Ms. Adkins,
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> 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.
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> 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.
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> 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.
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> 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?
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> 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 …
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> 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.
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> 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.
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> 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.
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> 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.
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> 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.
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> 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.
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> Those are my objections to granting this permit.
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> 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.
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> 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).
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> Thank you for listening,
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> Darryl Ting
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> 108 Sylvan Way
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> Marietta, OH 45750
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> darrting1 at gmail.com<mailto:darrting1 at gmail.com>
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--
George Banziger
202 Lawton Road
Marietta, OH 45750-1111
740-434-5685
cell: 740-434-3354