We WON a bargedock comment extension! — please send additional comments (even if you sent some in the first round) by Aug. 24. They can be sent electronically.

Yea!! The U.S. Army Corps of Engineers quietly extended the comment period on the GreenHunter bargedock proposal to Aug. 24. We won!! It was our 340 comments that did it. THANKS TO ALL WHO WROTE!…Now we ask you, please, to send additional comments with more detail and more specificity, even if you already sent in comments. MODEL COMMENTS HERE; abbreviated version HERE. COMMENTS CAN BE SUBMITTED ELECTRONICALLY.

The Corps’ guidance is specific — the more specific and detailed the comments, the more they will be considered in the decision to authorize an Environmental Impact Statement, which we need for further public input and TIME so this disaster doesn’t get permitted.

We’ve posted some lengthy model comments HERE. Guidance material is included. Feel free to e-mail acfanohio AT gmail.com for a Word doc version to make it easier to copy and paste. Use as much or as little or use as a model for your own.

Feel free to use the abbreviated version below (pdf HERE).

Be sure to include LRH-2013-848-OHR in your subject line. Comments due by Aug. 24.

U.S. Army Corps of Engineers


Public Notice No. LRH-2013-848-OHR

502 Eighth Street, Huntington, West Virginia 25701-2070

Via email to Teresa Spagna, teresa.d.spagna@usace.army.mil

RE: Comments on Sect. 10 Permit Application #LRH-2013-848-OHR (GreenHunter Meigs County Docking Facility)

Dear Ms. Spagna:

I hereby submit my comments in strong and informed opposition to U.S. Army Corps of Engineers issuance of a permit to GreenHunter Water, LLC for construction and operation of a barge unloading and pipeline facility in Meigs County, Ohio, to deliver “bulk liquids” generated by hydraulic fracturing (“fracking”) operations to upland facilities.

I request a public hearing and an Environmental Impact Statement (EIS) on this matter, owing to its significant, likely or even certain and largely irremediable impacts, especially on public water supplies, water conservation, and air and water quality as well as on public safety and the needs and welfare of the people throughout the eleven-state region who would all be affected by impacts of the project. The unloading and storage of vast quantities of highly hazardous, highly flammable, explosive, toxic radioactive chemicals[1] on the Ohio River are a matter of extreme public interest. In addition to chemicals used in the drilling and fracking process, mercury and other heavy metals, high salinity (chloride at up to 196,000 mg/l), radioactivity (for example, EPA reports liquid Marcellus Shale waste to contain radium 226 at concentrations of up to 16,030 pCi/l; the MCl is 5 pCi/L), and hydrocarbons are at significant levels in frackwaste.[2].

More than 3 million people rely on drinking water supplies downstream of this project. Vast volumes of unidentified and unidentifiable mixtures of highly toxic, radioactive material would likely cause untold and irremediable catastrophe from barge accidents, explosions during off-loading, leaks and spills, which are increasingly common. Spills, leaks, explosions and fires are occurring with increasing frequency at frack chemical and frackwaste transfer sites. They are therefore likely occurrences if this project were to be permitted. Chemical mixtures in the recent week-long Monroe County frackpad fire included chemicals for which testing protocols are not even developed. How can downstream water suppliers know whether these chemicals are in their systems if there are no testing protocols yet available? How can firefighters know how to handle emergencies? The C-8, Elk River, Toledo, and Opossum Creek 70,000 fishkill disasters are all ongoing disasters that would be dwarfed by the scale of disaster that could occur at this facility.

The project has no benefits to the region. Its reasonably foreseeable detriments are of great public consequence and must be considered in a public hearing and an EIS.

I look forward to notice from you of further opportunities for public comment and public hearings in communities that would be affected by this proposal.




[1] See for example U.S. House of Representatives Committee on Energy and Commerce, Minority Staff, Chemicals Used in Hydraulic Fracturing (April 2011), identifying 750 chemicals used in hydraulic fracturing, including 29 chemicals that are known carcinogens, regulated under the Safe Drinking Water Act, or listed as Hazardous Air Pollutants; US General Accountability Office, Information on the Quantity, Quality, and Management of Water Produced During Oil and Gas Production, GAO-12-56, January 2012; PADEP “Permitting Strategy for High Total Dissolved Solids (TDS) Wastewater Discharges,” April 11, 2009; Warner, N.R. et al, , Impacts of Shale Gas Wastewater Disposal on Water Quality in Western Pennsylvania?, Environ. Sci. Technol., 2013(47):11849–11857 (pubs.acs.org/doi/abs/10.1021/es402165b)

[2] New York State Department of Environmental Conservation, Revised Draft Supplemental Generic Environmental Impact Statement on the Oil, Gas, and Solution Mining Regulatory Program, Well Permit Issuance for Horizontal Drilling and High-Volume Hydraulic Fracturing to Develop the Marcellus Shale and other Low-Permeability Gas Reservoirs, September 2011, Table 5.9; Appendix 13; Marvin Resnikoff, Ph.D., Radioactive Waste Management Associates, “Comments on Marcellus Shale Development”, October 2011; USEPA letter from Shawn M. Garvin, Regional Administrator to The Honorable Michael Krancer, Acting Secretary, PADEP, 3.7.11; US General Accountability Office,Information on the Quantity, Quality, and Management of Water Produced During Oil and Gas Production, GAO-12-56, January 2012.

pdf here: abbreviated version and of longer model comments here.

Multi-state coalition press release published by Akron Beacon Journal at ohio.com. 8-11-14

Athens City Council and Mayor oppose dock proposal: Athens Messenger 7-22-14


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