Last day to Comment: Comment: Docket ID: USCG-2013-0915Agency: Coast Guard (USCG)Parent Agency: Department of Homeland Security (DHS) Summary: Carriage of Conditionally Permitted Shale Gas Extraction Waste Water in Bulk Dear U.S Coast Guard and Department of Transportation: I express my opposition to allow barging of fracking flow-back fluids/waste on U.S. rivers. As a former deckhand on a towboat, I worked the Allegheny/Monongahela/Ohio Rivers. Im well aware of the inherent hazards of river barge transport. Barges leak or strike obstructions that penetrate the hulls. During high-water, barges tear free from moorings and head, uncontrolled, downriver until striking a landing or bridge - often rupturing or sink. I worked the Mediterranean as helmsman. My captain once said to me: “Never take the water for granted” - good advice. We can’t take the inherent risks of barging toxic “slick water for granted. Steel barges full of drilling flow-back fluid contain toxics by design and brought back after use, e.g, benzene, ethylbenzene toluene, xylene (BETX) and radioactive material. This is a clear hazard to workers handling such cargo. Steel barges will also become radioactive after prolonged contact with the radioactive cargo. This is a matter of risk and our tolerance for risk. It is an unacceptable risk to our public drinking water source, fisheries, and ecological systems that sustain us and, worker safety. On shore storage and handling facilities pose similar threats due to shore-based spills and high water events; they are situated in historical flood plains. The Oil & Gas industry, in their recklessly pursuit of profit, have experienced significant problems managing dangerous waste streams they generate. They disposed waste streams, via waste water treatment plants, into the river. They lied to the public, telling it was safe. The practice ended when it was conclusively proved they were responsible for high levels of bromides in our rivers. Two commercial liquid waste treatment facilities have illegally allowed contamination of streams in PA; adjacent streams now have radioactive waste present. Theyve trucked significant amounts of toxic fluids to injection wells in Ohio. Result? Earthquakes. Now, they want to transport this dangerous cargo on OUR rivers to injection wells in Ohio. They come forward with new waste disposal plans. I get serious, expensive problems and hazards to my health, welfare and safety. The Oil & Gas Industry has lied about the safety of their disposal schemes; they’ve no credibility. They’re not so much interested in the public’s safety as they are in their own profits. Theyve vigorously oppose reasonable regulation or law to protect the public’s health, safety, estate and welfare. They’ve unduly influence government decisions with massive infusions of money into the political process, purchasing support of elected leadership who are deliberately indifferent to the risks and hostile to public concern. That pollution is unacceptable as well. When liquid waste is stored on a well site, storage vessels are marked “Hazardous Waste.” When it’s transferred to a tanker truck it magically becomes “Residual Waste.” Does a transfer hose from tank, to truck magically cure the toxic nature of this material? No. The “magic” is their financial influence to have regulators create some a legal fiction to save them money. If citizens hadn’t voiced concerns, they would still be dumping a toxic stew directly into the rivers. The Oil & Gas industrys historical conduct in this regard is reprehensible. Therefore, I write in strong opposition to granting the ability to ship toxic flow-back fluids via river barge and, demand that you deny them the ability to do so. I have no interest bearing consequences and costs of this unacceptable risk. No matter how it may be justified, the law of Unintended Consequence tells us you can’t assure the health, safety and welfare of citizens. That is your prime mission. I fully expect you to fulfill it. Sincerely, Douglas A. Shields, former President of Pittsburgh City Council (2006-2010) regulations.gov/#!docketDetail;D=USCG-2013-0915
Posted on: Fri, 29 Nov 2013 19:40:33 +0000
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