Why Triple Divide Caretakers Oppose the Headwaters Water Reclamation Facility
We recognize that recycling wastewater from fracking is a good thing, since it reduces the hundreds of millions of gallons of fresh water natural gas drilling companies now remove from Pennsylvania’s waterways.
However, we believe that recycling water to be reused for drilling operations is better for everyone when it’s done on-site. This option would eliminate the many hazards associated with transporting fracking waste over public highways and endangering both our communities and environment. Some may argue that centralized water treatment plants provide better oversight of the toxic sludge that results from recycling. If so, such plants should be located in industrial zones.
The Ulysses facility will be in the watershed of Ludington Run, a High Quality stream and tributary of the Genesee River. This area is currently zoned for agricultural use, and we repeat the need for industrial facilities to be located within industrial use zones. Ludington Run is also a part of Potter County’s Triple Divide, which Trout Unlimited designated as the Number ONE location in Pennsylvania to protect from hydraulic fracturing activities. Although this facility is a “zero discharge” plant, a failure of equipment or operations, as in the form of trucking accidents, will have devastating effects beyond the headwaters.
It is only through a political exemption legislated in the Natural Resources Recovery Act of 2005 that oil and gas drilling wastes are not classified as hazardous waste. The term “Residual Waste” is misleading, because flowback water and brine from drilling operations contain many toxic ingredients, including known carcinogens: such as benzene, toluene, ethylbenzene, and xylene.
DEP has recently announced that they are launching a new study to assess the levels of Naturally Occurring Radioactive Material (NORM) in Marcellus wastes. Waste from the Marcellus Shale can contain unusually high levels of NORM in the form of radium-226 and radium-228. We urge the Ulysses Township Supervisors not to approve this facility based on the grounds that fracking waste, as well as the technology being used to treat it, is still being studied.
The citizens of Ulysses Township are not the only Potter County residents who will be impacted by this facility. There are numerous pathways of exposure. All of us who live by the highways used by trucks transporting this waste are affected. Accidents will happen. They already have. Although officials of the company have said that there will likely be about 70 trucks a day coming through the facility, the permit allows up to 700 trucks per day, and we know the company also said it will be around 200 trucks a day… so how many is it? We urge the Ulysses Township Supervisors to require that all trucks potentially using this facility, regardless of size, only use designated routes that public and emergency responders can prepare for.
There has not been much drilling activity in Potter County, so we wonder why this facility is being planned for this area? Does the company plan to bring in waste from other counties or states? If so, where? What is the extent of travel? And then, where will the up to 10,000 pounds of toxic sludge this facility will produce every two days be taken? We urge the Ulysses Township Supervisors to reconsider the location of this facility because there are safer, more appropriate places for RevH2O to build it.
Marcellus wells bring Impact Fee money to the counties and municipalities where drilling occurs, but trucks hauling waste do not. They do, however, bring toxins into our environment and put stress on our roads and our bridges. Where will our municipalities get the money to repair the roads barraged by wastewater and sludge trucks?
In addition, we have learned that the planned facility will be located within the part of Potter County that both DEP and the EPA have designated an Environmental Justice Zone according to the 2010 census data. This means that any waste facilities proposed for such an area are required to include the public in the planning and permitting processes. This has not happened. We urge the Ulysses Township Supervisors to request that DEP re-evaluate the permits for this facility to include public participation.
Finally, we have urged the public to attend this meeting because we believe that officials at all levels of government should be held accountable as they make decisions that affect citizens and communities. We urge the supervisors to vote “No” on this facility until further questions and concerns are solicited from the public and addressed.