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FROM:
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Fred Tgytor, £s«, CtunseiHaumBnvtrtnmtmtalSbsspunxs&EmttB
Bans* Box 202217Hvrisbmrt.PA 17129-2217
(717) 797-3677(717) 772-2993 or 783-2322
REMARKS: • Urgent • For your review Q Reply ASAP Q Please Comment
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Subj: No SubjectDate: 98-03-04 13:52:23 ESTFrom: SMelch2245To: SandyHCSmi
I agree that there is danger that must be connected concerning the spreading of toxic wastes from NYC to Penn. farmlands.Whatever can be done must be done. [email protected]
WanadfMmch4,im Amtric* Ontint: SmdyHCSmi Fmge: 1
Sub;: USDA proposalDate: 98-03-03 10:01:49 ESTFrom: [email protected] (Connie L Keeney)To: [email protected] [email protected]')
ALTHOUGH I HAVE MANY CONCERNS WITH THE DECEMBER15TH PROPOSAL, I WANT TO SPECIFICALLY CITESECTION 205.22. I DO NOT APPROVE OF USING BiOSOLIDS, SEWAGE SLUDGE, ON SOILS WHERE FOOD ISGROWN.
CONNIE KEENEY 174-36-681720181 DUTTON RD [email protected], PA 17363
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Message-ID: <01 BD468A.BDC3D140@t!28.cyberia.com>From: -Connie L Keeney* <[email protected]>To: '"[email protected]"' <[email protected]>Subject: USDA proposalDate: Tue, 3 Mar 1998 09:57:04 4)800MIME-Version: 1 0Content-Type: text/plain; charset=Mus-asciiM
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Tuesday atonch 3,199$ AnrnriemOnitn»:SmdyHCSmi Pwge: 1
Subj Re: SLUDGE!Date: 9&03O2 16:34:46 ESTFrom: [email protected] (Dolores E. Krick)To: [email protected]
NO SLUDGE on our term ground. We are very concerned and obsolete!/opposed to sludge being spread on our farms!Certainly crops grown on sludge is not organic!
Steve and Dolores Krick11721 Muddy Creek Rd.Aindle, Pa. 17302
You dont need to buy Internet access to use free Internet e-mail.Get completely free e-mail from Juno at http://www.juno.comOr call Juno at (800) 654-JUNO [654-5866]
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To: [email protected]: Mon. 2 Mar 1998 13:55:32 -0500Subject: Re: SLUDGE!Message-ID: <19980302.141324.11894.1 [email protected]>References: <[email protected]>X-Mailer Juno. 1.49 . -X-Juno-Line-Bneaks: 1-8From: [email protected] (Dolores E. Krick)
Monday march 1199$ Amtica Onknt: SandyHCSmf Page: 1
Subj: SLUDGEBUSTERDate: 98-03-02 19:55:56 ESTFrom: SquochTo: SandyHCSmiCC: Squoch
To Whom It May CocemMy name is Peter H. Pasquoche III. I got a call from Sandy about the EPA allowing food to be grown on Sludged fields. This
SCARES the daylights out of me. Because this is dangerous because we do notwhat in sludge. And food should not be eatenbecause we do not know what effects itwill have on humans. Mo not think this should be allowed. NO DO NOT ALLOW THISTO H A P P E N » » This most deffinately is not ORGANICLY grown, lam dead againest this perposal. Thank you.
Peter H. Pasquoche IIITheresa R. PasquocheWalter L Lanham
Monday March 2.1998 Amenc* Ontttf: SmdyHCSnU tog*: 1
Subj: Against Sewage Sludge/BiosoiidsDate: 98-0W1 21:15:50 ESTFrom: RBFBARNTo: SandyHCSmi
Dear Sandy,
I'm writing to voice my protest against any agricultural use, including organic food production, of sewage siudge/biosolids.
Sincerely,E. Hosterman
Felton, PA 17322
Suntiay torch 1,19H Ammcs Onto*. SmxtyHCSmt A g * 1
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^ ORIGINAL:MIZNER 'COPIES:
93 N07 ; 0 ?;
REVIEW COM
1975
Wilmarth . .
Sandusky. •Legal . ;
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JULATORYSSiON
ORIGINAL: 1975rc, MIZNER
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Date: 27-Oct-1998 12:20pm ESTFrom: Cavett, Robert M.
robert_cavett@merck. com@PMDF@D
TO: 'Brezina, Edward (PADEP)' ( Brezina.EdwardOAl.dep.state•pa.us@PM
CC: Miorelli, Tom ( [email protected]@PMDF@DER003 )CC: Wittmer, Steve ( [email protected]@PMDF@DER003CC: Kuder, Beryl M. ( [email protected]®PMDF@DER003 )
CC: Buzby, Mary E. ( [email protected]@PMDF@DER003 )
Subject: Comments on Proposed Rulemaking - PA Water Quality Amendments
Dear Mr. Brezina:Merck & Co., Inc. (Merck) is a worldwide researcher and manufacturer ofhuman and animal health care products. As such, we own and operatemanufacturing facilities, research laboratories, and office supportfacilities that rely on water and wastewater utilities subject to theproposed rule.
Merck applauds PA DEP's effort to streamline, consolidate, and clarifyregulations, and update State regulations to be consistent with federalregulations. Merck believes, however, that elements of this proposalcontinue to place the emphasis on point source dischargers while nonpointsource contributions, which constitute the majority of PA water qualityimpairments, remain largely ignored. We appreciate the opportunity toprovide the following comments to this proposed rule.
Please find as a separate attachment comments for the proposed rulemakingfor Title 25 PA Code Chapters 92, 93, 95, 96, and 97 submitted by the WestPoint, PA site of Merck & Co., Inc.
<<Comments on PA proposed Water Quality Amendments,doc>>
Again Merck is grateful for the opportunity to provide comments to thisproposed rule. We invite the Department to contact Robert Cavett at (215)652-7973 to discuss these comments, to seek clarification of any informationin these comments, or to request additional information, if necessary.
Sincerely,
ei :£ Hd £213086
Environmental Project Engineer
m a d *- Co', Inc. D.v
s We the undersigned people living in Chanceford Township to herebyask the Court of C mon.Pleas in York, PA to i oin the further. _ x\dumping of sewage *.udge from whatever source arrived on realestate in Chanceford Township in that the practice of dumpingsewage sludge on land as a means of disposing of human sewageand other municipal waste.constitutes an actual hazard to the , _health and welfare to the people residing in the area wherein said sludge is dumped._._
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To the York County O-imissioners:We, the undersigned law,~nvners? object to our raised assessed W~d values. We feel our landvalues have gone down due to the increased Municipal Sewage Sludging on farmland in YorkCo. We feel out tax dollars are being used to devaluate our land. PA Farmland PreservationProgram is actually "preserving" these "farming dumps*along with the added support of$600,000. from you, our commissioners. All this sludge money, preservation money & count)money IS OUR TAX DOLLARS-WE DO NOT APPROVE!'Name Address Phone(not needed)
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We*the undersigned landowners^object to dur raised assessed iana vaiues,We feel our land value- have gone down due to the increased Municipal SewageSludging lh the Souths . York County. We feel oui .ax dollars arejbeingused to devaluate our land. PA Farmland Preservation Program actually is"preserving" these "farming dumps" along with the added $600,000. Help fromthe York Co. Commissioners. All this sludge money, preservation money andcounty money IS OUR TAX DOLLARS; |!:
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TO m e IUIK v uunuy tonranssioiieis. . .We,the undersigned landowners,object to our raised assessed land values.We feel our land vali have gone down due to the '"-"assd Municipal SewageSludging in the Southern York County. We feel our tax dollars are beingused to devaluate our land. PA Farmland Preservation Program actually is"preserving" these "farming dumps" along with the added $600,000. help fromthe York Co. Commissioners. All this sludge money, preservation money andcounty money IS OUR TAX DOLLARS. ______
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PETITION.-We the undersigned people living in Chanr^ford Township to hereby *ask.-tha.Coux af Common Pleaa. In. York, __P. -o .enjoin the further......dumping of sewage sludge from whatever source derived on realRshafp in Chanceford Township..ia_that.±iia__pracLU;& of Lumaiixasewage sludge on land as a means of disposing of human sewageand other municipal waste constitutes an actual hazard to thehealth and welfare to the people residing in the area wherein said sludge is dumped.
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._. BETITIQN -. .. . ... ..We the undersigned people living in Char'^.ford Township to hereby-ask .the ..Con ~af ..Common Pleas in York, 1 to enjoin the further..dumping of sewage sludge from whatever source derived on real-asta±e Jj^Chaj^^f QrdJQwnshi£^in_that the practice of. dumpingsewage sludge on land as a means of disposing of human sewageand other municipal waste constitutes an actual hazard to thehealth and welfare to the people residing in the area wherein said sludge is dumped.
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.PETITIONWe the undersigned people living in Chan-eford Township to herebyask-the.-.Cau _of.. Common Eleas_in York, ..1 to enjoin the further.dumping of sewage sludge from whatever source derived on realeshaKe in rhancefnrd Township in that the practice of ...dumpingsewage sludge on land as a means of disposing of human sewageand other municipal waste constitutes an actual hazard to thehealth and welfare to the people residing in the area wherein said sludoe is dumped. _
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PJETXTIQN ... .. . _We the undersigned people living in Chanc cord Township to hereby
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We the undersigned people living in Chanceford township to herebyask~the~Court-.of.-Cc on_Eleas in..York,_ PA to e jin the further ..dumping of sewage sludge from whatever source derived on real
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We the undersigned people living in Chanc^ford Township to herebyask the-Com nf rnmmnn Pleas in York, p ;Q enjoin the further. _dumping of sewage sludge from whatever source derived on real*«?t-afe in Channefprd Tnwnship in that the * practice . qf _dumEiH9sewage sludge on land as a means of disposing of human sewageand other municipal waste constitutes an actual hazard to thehealth and welfare to the people residing in the area wherein said sludge is dumped.
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We the undersigned people living in Chanr^ford Township to herebyask—the-Cou: xi£-Cnmmon~Elftas. in...YorJc,-JE ta enjoin the further.,..dumping of sewage sludge from whatever source derived on realpsfahfl in rhanrefnrd Township in that ..the; practice Qf _dumpiJl9 .sewage sludge on land as a means of disposing of human sewageand other municipal waste constitutes an actual hazard to thehealth and welfare to the people residing in the area wherein said sludge is dumped.
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We the undersigned people living in Chanceford Township to hereby...ask—the-.Court~of-Cor n__21eas in_Yock,_PA to._en in the furtherdumping of sewage sludge from whatever source derived on rea'lestate-in-JCharuciaCord.JEowiLship^in^.thaJ:_the__pnaatice.. of dumpi|0£Lsewage sludge on land as a means of disposing of human sewageand _o£h.ex-Jiiuniqj.pal^^ to_tfiehealth and welfare to the pedple residing in the area where']
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We the undersigned people-''living in Chanceford Township to .herebyask_the_.Court.of_Com n P1eas..ln,Jfork,-.PA^to_en, in the further.dumping of sewage sludge from whatever source derived on rejalestate.in_Chanceford__Tmm&hip_in_tha.L_the_pca^ of dumping.sewage sludge on land as a means of disposing of human sewage_and_othe^jnunlcApaJLJfiwta^ons..titut^s^n..ac^ualJiaj2ard to^^e..health and welfare to the people residing in the area wherej
5DRESS--J&ZL&KJb&Q
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To The YorK county commissioners: # - - ,We,the undersigned landowners,object to our raised assessed land values.We feel our land valu< have gone down due to the creased Municipal SewageSludging in the Southern York County. We feel our tax dollars are beingused to devaluate our land. PA Farmland Preservation Program actually is"preserving" these "farming dumps" along with the added $600,000. help fromthe York Co. Commissioners. All this sludge money, preservation money andcounty money IS OUR TAX DOLLARS. !
NAME ADDRESS PHONE
b>L£imic*tc MJkt J?f,ffi%s/SeAS>
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<*LL-&nJfc <Ofc AW« Sir, ¥lT4,PA /&*,.,,
4^&XXXXUN -
We the undersigned people living in Chanc^ford Township to herebyask -the' "Cau. r>£ Common Pleas in York, P :o enjoin the furtherdumping of sewage sludge from whatever source derived on realpsf-at-p in Chance for a Townfship^ln^tJhat thet practice, of Jumpingsewage sludge on land as a means of disposing of human sewageand other municipal waste constitutes an actual hazard to thehealth and welfare to the people residing in the area wherein said sludge is dumped.
/ADDRESS
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To The York County Commissioners: wu.*e/uuo.j » —-We,the undersigned Jane1 mers,object to our raised ssessed land values.We feel our land values .iave gone down due to the i creased Municipal SewageSludging in the Southern York County. We feel our tax dollars are beingused to devaluate our land. PA Farmland Preservation Program actually is"preserving" these "farming dumps" along with the added $600,000. help fromthe York Co. Commissioners. All this sludge money, preservation money andcounty money IS OUR TAX DOLLARS.
NAME ADDRESS PHONE
To The York County Commissioners:We,the undersigned landowners,object to our raised assessed land values.We feel our land values have gone down due to the increased Municipal SewageSludging in the Southern York County. We feel our tax dollars are beingused to devaluate our land. PA Farmland Preservation Program actually is"preserving" these "farming dumps" along with the added $600,000. help fromthe York Co. Commissioners. All this sludge money, preservation money andcounty money IS OUR TAX DOLLARS. :
NAME ADDRESS PHONE
•'Viiuiu a a xwi
2,the undersigned landowners,object to our raised assessed land values.We feel our land valuer ave gone down due to the i Teased Municipal SewageSludging in the Southern York County. We feel our cax dollars are beingused to devaluate our land. PA Farmland Preservation Program actually is"preserving" these "farming dumps" along with the added $600,000. help fromthe York Co. Commissioners. All this sludge money, preservation money andcounty money IS OUR TAX DOLLARS. =
NAME ADDRESS PHONE
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ijjj June, July, August & September 1997^ To the York County f nraissioners:
We, the undersigned landowners, object to our raised assessed land values. We feel our landvalues have gone down due to the increased Municipal Sewage Sludging on farmland in York
. Co. We feel out tax dollars are being used to devaluate our land. PA Farmland PreservationProgram is actually "'preserving" these "farming dumps"along with the added support of5600,000. from you, our commissioners. All this sludge money, preservation money & countymoney IS OUR TAX DOLLARS-WE DO NOT APPROVE!Eams Address Phone/not needed)
(JOS? ]/UMJUwt //&6/L/^-/
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To The York County mmissioners: June/July ,,%,We,the undersigned x-andownersfobject to our ral-*^d assessed land values.We feel our land values have gone down due to the increased Municipal SewageSludging in the Southern York County. We feel our tax dollars are beingused to devaluate our land. PA Farmland Preservation Program actually is"preserving" these "farming dumps" along with the added $600,000. help fromthe York Co. Commissioners. All this sludge money, preservation money andcounty money IS OUR TAX DOLLARS. ::
NAME ADDRESS PHONE
^/•OA'^cr /J'K'/*/yr<r,s?<r/ SA*?n£ / " V / V V
"7w? h^Mii/f- /?S* w- Hence &>. /SK^A/ <$jew , ra . / ? Jz /
^ June, JuJy, August &. September 1997To the York County 0 tmissioners:We, the undersigned lanflowners, object to our raised assessed land values. We feel our landvalues have gone down due to the increased Municipal Sewage Sludging on farmland in YorkCo. We feel out tax dollars are being used to devaluate our land. PA Farmland PreservationProgram is actually "preserving" these "farming dumps"along with the added support of$600,000. from you, our commissioners. All this sludee money, preservation money &. countymoney IS OUR TAX DOLLARS-WE DO NOT APPROVE!"BaQf Address Phonefnot needed^
June, July, August & September 1997To the York County C missioners:We, the undersigned landowners, object to our raised assessed land values. We feel our landvalues have gone down due to the increased Municipal Sewage Sludging on farmland in YorkCo. We feel out tax dollars are being used to devaluate our land PA Farmland PreservationProgram is actually ^preserving" these "farming dumps"along with the added support of3600,000. from you, our commissioners. All this sludge money, preservation money & countymoney IS OUR TAX DOLLARS-WE DO NOT APPROVE! *£am£ Address Phonefnot needed)
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' < June, July, August & September 1997To the York County C missioners:We, the undersigned landowners, object to our raised assessed land values We feel our landvalues have gone down due to the increased Municipal Sewage Sludging on farmland in YorkCo. We feel out tax dollars are being used to devaluate our land PA Farmland PreservationProgram is actually "preserving" these "farming dumps"aiong with the added support ofS600,000. from you, our commissioners. All this sludge money, preservation money & countymoney IS OUR TAX DOLLARS-WE DO NOT APPROVE!"£am£ Address Phonef not needed)
W O/UM TncctU^^ £J&*'KWA' (-iv^Vv €ltr. ;>
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June, Julv August & September 1997To the York County C imissioners:We, the undersigned landowners, object to our raised assessed land values. We feel our landvalues have gone down due to the increased Municipal Sewage Sludging on farmland in YorkCo. We feel out tax dollars are being used to devaluate our land. PA Farmland PreservationProgram is actually "preserving" these "farming dumps"along with the added support of$600,000. from you, our commissioners. All this sludge money, preservation money & countymoney IS OUR TAX DOLLARS-WE DO NOT APPROVE!"Name Address Phonef not needed)
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Z*/X6 Utfst!?&£r*&- Of- X^r<^
Jj*~-«.U-Ji /dfi^-^ Dover ^ f A
We,the undersigned landowners,object to our raised assessed land values.We feel our land valt have gone down due to the ncreased Municipal SewaoeSludging in the Southern York County. We feel our tax dollars are beingused to devaluate our land. PA Farmland Preservation Program actually is"preserving" these "farming dumps" along with the added $600,000. help fromthe York Co. Commissioners. All this sludge money, preservation money andcounty money IS OUR TAX DOLLARS.
NAME ADDRESS PHONE
IScaefVtxoJki
4sCw 7tfs*<C* , /6 ) Dc,u d id Lie* i4?mr6r
We,the undersigned landowners,object to cur raised assessed land values.We feel our land value have gone down due to the creased Municipal SewageSludging in the Southern York County. We feel our cax dollars are beingused to devaluate our land. PA Farmland Preservation Program actually is"preserving" these "farming dumps" along with the added $600,000. Help fromthe Yotk Co. Commissioners. All this sludge money, preservation m6ney andcounty money IS OUR TAX DOLLARS. j!"
NAME . ADDRESS PHONE
4A / &«*/tr. &J#t^(&
/eo/ #<*y yi"/ ^ro^oe /w-
9^ ?6 3/6
/ ! vJ'i,TO m e YorK county commissioners:rf''j We# the undersigned iatHnknera,object to our raised assessed land values,^ We feel our land valui have gone down due to the creased Municipal Sewage
Sludging ih the Southern York County. We feel our tax dollars are^beingused to devaluate our land. PA Farmland Preservation Program actually is"preserving" theme "farming dumps" along with the added $600,000. Help fromthe York Co. Commissioners. All this sludge money, preservation m6ney andcounty money is OUR TAX DOLLARS; j!1
NAME ADDRESS __ PHONE__T
yU/n. d Sfli^M,
2.
/ ;/^? fo^s fct^ tf/i n&L
(10S fincSi fptuotl, PR I7*o£\
June, July, August & September 1997To the York County C raissioners:We, the undersigned landowners, object to our raised assessed land values. We feel our landvalues have gone down due to the increased Municipal Sewage Sludging on farmland in YorkCo. We feel out tax dollars are being used to devaluate our land. PA Farmland PreservationProgram is actually "preserving" these "farming dumps"along with the added support ofS600,000. from you, our commissioners. All this sludge money, preservation money & count)money IS OUR TAX DOLLARS--WE DO NOT APPROVE!"Name Address Phonefnot needed)
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M^ JU-^pji'
June, J- ' . August & September 1997To the York County nmissioners:We, the undersigned landowners, object to our raised assessed land values. We fee! our landvalues have gone down due to the increased Municipal Sewage Sludging on farmland in YorkCo. We feel out tax dollars are being used to devaluate our land. PA Farmland PreservationProgram is actually "preserving" these "farming dumps"along with the added support of5600,000. from you, our commissioners. AH this sludge money, preservation money & countymoney IS OUR TAX DOLLARS-WE DO NOT APPROVE!'Eamfi . Address
floo/ati'toPhonef not needed)
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(^ 0.U4
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.-> June, Ji-1- • August & September 1997To the York County < unissioners:We, the undersigned landowners, object to our raised assessed land values. We feel our landvalues have gone down due to the increased Municipal Sewage Sludging on farmland in YorkCo. We feel out tax dollars are being used to devaluate our land. PA Farmland PreservationProgram is actually "preserving" these "farming dumps"along with the added support of$600,000. from you, our commissioners. All this sludge money, preservation money & count)money IS OUR TAX DOLLARS-WE DO NOT APPROVE!Name Address Phonefnot needed)
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_/ June, J August & September 1997To the York County mmissioners:We, the undersigned landowners, object to our raised assessed land values. We feel our landvalues have gone down due to the increased Municipal Sewage Sludging on farmland in YorkCo. We feel out tax dollars are being used to devaluate our land PA Farmland PreservationProgram is actually "preserving" these "farming dumps"along with the added support of5600,000. from you, our commissioners. All this sludge money, preservation money & countymoney IS OUR TAX DOLLARS-WE DO NOT APPROVE!"&amS- AjMryw = Phonef not needed)
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June, J-' August & September 1997To the York County nmissioners:We, the undersigned landowners, object to our raised assessed land values. We fee! our landvalues have gone down due to the increased Municipal Sewage Sludging on farmland in YorkCo. We feel out tax dollars are being used to devaluate our land. PA Farmland PreservationProgram is actually "preserving"' these "farming dumps"along with the added support of5600,000. from you, our commissioners. All this sludge money, preservation monev & countvmoney IS OUR TAX DOLLARS-WE DO NOT APPROVE1'Name fa^ U -~~ Address V/1P L /%_
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Sku&rkfa tan, PS1/?3*3
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V^ June, J' August & September 1997*' To the York County i jnmissioners:
We, the undersigned landowners, object to our raised assessed land values. We feel our landvalues have gone down due to the increased Municipal Sewage Sludging on farmland in YorkCo. We feel out tar dollars are being used to devaluate our land. PA Farmland PreservationProgram is actually "preserving" these "farming dumps"along with the added support of$600,000. from you, our commissioners. All this sludge money, preservation money & count)money IS OUR TAX DOLLARS-WE DO NOT APPROVE!Name Address Phonef not needed)
'-/ill, ffl /7/cJLC&*cJ,t*~>£^*s jyj 'g,*^, /w/. /gt^A. /?**?
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s(y June, } \ August & September 1997To the York County ,mmissioners:We, the undersigned landowners, object to our raised assessed land values. We feel our landvalues have gone down due to the increased Municipal Sewage Sludging on farmland in YorkCo. We feel out tax dollars are being used to devaluate our land PA Farmland PreservationProgram is actually '"preserving" these "farming dumps^along with the added support of$600,000, from you, our commissioners. All this sludge money, preservation money & count)money IS OUR TAX DOLLARS-WE DO NOT APPROVE!"Bams A(Mr?ss Phonef not needed)
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To The York County Commissioners: ' . "We,the undersigned le ^owners,object to our .raise assessed land values.We feel our land valu*«* have gone down due to the increased Municipal SewageSludging in the Southern York County. We feel our tax dollars are beingused to devaluate our land. PA Farmland Preservation Program actually is"preserving" these "farming dumps11 along with the added $600,000. help fromthe York Co. Commissioners. All this sludge money, preservation money andcounty money IS OUR TAX DOLLARS. '
NAME ADDRESS PHONE
CZlJVx_\r4&_\ \ ^ V d o vvv^z-\ V^xVVv^
£fa fry. </ofo LJ^h^A / z*-u-
£.
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lllllJLOOJ.UmiA. &
We,the undersigned landowners,object to our rals' assessed land vdlues.We feel our land valv , have gone down due to the increased Municipal SewageSludging in the Southern York County. We feel our tax dollars are beingused to devaluate our land. PA Farmland Preservation Program actually is"preserving" these "farming dumps11 along with the added $600,000. help fromthe York Co. Commissioners. All this sludge money, preservation money andcounty money IS OUR TAX DOLLARS. :
NAME ADDRESS PHONE
ys^-/ %^
SL. **fru-*—£&
^>L.X <lj**> *3^TT-' ^""
4-vcui € ^ l ^ £>*-**»•< P#
O -— c 1 (V Ci 0v\.
We,the undersigned landowners,object to our raiser assessed land values.We feel our land value have gone down due to the ^creased Municipal SewageSludging ih the Southern York County. We feel our tax dollars are beingused to devaluate our land. PA Farmland Preservation Program actually is"preserving" these "farming dumps" along with the added $600,000. Help fromthe York Co. Commissioners. All this sludge money, preservation mciney andcounty money IS OUR TAX DOLLARS i |!:
NAME ADDRESS , PHONE
0
(jii\*-o( (X Tv-ck-uOC/1
* w . w
^44 Gorxxm /^d. "Brtg.it, %. 1730?
30 3 5.i4f0car/tr S4 Aphq
ldJn)c/s*K fa, 17$CJL
woe T^coc>V.ur>
We,the Undersigned landotoners>bbjfect to out raised assessed land values.We feel our land valu have gone down due to the ncreased Municipal SewageSludging ih the Southern York County. We feel our tax dollars are beingused to devaluate our land. PA Farmland Preservation Program actually is"preserving" these "farming dumps" along with the added $600,000. Help fromthe York Co. Commissioners. All this sludge money, preservation money andcounty money IS OUR TAX DOLLARS •. |l"
NAME ADDRESS . PHONE
1/ s
y 6 1 - 1 ? Lk I
K<
To The YOTK county commissioners:We,the undersigned 1 ~ndotoners, object to our raif * assessed land values.We feel our land val .s have gone down due to the increased Municipal SewaoeSludging in the Southern York County. We feel our tax dollars are beingused to devaluate our land. PA Farmland Preservation Program actually is"preserving" these "farming dumps" along with the added $600,000. help fromthe York Co. Commissioners. All this sludge money, preservation money andcounty money IS OUR TAX .DOLLARS.
N A M E ^ III ADDRESS PHONE
O/lgfJliiM- m Cfin* t»
T 27-?oo/
s&
W
Wefthe undersigned landowners,object to our raisr assessed land values.We feel our land vail , have gone down due to the increased Municipal SewageSludging in the Southern York County. We feel our tax dollars are beingused to devaluate our land. PA Farmland Preservation Program actually is"preserving" these "farming dumps" along with the added $600,000. help fromthe York Co. Commissioners. All this sludge money, preservation money andcounty money IS OUR TAX DOLLARS.
NAME ADDRESS PHONE
Sty*fit* \bin
.f>*- /-7' " ' >?7-fy ,-
£
i
<*? Sts^,#
/Vn/ "Ctr />3'SJ2?
yfrwL
(\JLu- "iavJcX
York PA n ^ 2
T O Tne YorK county Commissioners: ^ ,We,the undersigned lr iowners,object to our rais< assessed land vdiues.We feel our land valu s have gone down due to the "increased Municipal SewageSludging in the Southern York County. We feel our tax dollars are beingused to devaluate our land. PA Farmland Preservation Program actually is"preserving" these "farming dumps" along with the added $600,000. help fromthe York Co. Commissioners. All this sludge money, preservation money andcounty money IS OUR TAX DOLLARS. t
NAME ADDRESS PHONE
^.V«-i—*"*—*
'^dOlUWUi. 7 •- — -- -— -— — — — — - - - - — —- -*w F- -»-v — — i y
We,the undersigned landowners^object to out raised assessed land values.We feel our land valu have gone down due to the increased Municipal SewageSludging in the Southern York County. We feel our tax dollars are beingused to devaluate our land. PA Farmland Preservation Program actually Is"preserving" these "farming dumps" along with the added $600,000. Help fromthe York Co. Commissioners. All this sludge money, preservation mdney andcounty money IS OUR TAX DOLLARS. j!
NAME ADDRESS PHONE
' ' few Qj$*M
ft.0 tf/ fox/^f $xr*\%<?+t7}oZ>
£• O. */ %(^ 5 %2n^ A ^Vf/Z/sfA £oc££o/. tf'£W,?/sM
tP^i fiisi
£0 3 fafts' y&J&z /I /VJs
-^ 7.-0/33
We
ill-**'*'
We,the undersigned landowners,object to our raise assessed land values.We feel our land valu have gone down due to the increased Municipal SewageSludging in the Southern York County. We feel our tax dollars are beingused to devaluate our land. PA Farmland Preservation Program actually is"preserving" these "farming dumps" along with the added $600,000. help fromthe York Co. Commissioners. All this sludge money, preservation money andcounty money IS OUR TAX DOLLARS. ,
NAME ^ ,. _ ADDRESS PHONE. ^ ^ f__5^_ ~. _ ^^s. * » » ^ * ^ * * * * * * * *
rl
-yn-.ln^c^
%r*w *"»•**
^&'<Vt/usv "M-r
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717 ?"O ^
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KS T O m e YorK county. Commissioners: J '"'Cs We,the undersigned la- 'owners,object to our raise assessed land values.V We feel our land valuv have gone down due to the increased Municipal Sewage
Sludging in the Southern York County. We feel our tax dollars are beingused to devaluate our land. PA Farmland Preservation Program actually is"preserving" these "farming dumps11 along with the added $600,000. help fromthe York Co. Commissioners. All this sludge money, preservation money andcounty money IS OUR TAX DOLLARS. ?•
NAME ADDRESS PHONE
/££&>* / v -7^^<
&?' 6/7)Sfcy
V*LH. Vy
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Jt-fi ~ /?/, \-1 -f/?W 6T^Y<-< i
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^^Iz&^o-dxo "RlPVx&X- K t O ^ w o ^ , '(£*{t\-9& 7
j>o s I***-- &. S' ?>>^*i {'*'<-' S~ ?fj •??/*'
To The York County Commissioners:We,the undersigned 1* downers,object to our rais assessed land values.We feel our land valv 3 have gone down due to the increased Municipal SewageSludging in the Southern York"County. We feel our tax dollars are beingused to devaluate our land. PA Farmland Preservation Program actually is"preserving" these "farming dumps" along with the added $600,000. help fromthe York Co. Commissioners. All this sludge money, preservation money andcounty money IS OUR TAX DOLLARS.
NAME ADDRESS PHONE
3 3c>7
i A- J. J. X A U M
We the undersigned people living in Ch reford Township to hereby.ask-the_.G ;t~af Common Pleasin .York, .FA to enjoin the furtherdumping of sewage sludge from whatever source derived on real
-estate in Channp.forri Tovmahlp^in-Jthat. ±IiQ- practice, of .dumping _sewage sludge on land as a means of disposing of human sewage_an±_other municipal waste constitutes an actual hazard to thehealth and welfare to the people residing in the area wherein said sludge is dumpecL
We the undersigned people living in Chancefor" Township to hereby.-ask_the_Cour.t-of..r imon_£leas -in..JTork,_PA. .ta_t™join the furlher_. _..dumping of sewage sludge from whatever source derived on real
--estate_la_ChancefordJTQWjnship,in...that..the. practice.of dumpingsewage sludge on land as a means of disposing of human sewage
._.androther_.muni.cipaXjwa^t£_cpnstit:.utes_an.actual.hazard to_thehealth and welfare to the people residing in the area whereji!
- -^in-S5id_.sludge_is_dumpe.dJ '._ __. _JjL
h^J^m.±^Km> .'&>!. toy 7teDDMolve , fA mot fit he& ~ (1 Ss^i. /?Sy'/ /Joy US /?<<f /,o* fc , pjs L
iLr^-^LAzL2 : .S/SLc^yL^JJiL
i!LJ^2i.2_(^
'WQf ftlio*. A
^ 1 &ox*W //,/?\//LLt.;./cMje Q+MI $0*1 fied L'O/i
w
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H_hjJ9U
4'/*•//fu-
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\ * v june, JUIV, August & aepiemocr i-yy iTo the York County r mmissioners:We, the undersigned landowners, object to our raised assessed land values. We feel our land
/ if/ values have gone down due to the increased Municipal Sewage Sludging on farmland in Yorkt ' l Co. We fee! out tax dollars are being used to devaluate our land. PA Farmland Preservation
Program is actually '"preserving" these "farming dumps"along with the added support of$600,000. from you, our commissioners. All this sludge money, preservation money &. countymoney IS OUR TAX DOLLARS-WE DO NOT APPROVE!Name^gt/w u_ Address Phonefnot needed)
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' - June, Ji August & September 1997To the York County L ^imtssioners:We, the undersigned landowners, object to our raised assessed land values We feel our landvalues have gone down due to the increased Municipal Sewage Sludging on farmland in YorkCo. We feel out tax dollars are being used to devaluate our land. PA Farmland PreservationProgram is actually "preserving" these "farming dumps"along with the added support of$600,000. from you, our commissioners. All this sludge money, preservation money & countymoney IS OUR TAX DOLLARS-WE DO NOT APPROVE!"Name &MISS& x. Phonefnot needed)
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To the York County C timissioners:We, the undersigned Ia*~owners, object to our raised assessed I*«<J values We feel our landvalues have gone down due 10 the increased Municipal Sewage Sludging on farmland in YorkCo. We feel out tax dollars are being used to devaluate our land. PA Farmland PreservationProgram is actually "preserving^ these ^farming dumps"along with the added support ofS600,000. from you, our commissioners. All this sludge money, preservation money & countymoney IS OUR TAX DOLLARS-WE DO NOT APPROVE!"Name __ Address Phonefnot needed)
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^ - ^ To the York County Commissioners:We, the undersigned la. owners, object to our raised assessed L A values. We feel our landvalues have gone down due to the increased Municipal Sewage Sludging on farmland in YorkCo We feel out tax dollars are being used to devaluate our land. PA Farmland PreservationProgram is actually ^preserving" these "farming dumps"along with the added support of5600,000. from you, our commissioners. All this sludge money, preservation money & countymoney IS OUR TAX DOLLARS-WE DO NOT APPROVE!"Name Address ^ Phonef not needed)
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vy June, July, August & September 1997To the York County mmissioners:We, the undersigned landowners, object to our raised assessed land values. We feel our landvalues have gone down due to the increased .Municipal Sewage Sludging on farmland in YorkCo. We feel out tax dollars are being used to devaluate our land. PA Farmland PreservationProgram is actually "preserving" these "farming dumps"along with the added support of$600,000. from you, our commissioners. All this sludge money, preservation monev & countymoney IS OUR TAX DOLLARS-WE DO NOT APPROVE!Name Address ^* Phonefnot needed)
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THE PINE CREEK ALLEYWATERSHED ASSOCIATION, INC.P.O. Box 239Oley, PA 19547
ORIGINAL: 1975MIZNERCOPIES: Wilmarth
Sandusky
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Environmental Quality BoardRachel Carson State Office Building400 Market StreetP.O. Box 8477Harrisburg, Pa. 17105-2301 U5w«i52^-"-w
October 22, 1998
Re: Regulatory Basics Initiative - Extension of PublicComment Period; Chapts. 92; and 93
Dear Sirs:
The Pine Creek Valley Watershed Association (PCVWA) hereby submits itscomments regarding the subject proposed rulemaking:
COMMENT PERIODThe extensive nature of the proposed rule changes and the relatively short sixty
day comment period poses a great difficulty for small volunteer organizations wishingto provide comment and input. We therefore, respectfully request that you extend thecomment period for another sixty days.
Chapter 92, NPDES Permitting, Monitoring, and Compliance92.25(3): For total residual chlorine, the technology cap of 0.5mg/l is proposed to beretained. We support this measure as it serves to ensure the protection of aquatic lifefrom a substance that can be toxic to such forms in high concentration.92.61: Additional public comment should be solicited, in particular when an
application is filed. It is important to know about specific public water quality concernsbefore all the calculations have been done and a draft permit published.92.81: We specifically oppose :
Allowing general permits to include limits for toxic chemicals. There is no easyway to track who uses these permits, DEP therefore should not allow toxics ingeneral permits;Allowing general permits to be issued in high quality waters with no indication ofhow water quality will be maintained. The use of these permits needs to befollowed closely, which is very difficult. Therefore, DEP in general should notallow the use of general permits in high quality waters;Deleting the requirement for documenting that the general permit will not violatewater quality standards. The documentation provision should be retained to
ensure water quality standards will not be violated by the use of general permits;Not including in the proposal a prohibition of the use of general permits inimpaired waters. The use of general permits should not be allowed in waterswith water quality problems.
Chapter 93 Water Quality Standards93.4: We support maintaining this section because it protects all our waters as
"potable water11 sources.93.4: We oppose the deletion of warm water fishes as a statewide water use. Abasement level of protection should be afforded.93.5(e): DEP should retain and implement the following language prohibiting "mixingzones" "Criteria necessary to protect other designated uses shall be met at the point ofwastewater discharge."93.6: One area not covered by Pennsylvania regulations is instream flow and habitat.Because PA has no comprehensive water resources management, the DEP shoulddevelop instream flow and habitat criteria and incorporate them into this chapter ofregulation. To this end, PCVWA seconds the testimony regarding the same subjectmatter, made by Mark Hersh, U.S. Fish & Wildlife Service, to this board at Harrisburgon Oct. 20, 1998, with specific emphasis on the following::
"While biological integrity is afforded some protection through theaquatic life protected water uses, there is no regulatory languageprotecting habitat. It follows, then, that Pennsylvania's waterquality standards should include provisions protecting the habitat andhydrological integrity of surface waters of the Commonwealth. Thiswould entail modifying one and adding two sub-sections to "Chapter93.6. General water quality criteria." The modifications tosub-section "(a)" follow the definition of "pollution" in thePennsylvania's Clean Streams Law:
(a) Water may not contain substances attributable to point ornonpoint source [waste] discharges in concentration or amountssufficient to be, nor shall waters be altered such that the alterationis inimical or harmful to [the water] designated or existing uses [tobe protected] or to human, [animal, plant or] aquatic life orwildlife.
The new sub-section "(c)," would simply read:
(c) Human-induced alterations in hydrologic regime, includinginstream flow, shall not be inimical or harmful to designated orexisting uses, including recreation and aquatic life and wildlife.Natural seasonal and daily variations shall be maintained.
The new sub-section "(d)" protects habitat:
(d) Human-induced alterations in habitat shall not be inimicalor harmful to designated or existing aquatic life and wildlife uses.
Three new definitions are needed in Chapter 93.1 in order to supportthese additions.
Aquatic life-Desirable aquatic flora and fauna that are wholly orpartially dependent on waters of the Commonwealth for habitat or lifecycle functions.
Flow-A hydrologic regime to which aquatic life have naturallyadapted.
Hydrologic regime-The regular pattern of occurrence, circulation, anddistribution of water in surface waters.
All these additions to Pennsylvania's standards reflect the existingState and federal laws, and simply bring the standards in compliancewith the existing laws."
PCVWA appreciates the opportunity to present its views on these proposedregulatory changes.
Thank you,
y^j^^/^/^j^—~~'Harlan J. Snyder, v.pres.
Sub] Keep sludge off farmlandDate: 98-03-04 09:33:56 ESTFrom: [email protected] (June Evans)Reply-to: [email protected]: [email protected] (Smith, Sandy)
I oppose using municipal sewage waste sludge on farmland used to growfood crops, whether organic or otherwise, but especially not for organic(bods that are by definition supposed to be free of the toxic man-madechemicals which are typically found in sewage waste sludge.
Robert Evans1752 Roundtop LaneWrights ville, PA 17368
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Message-ID: <[email protected]>Date: Wed, 04 Mar 1998 09:38:48 -0500From: June Evans <jevans@cyberia. com>Reply-To: [email protected] Mozilla 2.02 (Macintosh; I; PPC)MIME-Version: 1.0To: "Smith, Sandy" <[email protected]>Subject: Keep sludge off farmlandContent-Type: text/plain; charset=us-asciiContent-Transfer-Encoding: 7bit
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SUMMARY of Comments on the PROPOSED WATER QUALITY REGULATIONSOctober 22,1998 from ALLIANCE FOR A CLEAN ENVIRONMENT
ACE is a grass roots environmental organization in the Pottstown area.
ACE asks that the hearings be suspended and DEP be directed to hold informational o
workshops in each DEP District to explain to the public what they are proposing and that %yfollowing that, at a later date there be at least six public hearings statewide followed by asixty day comment period. The proposals are far reaching, complicated and are majorchanges to existing law. DEP has proposed too many regulatory changes at one time.
ACE believes these proposals give DEP too much discretion. ACE believes there shouldmore public involvement and participation at every step of the way in permitting and inevery DEP decision. These proposals attempt to eliminate the ability of the public toparticipate through streamlining, flexibility, and allowing DEP to waive, modify, andexempt when it suits them. ORIGINAL: 1975
ACE believes: ^ wilmarth
Sandusky- that any plans that are in the proposals which have not yet been written or formed must Legalbe done with the full participation and involvement of the public including publichearings, prior to the acceptance or approval of said plans- that DEP has sought to woo industry with linguistic detoxification to the extent that it ishard to trust DEP's definitions. We need workshops so DEP can stand up in public andexplain the new speak- that all CAFO operations must have individual permits- that all permits should have clauses requiring that radioactivity be tested for and thatzero radioactivity should be the standard
ACE opposes:
- the use of general permits. General permitting removes the public from the decisionmaking process. General permitting allows polluters to pass on their liability- allowing any toxics in point source discharge.- allowing general permits where toxics are involved- deleting warm water fishes as a statewide water use- effluent trading- the land disposal or land application of waste water. Waste water holds many pollutantsand pathogens and has not been adequately studied and should never be used for sprayirrigation nor land disposal.
Please read our full testimony. Thank you.
COMMENTS ON PROPOSED AMENDMENTS TO THE WATER QUALITYREGULATIONS : Chapters 92,93,95,96, and 97Conshohocken, PennsylvaniaBefore the EQB at 3 PMOctober 22,1998
By: Tina Daly for ALLIANCE FOR A CLEAN ENVIRONMENTMailing Address: 1880 Pickering Road
Pickering RoadPhoenixville,PA 19460
The ALLIANCE FOR A CLEAN ENVIRONMENT or ACE is a grass rootsenvironmental organization in the Pottstown area. I am pleased to present this testimonyon their behalf.
ACE asks the EQB to suspend this series of hearings on these proposed amendments.We ask that DEP be required to hold a series of at least one workshop in each DEPDistrict, followed at a later date by a series of at least one public hearing in each Districtand following that a 60 day comment period. We all know that the public has no ideathese regulations are being proposed, much less what is in them and how it will impactwater. What is the rush to get them passed? The public cares about water and deserves toknow about these proposals and the public deserves time to study and comment on them.ACE has great fiuth in the public. Does DEP?
There is no way that a group such as ours, that makes decisions based on the input ofmany individuals and board members, can adequately and thoroughly review andcomment intelligently on such proposals in the time frame allowed. A person must havethe proposed language, the existing language of five chapters, and copies of many otherdocuments and laws that are referred to, on hand when reading these proposals in order tomake sense of them. If DEP were open with the public and its concerns they would beglad to hold workshops and explain to us, who pay their salaries, what it is that is beingproposed.
There is no way that ACE can cover in ten minutes all that is the matter with theseproposals.
In general, the underlying attitude that is expressed in these proposals is sheer arrogance:DEP is taking on a lot of responsibility when it seeks to help polluters pass on theirliability to the public. These proposals are not very scientific, they are anti public health,they are short sighted, and they are anti-democratic. They are pro-industry, and full ofcorporate welfare provisions. These proposals give DEP far too much discretion.Please do not approve any part of these proposed changes.
In general, these proposals eliminate the ability of the public to participate in the decisionmaking process. They take away public scrutiny by streamlining the permitting process,by allowing DEP greater flexibility, by regulating that decisions can be made on a case-by-case basis, and by allowing DEP to waive, modify, and exempt when it suits them.
DEP has specifically asked for comment on a suggestion that additional opportunity forpublic comment on NDPES applications be provided in the regulations. ACE isinterested in public participation and involvement in all aspects of all work that DEP isdoing and not just in NPDES permitting. When dealing with permit applications, it isDEP sitting at the table with the applicants and not the public sitting there - this isbecause we have established DEP to represent us in such situations and to speak for us.This is not what is actually happening. Too often DEP considers itself as a separateentity or in fact as the friend of the applicant and not as a public servant. This is too badand this is why the public is now demanding to be given a place at the table. It isludicrous. We all know that with more public involvement and participation we will havebetter laws and more protection. ACE believes that the public has the right to know whatDEP is doing from the very start. Therefore, the DEP, not the applicant, should placelegal ads in LOCAL papers at every step of the permitting process - notices of intent,public hearing notices and in addition, DEP should write news releases explaining whathas been asked for, who has asked, etc. and the decision process that is going to take
There are several plans that are mentioned in the proposals that have not yet beendeveloped. If you approve of these proposals you are approving of a pig in a poke.Under no circumstances should any language be approved that allows plans to bedeveloped by DEP, at a later time, that would fall under these regulations unless there isfull public involvement and participation in the development of the plans. We need to beassured that any ancillary plans will receive automatic FULL public participationincluding notice from the earliest time that DEP takes the matter up to and including fullpublic hearings, without the public having to request, haggle and beg.
When DEP states that criteria are modified to "reflect the latest scientific information":we want to the see the scientific research information and we want to know who fundedit.
92.1 NPDES definitions: DEP has sought to woo industry with linguistic detoxificationto the extent that it is hard to trust DEP with definitions - they like to define toxicthings as being beneficial etc. We don't trust any of this section. This is the kind ofinformation that could be handled in a workshop. For example: the definition of apollutant has been revised and confused: exemptions from the definition areexcluded from one place and transferred intact to somewhere else. Read andwonder: 92,4(a)
92.2 Federal provisions not incorporated were determined to be "inconsistent" withDEFs NPDES program. Does this mean there is a federal program and we pick andchose what we want to obey in it? Why is DEP's program for a federal lawinconsistent with DEP regulations? Why do we drop the inconsistent part? Whynot change our law to match theirs?
92.3 Excluded from obtaining an NPDES permit are agricultural non-point sources. Weare opposed to this exclusion and also for the exclusions for dredge and fill, andsewage discharges into a sewer plant. There should be no exclusions especiallywhen the basic law is so weak.
92.5(a) ACE is opposed to permits by rule across the board, and especially for CAFOs.All CAFOs should have to have individual NPDES permits for every thing. In additionwe believe this is premature because the policies and regulations that guide PA inmatching the federal regulations for CAFOs have not been finalized.
92.11 Facilities should be constructed to meet all applicable requirements and standards.
92.13(b)(l) regarding determination for permit re-issuance: this is too lax. Appropriatecompliance actions have been relaxed so this won't do for the tough regulating that we
The DEP should not be enabled to issue NPDES permits which contain conditions thatensure compliance for out of compliance discharges.
92,41 The kind of language that runs throughout these proposals and which illustrateswhy there is so much distrust with them and with DEP is exemplified in thelanguage here: ".. .dischargers MAY be required to monitor and report all toxic,conventional, nonconventional and other pollutants ...IF requested by theDepartment...
92.51 DEP should require that all water quality standards be complied with. This is too
92.61 DEP can never require too much public participation. Public comment should besolicited when an application is filed and certainly before a draft permit ispublished.
92.71 (a) The public should be notified and given at least 30 days for comment whenpermits are transferred.
ACE believes that complete compliance histories of applicants and permit holders mustbe made public by DE P and must also be considered by DEP in the issuing of any and/orall transferring of permits.
92.73 ACE believes that DEP should regulate ALL radioactivity in ALL permits; that isto say that not only under NPDES but for all permitting, radioactivity should betested for and that zero radioactivity and emission should be the standard. Thereare too many places where concentrated radioactivity causes problems. Anexample would be at a landfill that accepts allowable limits of radioactivity inwaste, the radioactivity then concentrates in the landfill and the leachate and gasthen become radioactive. The leachate is then sent to the POTW where it joinsmore radioactive materials and is then permitted to go into a local water body inthe effluent, all without testing. The same goes for methane gas the is now beingpushed by EPA and DEP as good thing to burn as a supplemental fuel We allknow that radiation can not be burned off in boilers. Thus is radioactive matterspread about due to sloppy regulating and linguistic detoxification.
92.81 The heart of what DEP is doing with all this deregulation is expressed perfectlyhere: The present laws require that a point source not discharge toxic or hazardouspollutants. This provision is proposed to be revised to provide that effluentlimitations for toxic or hazardous substances may be established in the generalpermit. So - not only do we go from PREVENTION to CONTROL but we allowit to be done with a general permit so there is no trail. Mix it up and the liability is
ACE can not say strongly enough how much we deplore this proposal. There is no wayto track actions done under general permits. Please - do not allow general permits, and donot allow toxics in general permits. The way to get around this is through redefining andlinguistic detoxification and this is exactly why we do not trust any of the definitions.
ACE is opposed to the use of general permits where high quality waters are concernedand beyond that where any water is concerned. We are opposed to general permittingaltogether. DEP needs to retain language that requires documentation that any and allpermits will not violate water quality. It stands to reason that ACE opposes the use ofgeneral permits in impaired waters as well.
92.82 ACE is opposed to the use of General Permits. General permitting removes thepublic from the decision making process. General permitting allows polluters topass on their liability to some other entity.
What is the definition of "significant" history of noncompliance?
93.4 ACE believes that that DEP should retain language that protects all our waters aspotable water sources. With regulations such as are proposed we need all theprotection possible for our waters.
ACE is opposed to deleting warm water fishes as a statewide water use. Many streamswill not get on the list and, therefore, there will be no protection for those streams. Weneed more protection, not less, so keep the language that means that warm water fish area statewide water use.
93.5(e) The policy regarding mixing zones has never come under public scrutiny. IfDEP wants to institute a mixing zone policy it should do so with full public involvementand participation and then incorporate the policy into these regulations. This is one of thepigs in the poke we spoke of earlier.
93.5 In stream flow and habitat are not covered by regulations. We need to protectinstream flow now. DEP should develop instream flow and habitat criteria with fullpublic participation and then incorporate them into these regulations.
96.4 ACE wants this section to be changed to include nonpoint source problems. Theregulations do not consider flow conditions for rain induced pollution. Finally,clarification is needed as to whether these design flows are only for impairedwaters or all waters. This is very important because of all the residual andmunicipal waste that we are spreading around that can contribute to nonpointsources.
Another pig in a poke: this section gives DEP authority to approve effluent trading withvery few requirements. ACE is opposed to effluent trading to begin with, but having saidthat, we are also opposed to allowing DEP this much authority in a situation where theprocedure has not been clarified. DEP needs to solicit and use full public involvementand participation in establishing a procedure and then incorporate it into the regulations.
96.5 ACE is totally opposed to the land disposal of wastewater. We care about thequality of our soil and groundwater. The current trend to spray irrigate is entirelypremature. All the studies we are familiar with discuss the health issues involved inre-using wastewater. We would like the DEP to show the public what informationthey are using and on which they have based the decision to require wastewater tobe land applied. We would like DEP to certify to the public that each drop of waterthat is so used is clean and safe in the normal sense of the words. This is a waterproblem and an air problem. Land disposal of wastewater is a back end solutionjust as the land application of sludge is a back end solution for what to do withsludge. I notice this is called "disposal" and not re-use or application. We muststop using every water body for waste disposal and we must stop using every grainof soil as a potential depository for the same. Go to the front end of the waste waterpipe and solve the problem there - where the polluter is passing off his problem andliability to the public or farmer or golf course user.
Chapter 97 is deleted. Well, we need help to understand what that means. It is my guessthat it doesn't mean anything positive for the environment. This in a state that importsmore waste than any other, that uses wastes for land remediation, fertilizer, waterreplenishment and so on. This from a DEP that is also changing its residual andmunicipal waste regulations, which by the way will have enormous impacts on water
quality, and this from a DEP that is in such a hurry to pass all these proposed changesthat it can not take time out to explain what it is doing.
Please: do not approve these proposals. Please include my comments in the hearingrecord Thank you.
Presented by Tina Daly for ALLIANCE FOR A CLEAN ENVIRONMENT
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CLEAN WATER ACTION
September 30,ORIGINALMIZNERCOPIES:
1998
Wilmarth
SanduskyLegal
§James M. Seif, ChairpersonThe Environmental Quality BoardPO Box 8477Harrisburg PA 17105
Dear Mr. Seif and EQB Members:
I am writing on behalf of Clean Water Action's 80,000 members in Pennsylvania to iextension of the comment period for DEP's proposed new Water Quality Standards and ToxicsManagement Strategy (Chapters 92, 93, 95, 96, and 97; and Chapter 16).
These changes are of immense importance and will affect the manner in which we protectwaterways in our state for years to come. In addition, the changes are long and exceedinglycomplex, with the Water Quality Standards alone covering 60 pages in the Pennsylvania Bulletin.
In light of the importance and complexity of these changes, it is imperative that the public getadequate time to review and comment on the changes. The original 60 day comment period issimply not long enough for changes of this complexity.
I strongly urge you to extend the comment period for at least an additional 60 days in order toallow adequate time for public review, analysis and comment.
Please let me know of your decision in care of our Philadelphia office at the address below.
Sincerely,
Robert WendelgassPA State Director
- 2 iSSR
S£NVjSCi»H£aiTAL QUALITY C U
37 North 8th Street, Aiientown, PA 18101 • (610)434-9223 • FAX (610) 434-5790- — = ? 1128 Walnut Street, Suite 300, Philadelphia, PA 19107 • (215) 629-4022 • FAX (215) 629-3973
607 Penn Avenue, Suite 212, Pittsburgh, PA 15222 • (412)765-3053 • FAX (412) 765-17374455 Connecticut Avenue NW, Suite A300, Washington, DC 20008-2328 • (202) 895-0420 • FAX (202) 895-0438
©
Pennsylvania Environmental NetworkVoices for Environmemntal Justice
93SEP f8 A; i l ! : r , c
ORIGINAL: 1975MIZNERCOPIES: Wilmarth
Sandusky IfSeptember 14, 1998
James Seif, SecretaryDepartment of Environmental Protection400 Market Street
Harrisburg, PA 17101-2063
RE: Proposed Ruiemakings
Dear Secretary Seif,We have become aware that the DEP has proposed extensive amendments to theEnvironmental Quality Board on three sets of Regulations: Residual Waste, MunicipalWaste, and Water Quality. There are three hearings scheduled for each of theseproposals: first hearing is set for September 16th in Conshohocken.
It is our opinion that too much is being proposed at once and that the public is unaware ofthese proposals and the extent of the proposals and of what they might mean. Therefore,we are requesting that the department and EQB slow down the process and allow plentyof time for public review and hearings.
We propose that the DEP schedule a minimum of one workshop in each DEP District oneach Proposed Amendments. In addition, we request that there that there be a minimumof six public hearings held several weeks after the workshops. This will give theinterested public time to learn what is included in the proposals and to study theproposals.
At the Pennsylvania Conservation Network held in Harrisburg on Friday September 11,1998, our Sludge Team Chair, Tina Daly, made these proposals to Dave Hess who was atthe Meeting on behalf of DEP. We assume that he has shared these ideas with you.
We look forward to hearing from you regarding this request and proposal.
Sim
.XI
C.C: Susan Wilson, Citizen's Advisory Council
• r?iicL";v;i.ALLIANCE FOR A CLEAN ENVIRONMENT
549 EAST VINE STREET : 3 SEP 2b Ail 10= !•• 5STOWE, PENNSYLVANIA 19464
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ORIGINALMIZNERCOPIES: Wilmarth
SanduskyLegal
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September 22,1998
James Seif, SecretaryDepartment of Environmental Protection400 Market StreetHarrisburg, Pa. 17101-2063
RE: Proposed Regulation Changes
Dear Secretary Seif:
DEP proposed extensive amendments to the Environmental Quality Board on three setsof regulations: Residual Waste, Municipal Waste, and Water Quality. Hearings werescheduled for each of these without giving the public enough time to learn what isincluded in the proposals, much less time to study what these proposals might mean tothe public health and safety.
It is definitely not in the pubic interest to propose so many significant changes at onetime. Pennsylvania is already having serious waste problems that have the potential toadversely affect our air and water. Governor Ridge has finally put a moratorium onlandfills, which shows he recognizes the fact that Pennsylvania already has a substantialproblem. To rush into multiple changes that could make this problem worse seems atbest ill-advised, and at worst irresponsible. Why not impose a moratorium on changes toregulations as well? Why isn't just one of these issues being evaluated at a time? Whyhave no workshops been held to explain these proposed changes to the public before thehearings?
We are requesting that DEP hold a separate workshop in our district on each of theseproposed sets of regulations, with a hearing at least several weeks later, fallowing each
P^ workshop on each separate issue.
oo The public has a right to understand fully these issues of great importance to theirc<2 environment and consequently their health. People have a right to take part intelligently3 _ in this decision making process. PLEASE REVISE THE SCHEDULE FOR THESE- ^ HEARINGS. FIRST PROVIDE A SEPARATE WORKSHOP ON EACH ISSUE
THEN ALLOW ENOUGH TIME BEFORE SCHEDULING A HEARING ON THA TISSUE.
Anxiously awaiting your response!
Sincerely,
Dr. Lewis C. CuthbertPresident, Alliance for a Clean Environment
Copies: Governor Tom RidgeSenator James GerlachSenator Mike O'PakeRepresentative Tim HennesseyRepresentative Dennis LehPottstown MercuryPhiladelphia Inquirer
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Subj: Re: Sludge!Date: 98-03-06 12:04:18 ESTFrom: PSorensunTo: SandyHCSmi
We don't approve of Municipal Waste Sludge being put on farmland.
Philip & Jan Sorensen
Fnday March*, 1998 Amwic*Ondht. SmtdyHCSmi f t * , r f
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<*JZ*°,n a r P , =n CHESAPEAKE BAY FOUNDATION
LenncalJ. Henderson
WiitiamC Baker
MichadF.Hinhnefd.PhD
EX OFFICIO TRUSTEESGovernor Thomas/.RidgeGovernor Parris N. GlendeniogGovernor Jame* S. Gilmore. HIMayor Marion BarryHal C. B. Clagett - Clagett TrusteeJoanne S. Berkley- Bay Care ChapterMarilyn W Layer - York Chapter
TRUSTEESMynha L AllenDonald F. BoeschGeorge W. Brown. PhD.Louisa C.DuemlingCarenEGjotfclty
Susan Taylor HansenEdward M. Holland
H ' F . (Gerry) Lenfest
KadMrine Turner Mean
G.Sttdt PhillipsGeorge G. Phillips. Jr.Robert M PinkardMarie W.RidderWillcoxRufTin.Jr..M.D.
Edmund A. Stanley. Jr.
Aileen Bowdoin TrainMichael WatsonJames C. Wheat, mL. Dondson Wright. Ph.D.
HONORARY TRUSTEES
T. Marshall Duer. Jr.C. A. Porter HopkinsCharloMcC. Manias
Blaine T.PhillipsGodfrey A. Rockefdkr
C.Trowbridge StrongWilliam W.Warner
980CU1 MUl'5* jMj_§
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Environmental duality BoardP. O. Box 8477Harrisburg, PA 17105-8477
Resource ProtectionEnvironmental Education
ORIGINAL: 1975MIZNERCOPIES: Wilmarth
ENVIRONMENTAL QUALJTY & « & : S a n d u s k y
Re. 25 PA Code Chs. 92, 93 and 95-97 on Water Quality, ProposedChanges (PA Bulletin Aug. 29,1998)
Octobers, 1998
Dear Board Members:
We respectfully request to have the comment period on the proposedchanges to 25 PA Code Chs. 92, 93, and 95 - 97 on Water Qualityextended beyond the October 28 deadline.
Due to the breadth and complexity of the proposed changes, the 60 daycomment period is insufficient to be able to adequately analyze andrespond to the proposal. We would appreciate if an additional 60 dayswould be added to the public comment period.
Thank you for your consideration in this manner.
Sincerely,
me E. ChinchilliPennsylvania Executive Director
J«4e»eE.ChindHUi
Pennsylvania Office: Old Waterworks Building, 614 N. Front Street, Harrisburg, Pennsylvania 17101,717.234-5550, fax 717.234-9*32Headquarters Office: 162 Prince George Street, Annapolis, Maryland 21401,410.268.8816, fax 410.268.6687 ^&L>
Maryland Office: 111 Annapolis Street, Annapolis, Maryland 21401,410.268.8833, fax 410.280.3513 fggj \Virginia Office: 1001 E. Main Street, Suite 710, Richmond, Virginia 23219. 804.780.1392, fax 804.648.4011 \%£?/
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Environmental Quality BoardP.O. Box 8477Harrisburcr, PA 17105-8477
Dear DEP,
% ^ _ ,ORIGINAL: 1975
COPIES: Wilmarth
Sandusky
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We are writing this letter to urge you to stop the roll-back ofwater pollution regulations in the Regulatory Basics Initiative.
In changes you propose to Chapters 92, 93 and 96. we see anegative impact on Pennsylvania's clean water. Our regulationsshould not be rolled back in the interests of developers and otherbusinesses who donate large amounts of money to politicians.
Please do your iob to protect our water with the currentregulations and eliminate loopholes that allow pollution of our
Sincerely,
Nancy J. Lezark
11 Beatty Rd.Clarksburg, PA 15725
P.O. box 8477 • txirrisburf|>^X71(5-6pl^72» 14017)787-4526
Mr. Robert E.Nyce, Executive Director ORIGINAL: 1975 g- % :Independent Regulatory Review Commission Mizner ^ ^ ^ j ,
Harrisburg, PA 17120 Legal8 * *' °
Re: Proposed Rulemaking - Water Quality Amendments (Chs. 92, 93, 95, 96 & 97) (#7-338)
Dear Mr. Nyce:
The Environmental Quality Board has received comments regarding the above referencedproposed rulemaking from the following:
1. Alexander P and Nancy J. Lezark
These comments are enclosed for your review. Copies have also been forwarded to the Senateand House Environmental Resources and Energy Committees. Please contact me if you have anyquestions.
Sincerely,
Sharon K FreemanRegulatory Coordinator
Enclosure
RECYCLED PAPERS
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Environmental Quality BoardP. O. Box 8477Harrisburg,PA 17105
Gentlemen:
I oppose the new proposed water quality standards and toxics strategy.
Please strengthen the standards that protect our water, not weaken them. The Department of-
Environmental Protection's proposed toxics strategy is too weak and will allow even more toxic
discharges into our waters. PLEASE STOP THESE NEW STANDARDS!
Sincerely,
Patricia M. Payes409 Crescent RoadWyncote,PA 19095
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ORIGINAL: 1975M J Z N E R • • • ' - . .
COPIES: Wilmslih
Sandusky
812O BROOKSIOE ROADELKINS PARK, PA M A T {OfQ ^ *7 M#
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Tuesday, October 6,1998 fiSfev'a Umrt.ORIGINAL: 1975
WH
Environmental Quality Board MIZNER
PO Box 8477 COPIES: Wilmarth
iUJXLisV:
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ENVIRONMENTAL QUALITY BOARD jHamsburg, PA 17105 Sandusky
To whom it may concern,I am writing as a concerned citizen who is worried about the conditions of our
water. I am urging you to strengthen the standards that will protect our water, notweaken them. The Dept of Environmental Protection's proposed toxics strategy is tooweak and will allow even more toxic discharges into our waters. I want these newstandards stopped.
Thank you for your consideration in this matter and I would appreciate aresponse to this letter.
Sincerely,
James P. CMalley
748 Hawthorne Drive
Pittsburgh, PA 15235-4147
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ORIGINAL: 1975MIZNER
EdwardBrezina Octl3,1998 COPIES: wilmarthPADEP JewettPO BOX 8555 SanduskyHarrisburg, Pa 17105 &
Mr. Brezina,
This is a letter referring to the proposal from the DEP wanting to weaken thewater quality standards. We are supposed to be more environmental aware of issues andtake action on protecting our waterways, they are a precious resource. To have the DEPwant to weaken standards just makes me sick. They are not doing their job. We arealready second in the nation for toxic waste in our waterways, apparently the state wantsto be number one. I want an answer on why the DEP wants to roll back the waterstandards, and why they want to take away our right to be involved in the permit process.I want these new standards stopped. We need to strengthen the standards that protect our
Sincerely, Angela Radigan
Please respond to:Angela Radigan231 Portman LaneBridgeville. Pa 15017
It,
68:1 Wd 8213086
M E M O R A N D U M980CT2I AMIhLB
I N T E R O F F I C E
, REVIEW COMMiSSIONORIGINAL: 1 9 7 5 Date:MIZNER F r o m :COPIES: Wilmarth
Jewett Dept :Sandusky Te l No:
Brezina.Edward ( Brezina.EdwardOAl.dep.state.pa.us@PM
13-Oct-1998 09:07pm ESTCharles F Jacobson, Srchaj [email protected]@PMDF@DER0 0 3
Subject : Chapter 16
Charles F. Jacobson, Sr.2A Kelsey S t .Wellsboro, PA 16901-1321
Mr. Edward Brezina;I am incensed with the steps you and your department seem so ready totake to reduce the water quality of Pennsylvania. We already have morepollution and poisoned water than we should have. The idea thatrelaxing the standards and regulations can in any way be good for thepeople of this state is ridiculous. We have had more than our share offish kills and incidents of poisoned well water. We certainly do notneed more. I would hate to think that the decisions you arecontemplating are business and money driven. We are being assaultedfrom all sides with garbage from out of state and the practice ofspreading sewage-sludge. We cannot afford to have the government wedepend on make it easier for business and industry to indiscriminatelydump their waste chemicals and pollution where-ever they wish as long asit adds to their bottom line. Please, in the name of decency andhonesty do not make any changes that will most certainly reduce ourwater quality. The health and welfare of the people is far more im-portant than more wealth for business. Do the right thing.
Yours truly Charles F. Jacobson Sr.
Edward Btezina ; ' ^ Octl3,1998 \ *
Harrisburg, Pa 17105
Mr. Brezina,
This is a letter referring to the ridiculous proposal from the DEP wanting toweaken the water quality standards. Aren't we supposed to be more environmental awareof issues? We are already second in the nation for toxic waste in our waterways,apparently the state wants to be number one. I want an answer on why the DEP wants toroll back the water standards, and why they want to take away our right to be involved inthe permit process.I want these new standards stopped. We need to strengthen the standards that protect our
Sincerely, Alicia M. Scott
234 Portman Lane MIZNER 1 9 ? 5
Bridgeville. Pa 15017 COPIES : wilmar th
Sandusky
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Edward BrezinaPADEPPO Box 8555Hamsburg, Pa 17105
Mr.Brezina,
Oct. 15,1998
-
ORIGINALMIZNERCOPIES: Wilmarth
Sandusky
I have recently found out that the DEP is proposing to roll back the waterstandards allowing industries to come in our state and pollute more, plus eliminate thepublics right to be involved in the permit process. The obvious question is why weakenstandards instead of strengthening them. Water should be treated as a precious resourcenot a dumping ground for toxic chemicals. The DEP is here to protect and not destroy. Iwant this ridiculous proposal stopped
Sincerely,
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SIERRA CLUB
JEFF SCHMIDTGovernmental Liaison
ppr^pv^nPENNSYLVANIA
ENVIRONMENTAL LOBBY
9 8 OCT 21 mil: 5k
mra,.,::«^mgr %Environmental Quality Board400 Market St. 2"" FloorHarrisburg, PA 17105-8457
October 9.1993
Dear Board Members:
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ORIGINAL: 1975MIZNERCOPIES: Wilmarth
Sandusky
Suite 404600 North Second Street
I"We respectfully request to have the comment period on the proposed changes to 25 PACode Che. 92,93, and 95 - 97 on Water Quality extended beyond the October 26deadline.
Due to the breadth and complexity of the proposed changes, the 60 day commentperiod is insufficient to be able to adequately analyze and respond to the proposal Wewould appreciate if an additional 60 days would be added to the public comment period.
Thank you for your consideration in this manner.
Sincerely,
Jeff Schmidt
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ORIGINAL: 1975MIZNERCOPIES: Wilmarth
14-Oct-98 Jewett O r ^Sandusky " c L<CT ? P<
To whom it may concern, ^ L e t t ^ 8 ^ _
I am writing to inform you that I strongly oppose THE MEW PROPOSED UVWATER QUALITY STANDARDS AND TOXICS STRATEGY. It is important toStrengthen the standards that protect our water, NOT WEAKEN THEM. DEP'sproposed toxic strategy is too weak and will allow more toxic discharges into our water.PROTECT OUR WATER! STOP THE ROLLBACK!
Sincerely,
Ke%D. Keck
ORIGINAL: 1975 Drv->r-,.14-Oct-98 Form l e t t e r htZiJ-n/rr)
To whom it may concern, " v u^ * ^8 p|f /. j
I am writing to inform you that I strongly oppose THE NEW PROP^grm%j;rylW%yWATER QUALITY STANDARDS AND TOXICS STRATEGY. It is important f^SSOVStrengthen the standards that protect our water, NOT WEAKEN THEM. DEP'sproposed toxic strategy is too weak and wilt allow more toxic discharges into our water.PROTECT OUR WATER! STOP THE ROLLBACK!
<^S4ncere.ly, j / , *
cZbidneM. Cerino
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1 iOCi 2?ifaWwne Chapter Trout Unlimited"SUPPORT QUALITY TROUT FISHING"
c : A ^ P.O. Box 351
ORIGINAL: fcrfs. How.^. Pennsylvania 18428
MIZNEROctober 14, 1998 COPIES: Wilmarth
Sandusky
Environmental Quality Board L e 8 a l
P.O. Box 8477Harrisburg, Pennsylvania 17105-8477
Dear Board Members:
I am writing you on behalf of the Pike-Wayne Chapter of Pennsylvania TroutUnlimited, concerning the proposed regulatory changes dealing with water qualitystandards and permitting, as advertized in the Pennsylvania Bulletin, Volume 28, Number35, dated Saturday, August 29,1998, a/id located at Part III, pages 4431 through 4497of the Bulletin. This proposed rule making addresses parts of 25 PA. Code Chapters 92,93, 95-97, Water Quality.
Our Chapter appreciates the information that the Pennsylvania Bulletin provides.It allows,the public and in particular our organization the opportunity^ comment andhave a hand in the rule making process. We would like to make the following commentsin reference to the above mentioned Code Chapters.
Although the Bulletin states that the "regulatory revisions attempt to streamline andclarify regulatory requirements, update the regulations to be consistent with Federalregulatory changes and consolidate certain chapters." (page 4431 9th paragraph, secondcolumn), we believe it is in the best interest to Pennsylvania and its citizens to be aboveFederai standards. The United States government has taken the position that a state willnot go below its standards by providing laws. Federal water protection laws provide forthe very minimum that a state must follow in order to protect its citizens through waterquality standards. Pennsylvania's standards should be as high as practicable, and farabove the minimal standards set by Federal regulation and law.
Concerning Chapter 92. NPDES Permitting, Monitoring and Compliance, ourresponse to the rule proposals are;
- Section 92.2d: the cap for total, residual chlorine (O.Q\5 mg/l) should bemaintained.
- Section 92.51: the standard conditions iri ati permits should read that compliancewith all water quality standards is required.
- 1 -
- Section 92.81: toxic substances should always require an individual permit. Ageneral permit does not allow for an adequate review for toxic substance whichcould adversely affect Pennsylvania's waters. General permits should not be usedin conjunction with high quality or exceptional value designated waters. All PADEPpermits should continue to include documentation that the general permit will notviolate water quality standards. Waters that-exhibit water quality problems shouldnot be used in conjunction with general perrriits These impaired waters shouldbe addressed with other than a general permit such as an individual permit.
Concerning Chapter 93. Water Quality Standards, our response to the ruleproposals are ;
Section yj.<+: An waters of Pennsylvania should continue io receive the status ofpotential potable water sources. Since historically most waters were potable, ourCommonwealth should do nothing short of attempting to regain the highest waterquality for as many waters as possible. It is our right and heritage to demandnothing less and thus retain this status as is.
- Section 93.4: We are opposed to the change in the elimination of "warm waterfishes" as a Statewide use. Many coldwater fisheries begin as warmwaterimpoundments, ponds and wetlands. Therefore, we recommend no change inthis regulation because of the intrinsic protection value to warm water fishes andto the connection in many instances to coldwater fisheries
- Section 93.5(e): PADEP should retain its mixing zone criteria as currently statedin this section.
- Section 93.6: This section should include tfnew development in which instreamflows and habitat criteria have a set'standard' and therefore, measurable andregulated. Because of the indiscriminate use by water uptakers (examples are golfcourses, ski resorts, PennDot highway work) and the consequential negativeimpacts to the downstream areas biotio.and abiotic, from the point of extraction,we suggest that this new criteria be included in this section.
Concerning Chapter 96 Water Quality Standards Implementation, our response tothe rule proposals are ;
- Section 96.4 (h): Non point source pollutants should be addressed. Manywaterway pollution problems originate at non; point sources. In addition, thissection portion only addresses problem loading at design flow standards. Underhigh flow conditions, waterways accept non point source pollution loads. Aseparated section should address, through a: modeling type, both the non pointsource pollution loading and associated high water conditions
-2-
Thank you for taking the time to read and consider our comments, and for theopportunity to be a part of the rule making public comment decision. We trust that theEnvironmental Quality Board will produce just and fair Code Chapters that will enhancethe environment for the citizens of the Commonwealth of Pennsylvania.
Sincerely,
Wayne Poppich, Board of DirectorsPike-Wayne Chapter , Trout Unlimited
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