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Reprinted here is an appeal from Williamsport resident, Jon Bogle, and a letter of petition to our DEP. Please do your part...
Below is a letter to DEP opposing the granting of a permit to operate a waste water discharge plant at Water Tower Square. In total, there are ten plants in the works which will dump four million gallons of the gas drilling industry’s waste water, containing millions of pounds of dissolved salts, into the West Branch Basin every day.
The thirty day period DEP has set to comment on this permit ends on June 1st. A strong response is needed.
This is the first issue where the gas industry will try to transfer our quality of life to their bottom line. We need to send a clear message that we won’t stand for it. The Gas industry will do what is necessary to get to the gas. If we demand the state of the art treatment of our landscape and environment we will get it. If we don’t--they will treat rural Pennsylvania as a third world country. Our quality of life is not their concern.
You can simply print out this letter, add your name and address and send it in. Or, you can modify it in any way you want, add to it, or write your own. It is your letter and each person, not just each address, is entitled to send one.
Many of us believe that DEP is under political pressure to grease the way for the gas industry. A strong public response will help to counteract that pressure and loosen the bonds of DEP’s better angels.
If you have persons on your e-mail list who may be willing to help, please send this on to them.
201 E 3rd St.
TO: Pennsylvania Department of Environmental Protection
Water Management Program, Permit Section
208 West Third Street, Suite 101
Williamsport, PA 17701-6448
RE: Opposing the granting of a NPDES permit to operate, PA0233650,
Industrial Waste, TerrAqua Resource
Management, LLC, 1000 Commerce Park Drive, P. O. Box 487,
Williamsport, PA 17703-0487.
Also opposing NPDES permits for the nine other similar facilities in
the West Branch Basin which DEP
has knowledge of that are preparing to submit NPDES permit
applications or have already done so.
FROM: YOUR NAME/ADDRESS HERE
The TerrAqua proposed facility at Water Tower Square is clearly a transfer of the Susquehanna Riverʼs water quality to the financial bottom lines of the gas industry and to the facilityʼs owners. It will put hundreds of thousands of pounds of dissolved salts into the river at Williamsport-- every day.
It will not remove most of the dangerous chemicals in the water from gas well fracturing operations.
As is the case with the other nine plants being proposed for the West Branch basin, it will be little more than a dilute and dump operation. Pennsylvaniaʼs rivers and environment deserve the same state of the art treatment for this waste water that the gas industry has available and uses in other places. Our rivers havenʼt yet recovered from the damage inflicted by the coal industry over a hundred years ago. We need DEP to protect them from being used as a chemical dump.
Pennsylvaniaʼs DEPʼs new policy statement, Permitting Strategy for High Total Dissolved Solids (TDS) Wastewater Discharges April 11, 2009 clearly describes the damage of continuing to dump dissolved solids (salts) into our rivers. The new strategy, which goes into effect on January 1, 2011, will not permit new large volume dischargers of dissolved salts. It also clearly states that any facilities seeking a licence until then must show they will possess the technology to remove salts from the discharge. A capability TerrAquaʼs application doesnʼt have. The April 11th Strategy policy is cited below:
(a) DEP will not issue permits for new sources of High-TDS industrial waste unless the applicant proposes to install adequate treatment for TDS on or before January of 2011.
TerrAqua, which is still at the conceptual, approval seeking stage, will begin discharging large quantities of dissolved solids into the Susquehanna river almost exactly when DEPʼs new policy goes into effect. It is difficult to understand why TerrAqua would go forward with this application unless they are expecting to be granted an exception to the new regulations when they go into force.
It is also clear that TerrAquaʼs facility isnʼt a critical component of the new gas exploration industry because at a 400,000 gallon maximum capacity it doesnʼt begin to address the volumes of anticipated waste water from this industry. Indeed, even if all ten of the new high-salt dischargers on the Susquehanna were approved, they would only account for 20% of the needed capacity.
Estimates from the industry indicate that demand for brine water treatment in Pennsylvania will reach approximately nine Million Gallons per Day (MGD) in 2009, 16 MGD in 2010, and 19 MGD in 2011.
Estimates from the Susquehanna River Basin Commission are 20 MGD for that same timeframe.
The April 11th report makes clear that the Susquehanna, like other rivers in Pennsylvania, is already challenged from discharges and acid mine drainage.
Many of the areas where the drilling for natural gas is proposed have a history of mining activity and are affected by Abandoned Mine Drainage (AMD). Brine and fracturing wastewater have high concentrations of dissolved solids, and considering the already elevated levels of dissolved solids in the AMD-affected surface waters, the need to stringently control these dissolved solids likely will prevent other pollutants from exceeding water quality standards on a cumulative basis.
...watershed analyses conducted by DEP of the West Branch of the Susquehanna River watershed has documented that it is also severely limited in the capacity to assimilate new loads of TDS and sulfates.
Local biologists have estimated that several million fresh water clams live in each mile of the Susquehanna River. These serve to filter the nutrients out of the water which are
so harmful to the Chesapeake Bay.
Without this natural filtering our local cost of reaching acceptable nutrient levels for the Chesapeake Bay will be higher. Again below, from the April 11th policy:
The major concern associated with high TDS concentrations relates to direct effects of increased salinity on the health of aquatic organisms.
It is clear that TerrAquaʼs NPDES permit application, and the other nine possible facilities, are in direct opposition to the strategic intentions of DEP for maintaining water quality in Pennsylvaniaʼs rivers and streams.
There is no ethical or logical reason why this permit should be granted.