Commentary on Coventry landfill UD3 proposal by Peggy Stevens

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I write today as a follow-up to the public DEC hearing of August 18th in Coventry on the proposed NEWSVT Coventry landfill treatment facility that would attempt to filter toxic substances from liquid collected in the Under Drain of the Phase III section of the landfill.

As was noted by several in attendance last Thursday night in the Coventry Community Center, very little if any public notice was provided for the meeting, and definitely no notice in local newspapers or posting in the town hall itself.

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You had to know how to get into the ANR Electronic Notice Board in order to try to find notice of the meeting.

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Anyone who has tried knows how frustrating and even impossible that effort can be. One Coventry resident was heard to say that he had been in that building to vote a week earlier and seen no notice of the upcoming hearing.

Was it possible, as another meeting-goer wondered, that the lack of notice was intentional?

In spite of that, turnout was pretty good, and almost to a person the questions directed to the moderator, DEC staff person Kasey Kathan, were incisive and highly critical of the pilot project design and the process involved in developing the project.

Many of those present were also in attendance at last Fall’s public hearing on the Draft Leachate Pretreatment Permit, a much bigger and potentially even more environmentally threatening project than the UD3 plan under discussion last Thursday.

No response to public comments about that proposed project, submitted ten months ago, in October 2021, has been provided to date.

Questions about the inadequacy of the speculative UD3 design- which uses the cheapest and least effective filtering material, Granulated Activated Charcoal, to filter the exceedances of “safe” limits for PFAS “forever” chemicals, Arsenic and Cadmium found in the liquid collected in the underdrain for Phase III- were met with the repeated response that the design “meets the existing rules and regs of the DEC.”

Concerns were also raised about the fact that the design calls for used filters (full of toxic PFAS chemicals, Arsenic and Cadmium) to be returned to the landfill, further concentrating these poisons in leachate generated in the future.

Science calls for these spent filter materials to be solidified and stored in dry vaults to prevent future environmental contamination by these toxic substances. Science is being disregarded.

The fact that recent EPA guidance about PFAS chemicals states that there is no known safe level of exposure for many of the bio-accumulative 9,000 PFAS chemicals (and that the maximum limit for PFOA and PFOS- the most common of these toxins- is now 4 parts per quadrillion!) seemed not to be a concern of DEC, who stated that it would be the standard in place at the time the ten-year permit was issued that would apply. (The current standard for PFAS in drinking water is 20pptrillion for just five of the thousands of PFAS chemicals.)

This was astonishing news to many, who wondered out loud how that could be the case, and why the most stringent standard would not be the one chosen today, or why NEWSVT would invest a small fortune in a technology that was obsolete before it even began to be built?

Passing references were made to questions raised in years past, like what is the cause of the cancerous lesions in the up to 40% of Brown Bullhead in Memphremagog; or why the State doesn’t require and perform more frequent monitoring of landfill operations; or who was funding the construction- not public money, right?; or how much money has been set aside to cover costs of closing the landfill and continuing to collect and dispose of leachate for decades to come?

No truly adequate response to any of these questions was forthcoming.

One question asked several times over by different attendees, was about the lack of objective ANR/DEC oversight of the project in question.

“Seems like the tail (NEWSVT) is wagging the dog (DEC), or “the fox is guarding the henhouse,” or that “this is an incestful situation. Why is NEWSVT allowed to choose the technology and set the standards for monitoring for the health and safety of the environmental, people and wildlife? Isn’t that the job of the DEC?”

For many, the greatest concern is that this project brings us one step closer to siting the bigger and more environmentally dangerous “pilot” Leachate Pretreatment facility in Coventry. importing millions of gallons of leachate monthly for “treatment” in addition to the millions of gallons generated monthly on-site.

This would add to the environmental burden and threat already posed by the ill-sited landfill, uphill from the Black River and Lake Memphremagog.

Two citizens from Sherbrooke, Quebec, representing the environmental group Memphremagog Conservation Inc., solemnly and respectfully reminded the audience that any future discussions and decisions must include the citizens of Quebec, 175,00 of whom, after all, get their drinking water from Lake Memphremagog.

This was a reminder that there is a current ACT 250 moratorium on treating leachate anywhere in the Memphremagog watershed.

In the opinion of those in attendance, this ban should be made permanent and the landfill should be closed as soon as the State develops a state-run landfill, out of the Memphremagog watershed, farther south where most of the State’s trash comes from, to include a scientifically sound, state-of-the-art leachate treatment facility.

It may very well be, as one of the last commenters suggested, that the only way to correct the obvious failure of the ANR/DEC to “protect, preserve, restore and enhance” our natural resources will be through legislation.

In that case, I urge all concerned citizens to send their comments by September 2nd
To: [email protected] Subject: Public Comment for permit # OL510-2022-2

Then send a copy to your local legislators whose email addresses can be found when you search https://legislature.vermont.gov/people/all/2022.

Just click on the name of your representative.

Peggy Stevens
Charleston, VT

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