Fwd: land fill expansion could mean frack waste

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Rita Yelda

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Mar 9, 2015, 11:32:57 AM3/9/15
to citizens-against-fracking-, dontfrackcha...@googlegroups.com

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From: "snowshoefilms .com" < snowsh...@hotmail.com>
Date: March 5, 2015 at 1:27:37 PM EST
To: "snowshoefilms .com" < snowsh...@hotmail.com>
Subject: land fill expansion means frack waste

LANDFILL EXPANSION: We can make a difference.

The DEC judge at the official DEC hearing on the landfill last night (March 4, 2015) said  if letters were mailed by March 11 to the above address, they will be included in her decision about whether to double the size and possibly the volume of the public landfill.

A DEC rep I spoke to said they may have a new category to investigate re the landfill expansion due to the several letters on the subject. If the  DEC gets a total of 20 letters on a subject, in this case, expressing concern for the materials being trucked in from Pennsylvania that may include radiactive fracking waste (brine, cuttings, drilling mud and construction demolition debris) -- then they will open another area of investigation  -- ie radioactive fracking waste being trucked in to dump here. We presently are aware of 9 letters on the subject of fracking materials from Pa. sent to DEC.

As several people noted at last night's hearing "Why ban fracking in NY State - then allow the very waste that is banned to be dumped here?"

Below is part of my testimony:

Do we receive high volume hydraulic fracturing waste at the Chautauqua County Landfill?

The primary reason for loss of public and private water sources in Ohio due to storage of radioactive high volume hydraulic fracturing waste  is because real  time measurements of radiation using a Geiger counter at a landfill or water treatment plant  - measures gamma rays from black shale generated waste which contains naturally occurring radiation from radium, radon and plutonium.

The problem is black shale radiation is Alpha and Beta radiation which cannot be measured with a Gamma Geiger counter.  When drilling mud, HVHF cuttings, construction demolition debris or brine are stored or the leachate is sent through a water treatment plant in Jamestown the water soluble radioactive materials are concentrated but will not be discernible with an on site Gamma reading Geiger counter.

For an accurate reading, samples must be sequestered in closed containers for 21 days minimum to acquire their constituent parts to determine radioactivity.

Minimum allowable radiation is 5 pico curies per gram or in water 5 pico curies per litre.

Are we testing the materials coming from Pennsylvania to our landfill, our leachate, our water after treatment for Alpha and Beta radioactivity? What regulations does New York State have in place to address Alpha and Beta radioactive waste?

Karen Harvey   716 753 7062

Please send your comments  regarding the expansion of the Chautauqua County Sanitary Landfill to: David Denk,  Regional Permit Administrator,  NYSDEC, Region 9,  270 Michigan Av.,  Buffalo, NY 14203

Gary A. Abraham

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Mar 9, 2015, 5:36:20 PM3/9/15
to citizens-agai...@googlegroups.com, Gary Green, Kathy Boser, Paula Vance, Hal Jacobi, Mike Lippert, karenmosman, Tom Barber, Sandra Sheldon, Marika Burke, Meg Kyrwe, Mark Alessi, Will Kennedy, Earl Robinson, Jason Knapp, Kathy Eggers, robins...@yahoo.com, Suzi Stevens, Robin Stroman, Robin Spencer
Rita,

If you have not previously, you may want to look at my comments last fall on the Hyland Landfill (on behalf of CCAC), where the frack waste issues are also discussed, as well as a backgrounder I prepared on the matter, here.

The drinking water standard for total radium (not radiation) (5 pCi/L), as you probably know, does not apply to disposal of waste. The discharge limit for wastewater treatment that accept leachate from landfills containing frack waste is 60 pCi/L, and so far none have come close to that. However, Hyland, Chemung County Landfill and Hakes C&D Landfill (all operated by Casella) have elevated alpha and total radium in their leachate. This affects the waster treatment plants that accept their leachate by risking unacceptable levels of radon within the plant. Radon is a decay product of radium. As note in the film Triple Divide, EPA recommends radon concentrations in enclosed spaces like a treatment plant be limited to 4 pCi/L. If that is the result of managing radioactive landfill leachate, the landfill as well as the plant are liable for impermissible "interference" with plant operations, which is enforceable by citizens under the citizen suit provisions of the federal Clean Water Act.

--Gary
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Law Office of Gary A. Abraham
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