Posted by: nevadansagainstgarbage | December 16, 2011

COMMENTS TO THE NDEP DURING PUBLIC COMMENT PERIOD

Comments from the 12-1 NDEP Public Comment Meeting held at the Winnemucca Convention Center will be posted over several days. The purpose is to let people see the concerns that have not been addressed by NDEP and to serve as an example for others to send in their own comments and, if so inspired, to have them posted here as well. For example, the fact that NDEP would publish a Draft Permit with the intent to issue an Operating Permit without having a finalized plan for the handling of leachate, one of the most toxic byproducts of a landfill, is telling in and of itself. For whatever reason, they are in a rush to issue this permit.

These comments will be published here with the names of the commentator included or not depending on your wishes. Click here to read the first comment.

ONCE AN OPERATING PERMIT IS GRANTED, WHAT CHANGES CAN BE MADE? What guarantees can and will NDEP make to the citizens of Humboldt County that: The waste stream source will never change, the waste stream contents will never change, the plan of design will never change, the inspection process will never change?
Answer: You can’t and won’t make any of those guarantees as per NAC 444.6435 which says that all of the aforementioned items and more are subject to change if the operator so requests. Click here to read the second comment.

All leachate is toxic, all landfills generate it, all landfills leak, and once an aquifer is tainted, it is impossible to fix. You are either ignoring the loads of documents that are coming your way or you do not understand them. Click here to read the third comment.

All liners leak: Not if, just when. As stated by the EPA in the Federal Register (53-Federal Register 33314~33422 August 30, 1988). The NDEP in a letter to Norcal Waste Systems dated March 4, 2009 also stated that the NDEP will not assume “no 1eakage” through the liner. Click here to read the fourth comment.

Many who oppose the proposed Jungo landfill are primarily concerned about the feasibility of Jungo Flat for that activity; indeed, due to relative elevation, ground and surface water conditions, complex soils and potential seismic activity the Jungo site does not appear to be suitable for a Class 1 landfill.Click here to read the fifth comment.

First of all I question the RPC’s issuance of the first CUP. At the time a second landfill was not even legal. Recology’s initial CUP was approved by the Regional Planning Commission on 4/12/07. At that time, only one landfill was allowed in Humboldt County, NV. An ordinance allowing a second landfill (ordinance number 10-15-2007), was implemented with an effective date of 10/26/07, by the County Commissioners. Ordinance 10-15-2007 gave the board and council authority to contract for and manage programs for HAZARDOUS waste, not just SOLID waste. The summary of the amendment for ordinance 10-15-2007 and the public notice on 10/5/07 did not mention that change documented in section 13.12.270 of the ordinance.
Click here to read the sixth comment.

Many of my fellow citizens and I have brought forth numerous observations to NDEP pointing out that the proposed site cannot support the proposed project as designed without creating real and substantial danger to the health and welfare of the residents of Humboldt County Nevada, and to the underlying aquifer and surface waters of the State of Nevada. Briefly, such observations include: Click here to read the seventh comment.

I came across a study just today that exemplifies a particular area of reference to which myself and others have voiced objections. That is in regards to flooding and sheeting. This study, entitled “Estimating playa lake flooding: Edwards Air Force Base, California, USA by Richard H.French, Julianne J. Miller & Charles R. Dettling” was undertaken to determine the depth of water as a result of a 100 year precipitation event at the dry lakes (playas) … Click here to read the eighth comment.
Click here to read the attachment.

As is common with many land leases, it is important to note that Nevada Land and Resources LLC has an amended notice of non-responsibility with Jungo Land and Investements, Inc. as part of the lease and option to purchase. This notice specifies they are “…not responsible for any claims arising from any work of improvement in, upon or over said real property, including but not limited to, mineral exploration, mineral development, mineral processing, the construction, alteration, addition to, repair, demolition or removal of any building or structure whatsoever, or the seeding sodding or planting for landscape purposes, or filling, leveling or grading of said property”. I’m betting this covers landfills, too. Notice on file and dated 2/5/07. Also, it applies to all four sections of land Jungo Land and Investment Inc has a lease/purchase option on. Click here to read the ninth comment.

Read all the comments from the meeting by clicking here.

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