TO:

DEQswprogram@mt.gov, cdorrington2@mt.gov, daniel.zolnikov@legmt.gov, larry.brewster@legmt.gov, carrie.lud@riverstonehealth.org, barry.usher@legmt.gov, djones@yellowstonecountymt.gov, greg.oblander@legmt.gov, katie.zolnikov@legmt.gov, jostlund@yellowstonecountymt.gov, mmorse@yellowstonecountymt.gov,  

Tom.McGillvray@legmt.gov, megan.lit@riverstonehealth.org, jon.for@riverstonehealth.org  stoptheshepherdlandfill@gmail.com

 

SUBJECT: Pacific Steel & Recycling Automobile Shredder Residue (ASR) landfill

 

Hello,

 

My name is ________, and I am a Yellowstone County resident and have many concerns regarding the proposed Pacific Steel & Recycling Automobile Shredder Residue (ASR) landfill. Starting with the MT DEQ “Public Meeting”. This meeting had technical difficulties resulting in many residents leaving early out of frustration of not being able to hear the presentation and questions and answers. We weren’t allowed to ask questions freely, but instead were told to write a question down on a card and they would be read by DEQ. The questions the residents wrote down were filtered, sorted, and at times, the entirety of the questions/comments on the note card weren’t read out loud by DEQ. Only a small portion of the audience could hear the questions and answers. The residents had to yell just to be heard by DEQ and Pacific Steel representatives. The audience had several questions about the chemical makeup of the ASR material itself. Both DEQ and Pacific Steel stated they did not know what chemicals are in the ASR material. If they do not know what is in the ASR, how can DEQ and Pacific Steel properly mitigate and regulate the contaminants to protect our air quality, water quality, human health, wildlife, and more.

 

I understand that under Montana law, this landfill is not considered hazardous, nor is it considered illegal in Montana. However, since this is the first ASR Landfill permitted in the United States,  Even though it is approximately 3 miles north of a subdivision that includes around 200 households, not counting the households surrounding the areas that are even closer to the landfill site; and it is also 6 miles from the Independent Elementary School and Shepherd Elementary, Middle and High Schools. MT DEQ needs to evaluate the impacts of this ASR landfill on the Shepherd School Water Protection Plan of 1999 to ensure the school’s water supply is not further contaminated. 

 

Pacific Steel keeps stating they want to “store the ASR” for future recycling. However, according to the EPA, ASR that contains more than 2ppm of PCB’s cannot be recycled. In Pacific Steel’s application, a small sample was analyzed showing the ASR material has approximately 10ppm. Therefore, this ASR material can NEVER be recycled due to its PCB concentration being 3 times the limit.

Pacific Steel also has not tested this ASR material for PFAS. According to MT DEQ’s PFAS initiative: 

• “Major Sources of PFAS: Aqueous film forming foam, production and manufacturing facilities, landfills, and wastewater treatment plants, including biosolids application sites.” 

• Under MT DEQ’s PFAS Action Plan Objective 5, “Prevent creation of new sites (such as biosolid application sites) through better sampling and planning.”

• “Only a few of the thousands of PFAS have been studied for their potential to affect people’s health. Research is ongoing and we will learn more over time. Studies that have occurred suggest that exposure to certain PFAS may lead to health problems including changes in the liver, cardiovascular effects, reproductive effects in women, immunological and developmental effects in infants and children, and an increased risk of kidney or testicular cancer.”

 

Pacific Steel should be held accountable for testing the ASR material for PFAS concentration and identification. We need a baseline to compare future testing of ASR material. Also, if the ASR does not contain PFAS and PCBs in high concentrations, then Pacific Steel should not have a problem with testing it. It was explicitly stated in the public meeting that Pacific Steel and DEQ do not know what is in this ASR. It is concerning us that the regulating agency and the applicant (Pacific Steel) know less than we do about this ASR.

 

It was also made apparent at the "public meeting", that Great West Engineering is not done monitoring the groundwater wells. They won't be done for another 6 to 8 months. They also stated they have not submitted any water quality to DEQ yet.

 

Since this is the first ASR landfill in the United States, and there are so many unanswered questions, at minimum we need an appropriate public meeting to determine what questions can be answered. 

 

I respectfully request DEQ to postpone granting the permit, until EPA and MT DEQ set appropriate regulations to protect human health, wildlife, and environmental resources such as water and air from the mysterious ASR materials.

 

Sincerely,

 

(YOUR NAME

ADDRESS

PHONE NUMBER

EMAIL)