Moshannon Creek Watershed Coalition Public Comment

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PO Box 94Hawk Run, PA 16840www.moshannoncreek.orgThe board of directors and membership of the Moshannon Creek Watershed Coalition (MCWC) wish toexpress their concern regarding the recent disclosure of environmental problems associated with theconstruction of I-99 and the proposed plan for disposing of the pyritic rock discovered there.While we appreciate that measures are being taken to attempt to best protect all watersheds, persons, andwildlife, we are concerned that this problem does not occur again elsewhere. We also have concerns aboutthe proposed solution; we have a vested interest in this solution.The purpose of this statement is not to propose steps for preventing this problem from occurring again.Although we cannot offer any solutions at this time, we do wish to encourage the DEP and otherparticipants in this process to fully research the history of this activity and determine why it occurred. Wehope that they not only disclose this research to the public, but also determine what steps can beimplemented to reduce the probability that such an error will occur again.We applaud the CDT for bringing this problem to light and we also applaud the DEP and PennDOT forthe steps that they have taken to make the information and possible solutions public since the CDT firstreported the problem. However, while we hope that this will continue to take place in the public eye, wedo encourage the participants to take steps to ensure that organizations such as ...

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PO Box 94 Hawk Run, PA 16840 www.moshannoncreek.org

The board of directors and membership of the Moshannon Creek Watershed Coalition (MCWC) wish to express their concern regarding the recent disclosure of environmental problems associated with the construction of I-99 and the proposed plan for disposing of the pyritic rock discovered there.

While we appreciate that measures are being taken to attempt to best protect all watersheds, persons, and wildlife, we are concerned that this problem does not occur again elsewhere. We also have concerns about the proposed solution; we have a vested interest in this solution.

The purpose of this statement is not to propose steps for preventing this problem from occurring again. Although we cannot offer any solutions at this time, we do wish to encourage the DEP and other participants in this process to fully research the history of this activity and determine why it occurred. We hope that they not only disclose this research to the public, but also determine what steps can be implemented to reduce the probability that such an error will occur again.

We applaud the CDT for bringing this problem to light and we also applaud the DEP and PennDOT for the steps that they have taken to make the information and possible solutions publicsincethe CDT first reported the problem. However, while we hope that this will continue to take place in the public eye, we do encourage the participants to take steps to ensure that organizations such as ours have an equal voice.

The disposal of the pyritic rock in the Moshannon Creek watershed is of particular interest to our organization and members. As citizens, many of our members have expressed concern over the logistics of the delivery of the material to the proposed disposal site; however, the primary concern of the organization is the effect that this disposal will have on our watershed.

As a party with a vested interest in the long term quality of the Moshannon Creek, we are obviously quite concerned that any such action be done only in a way that will improve the quality of the creek. Our long term goal is to restore the watershed to a pristine state. While we recognize that this is an ambitious goal, it is our hope and expectation none-the-less. With this in mind:

MCWC is willing to sample the area of proposed impact to establish a base line measurement of water chemistry. The results of this sampling could be used to determine allowable discharge levels for permitting purposes (NPDES and other). Regardless of our involvement, we advocate the inclusion of a variety of parameters in any permit. Any permit should include more parameters than just pH. At this time we also believe that at a minimum aluminum, iron, manganese, acidity, lead, copper, and zinc should also be included. Further research may increase the list of parameters.

MCWC respectfully requests that PennDOT establish a trust to pay for any sampling equipment and analysis that MCWC performs in conjunction with this site.

MCWC offers to help develop a sampling plan and provide the man power for long term sampling and oversight on the affected area if the proposed solution is implemented. A sampling plan should include measures for both surface and groundwater impact areas to ensure that Moshannon Creek, Wolf Run, Barlow Hollow Run, existing private wells, and Black Bear Run are not adversely affected by the proposed disposal of this waste.

Moshannon Creek Watershed Coalition

www.moshannoncreek.org

MCWC requests that the site in question be lined before any materials are put on the site. We have yet to see sufficient proof that the existing clay is sufficient to prevent leachate from contaminating the ground water. A synthetic liner provides added protection against such contamination; this protection is critical not only for the private wells that are near the site, but also for a nearby public water supply that might be adversely affected.

5. that PennDOT agree to put additional monies in the trust or toMCWC requests undertake an additional reclamation project along the Moshannon Creek to ensure that the overall impact on the stream is positive. Any selected project would need to meet the approval of all parties.

6. MCWC requests that PennDOT enter into a legal agreement with either MCWC or another entity such as Rush Township. In this agreement PennDOT will agree to compensation for remediation should the acidity or metals in the effluent from this site exceed permitted levels. If permitted levels are only stated for a minimum set of parameters, then MCWC may wish to establish additional levels for certain parameters and include them in this agreement. This agreement would be in addition to any DEP compliance plans and would provide an added level of security and comfort for those with a vested interest in the watershed.

Some of the above recommendations address a perception problem that exists between the Commonwealth’s agencies and the public. We feel that our participation in this effort may help mitigate some of the concerns and increase the public’s degree of comfort in both the validity of any claims and in the positive impact of this effort on the watershed.

As stakeholders in the Moshannon Creek watershed, we strongly encourage the Commonwealth and its representatives to work closely with the people and organizations of our local communities and watersheds to protect and preserve our natural resources. We believe that implementation of the steps outlined above will help to rebuild and restore our faith in our collective abilities to work together to be responsible stewards of our environment.

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