From Susan Heathcote at Iowa Environmental Council.

Comments are due next Monday!  Deadline for Action: 12 August
(See Part 1 for details and talking points -- see sample letter below)

Proposed Industrial Pollution Permit Endangers the Yellow River in
Northeast Iowa

A wastewater discharge permit is in process that would seriously damage
water quality in the Yellow River watershed.  Your comments are needed to
help ensure this permit is not approved as it is now written.

Copies of the permit can be obtained by calling Steve Williams at DNR at
515-281-8884.  In addition to a copy of the permit, you may also want to
request copies of the variance request and the Waste Load Allocation/Permit
Limits rationale document.

DNR Contact Information

The Iowa Department of Natural Resources is accepting written comments on
the draft permit through Monday August 12, 2002.

Written comments can be sent to:

Steve Williams
Iowa Department of Natural Resources
Wallace State Office Building
Des Moines, Iowa  50319

You can also submit your comments by email to
<[log in to unmask]>.

Sample text for letter or e-mail

Dear Mr. Williams,

I am concerned that the discharge permit that DNR has proposed for
AgriProcessors in Postville, Iowa does not protect water quality in Hecker
Creek or the Yellow River.  Groundwater quality is also at great risk
because of the direct connection between surface water and groundwater in
the area.

It appears the permit allows for violations of cold water stream
protections, allows for violations of groundwater protection laws and
regulations, and allows for intolerable levels of pollution in Iowa's
surface water.

It is especially disturbing that DNR would grant variances to our water
quality standards to discharges entering the Yellow River, a cold water
trout stream and high quality resource water, since Iowa's water quality
standards specifically state that these designated water bodies "warrant
special protection".

I am also concerned that the potential exists for serious groundwater
contamination that could impact drinking water. The Karst areas of the
statesuch as the area around Postvilleare particularly vulnerable to
groundwater contamination and extra precautions are needed to protect this
valuable resource.  This is particularly the case when wastewater is
allowed to enter directly into our groundwater through a sinkhole or losing
stream.  In fact, Iowa water quality standards state that no new wastewater
discharges will be allowed on watercourses that directly or indirectly
enter sinkholes or losing stream segments.

I ask that DNR enforce standards rather than exempt AgriProcessors from
Iowa's water quality standards for Total Dissolved Solids (TDS) or from the
standard that disallows using a zone of initial dilution (ZID) for cold
water streams.  I also ask DNR to protect Iowa's groundwater by denying
this new discharge into Hecker Creek, a losing stream that is directly
connected to the groundwater aquifer.

The proposed permit pertains to a new treatment facility separate from the
existing industrial lagoon system currently handling waste from
AgriProcessors and Turkey Products.  Turkey Products plans to continue to
operate the existing lagoon system to treat their wastewater so this is
clearly a new wastewater discharge.  The DNR has complete authority to
enforce Iowa's water quality protection laws and regulations and prevent
this new discharge into Hecker Creek.

Finally, I am concerned that the process used to arrive at this permit is
seriously flawed and will set a precedent for future permit
deliberations.  I request that an additional public meeting be held before
any final decision is made on this permit. These issues need to be more
thoroughly discussed and adjustments must be made to this permit to achieve
a better balance between AgriProcessor's permit needs and Iowa's water
quality protection needs.

Iowa DNR has a responsibility to protect our surface waters and groundwater
and should use the rules and procedures that are currently in place to meet
this responsibility.

Sincerely,

[Your Name]

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