From Susan Heathcote at Iowa Environmental Council.

Comments are due next Monday!  Deadline for Action: 12 August
(See Part 2 for a sample letter)

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.

The permit fails on several fronts:

- It fails to protect our high quality waters.
- It fails to protect our groundwater.
- It fails to enforce our surface water quality standards.
- It fails to adequately engage the public and all stakeholders in the
permit process.

Public comments are needed to ensure adequate enforcement of existing water
quality laws and standards in order to protect Hecker Creek and the Yellow
River in Allamakee County.

Groundwater used as a drinking water source in the area is also at great
risk because Hecker Creek "loses" some of its water into the underlying
groundwater aquifer.

Your comments are needed on the draft for a new wastewater discharge permit
for AgriProcessors in Postville.

Please read the Background and Key Issues sections below.  At the end is a
sample letter to the DNR and contact information for your convenience.

Background

The City of Postville has managed an industrial lagoon for many years to
treat the waste from Turkey Products and AgriProcessors (two meat and
poultry processing plants).

Two years ago massive discharges of insufficiently treated waste killed
fish in the Yellow River.  The resulting settlement between the City of
Postville and AgriProcessors over this fish kill calls for the construction
of a new wastewater treatment facility for AgriProcessors and maintenance
of the current lagoon system for Turkey Products.  The permit in question
is for this new facility.

The new facility will discharge into Hecker Creek, the same tributary into
which the current lagoon discharges.  From the discharge point, Hecker
Creek runs 2.7 miles before it empties into the Yellow River.

The lower segment of Hecker Creek is a documented "losing stream" with a
direct connection to the groundwater aquifer. Iowa Water Quality Standards
*do not allow new wastewater discharges into losing streams*.

The Yellow River is a cold water stream, Class B(CW), and is also
designated as a High Quality Resource (HQR) water.  Iowa Code *specifies
that HQR waters "warrant special protection."*

Key Issues

Failure to protect high quality water bodies.
Iowa water quality standards specifically forbid the use of a dilution zone
when a discharge enters a designated cold water stream.   The ZID is
essentially a dead zone in the stream where pollution levels are sufficient
to kill aquatic life.  The proposed permit grants a variance to existing
state Water Quality Standards by allowing for a Zone of Initial Dilution
(ZID) in the Yellow River, a cold water stream designated as a High Quality
Resource Water.

Failure to enforce water quality standards.
A second variance granted in the proposed permit exempts AgriProcessors
from the current Total Dissolved Solids (TDS) limit of 750 mg/L. The
variance would replace the TDS standard with a permit limit for chloride,
since the dissolved solids in the discharge will primarily be excess salt
(sodium chloride) from the meat processing.  The allowable discharge in the
proposed permit for chloride alone is 3285 mg/L, which greatly exceeds the
current TDS standard and will have a significant detrimental effect on
aquatic life in Hecker Creek and the Yellow River.  Hecker Creek is a small
general use stream with relatively little capacity for dilution.  Our water
quality standards provide little protection for general use streams, but do
require that they be free from acutely toxic conditions and protected for
livestock and wildlife watering.  The proposed variance from the TDS
standard will not adequately protect for these general uses.  Even after
dilution, the concentration of chloride in the Yellow River will be
approximately 30 times higher then current levels.

Failure to protect groundwater.
Iowa water quality standards specifically prohibit new wastewater
discharges into watercourses that directly or indirectly enter sinkholes or
losing stream segments. A losing stream is a stream with fractures or
sinkholes in the streambed that allow surface water to flow directly into
the groundwater.  Under the draft permit, AgriProcessors will be allowed to
discharge into Hecker Creek, which is a "losing stream" typical of the
Karst geology of this region. As such, the new permit violates water
quality standards and state laws designed to protect Iowa's groundwater. It
is estimated that at least 338,000 gallons of water flowing in Hecker Creek
are lost every day into the aquifer before the creek empties into the
Yellow River.  Pollutants of concern to the drinking water aquifer include
salt (sodium chloride) and fecal coliform bacteria.  Based on the proposed
permit levels, it is estimated that 5 tons of salt and 2.5 billion colonies
of fecal coliform bacteria would enter the aquifer every day.

Failure to adequately engage the public in the permit process.
Public input on the proposed permit has been limited to a single public
meeting held in Postville on July 31.  More than 100 people attended this
meeting.  And more than 20 individuals made public comments expressing
concerns about the impact the variances in the proposed permit will have on
water quality.  At this meeting, DNR took testimony from the public but did
not answer questions or allow any discussion of the justification for the
proposed variances.  Many people at this meeting requested another meeting
be held to address the issues raised, but as far as the Council is aware,
no such meeting is planned, and the public comment period closes on August
12.

For more information
Contact Susan Heathcote at the Iowa Environmental Council at 515/244-1194
or <[log in to unmask]> or Steve Veysey with Hawkeye Flyfishing
Association 515/2945805 <[log in to unmask]>.

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