Formal comment on Mid Atlantic Recycling Technologies, Inc. permit application

September 28, 2007

Mr. Joel Leon
Bureau of Operating Permits
NJ Department of Environmental Protection
401 East State St., 2nd Floor
Box 27
Trenton, NJ 08625-0027

Re: Significant Modification to an Air Pollution Control (APC) Operating Permit for Mid-Atlantic Recycling Technologies, Inc., Vineland, NJ

Dear Mr. Leon,

Citizens United to Protect the Maurice River and its Tributaries, Inc, a 501c3, would like to voice its concerns regarding the application for significant modification to an operating permit by Mid Atlantic Recycling Technologies, Inc.

We are sure you are equally concerned with MART's inability to achieve a credibility level which would allay residents' fears that MART is a safe neighbor; especially given their proximity to many food processing industries that rely so heavily on a clean reputation and process. To place an undue burden of the prospect of an expansion of the MART facility could further degrade the Park's environmental integrity. The continual DEP's penalties levied against MART demonstrate at worse an inability to meet acceptable environmental standards and at best many perceived inadequacies. In either case it raises serious questions regarding rationally granting an approval for expansion.

As you know, neighbors have repeatedly raised concerns regarding the operation of the MART facility. Concerns bore out of the issuance of many fines for the improper operation. Is it reasonable to assume that the businesses and neighbors surrounding these two facilities should be exposed to an increased amount of hazardous material hauled to the facility? Recently the Coalition for Clean Air and Clean Water made settlement with the company; could it be the prolonged battle took up too much time and resources to further their objections? Shouldn't citizens have faith in the DEP to indeed PROTECT them, their environment and their livelihoods?

We also continue to be concerned about surface water and groundwater pollution from this site. In past correspondence and public comments we have requested a full damage assessment of the local water resources in addition to the air quality measures, and we have requested that the Department consider requiring that MART fund an independent (not a primary or sister company) chain of custody water quality and sediment testing at the intersection of Mill Road and Burnt Mill Branch to rule out the possibility of any surface water contamination, and that MART perform groundwater testing at the site to rule out the possibility of contamination from soil leachate. We also asked about the need for a liner to be utilized on site. We have received no information regarding our formally submitted water quality concerns and MART's performance in terms of water quality degradation, and we suggest that the local environment would be much better protected if water pollution was connected with air pollution for this proposed expansion. Hopefully, surface and ground water quality has not been degraded by MART, and a comprehensive assessment of the local water quality will help restore public confidence in the regulatory system.

The increased levels of various metals and particulates raise serious concern; for example; the annual emission rate of nitrogen oxides as NOx. It is our understanding that MART has purchased NOx credits and that the application request for expansion falls within required guidelines. However, we remain concerned because the Federal rule requires emission reductions for oxides of nitrogen (NOx) since they are precursors to fine particulate matter (PM2.5), and NOx is a contributor to ozone. NOx emissions contribute to the formation of acid rain and, either directly or through the creation of ozone, are harmful to human health. MART lies within the Kirkwood Cohansey aquifer, which is known for its porous, silica sand, and the deposition of matter leaching into the aquifer must be avoided. Expansion will likely result in thousands of additional diesel fueled vehicles transporting contaminated soil both in and out of MART thus generating even more NOx emissions.

It is imperative that "independent testing" is implemented at certified laboratories and that proper air monitoring equipment is employed at the facility. We do not believe it would serve the public interest to ignore MART's past litany of fines, missed deadlines and failure to comply with regulatory standards imposed by the DEP.

The processes performed at the MART facility are a laudable public service, but only if proficiently executed and without detriment to the surrounding community.

Sincerely

Jane Morton Galetto
President, Citizens United to Protect the Maurice River and Its Tributaries, Inc.

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