P NARVON Last Friday the
Lancaster Environmental Action
Federation went on record in
strong opposition to the proposed
hazardous waste landfill at the
Narvon clay mines.
The following is their statement
The Lancaster Environmental
Action Federation is an
organization that was formed in
1972 by persons who wanted to
improve the environment of
Lancaster County and assure a
high quality of life for county
residents.
During the past ten years, LEAF
members have been involved in
environmental issues at the local,
county and state levels. They have
dealt with a wide variety of con
cerns including water quality,
solid waste management and
recycling, nuclear power plant
siting and operation, farmland
p preservation, energy con*
servation,. air pollution, preser
vation of open space, soil con
servation and environmental
education. Getting involved in the
siting of the hazardous waste
facility at Narvon in Eastern
Lancaster County was a natural
follow up to our past activities.
For the past year, members of
LEAF’S Board of Directors have
taken part in Envirosafe Services
Inc.'s Narvon Public Participation
Committee which has been
meeting with representatives of
the company to study the proposed
Saw Dust Days
Demonstrations All Day Long
LOG SPLITTERS
Self power and tractor mounted 3 pt.
CORDWOOD SAWS
SHREDDERS
Self powered and tractor mounted 3 pt.
KUBOTA TRACTORS
KING’S LAWN AND GARDEN
Rt. 422, 2 Miles East of Myerstown
Across from Dutchway Market
LEAF opposes Narvon landfill
hazardous waste site at the Narvon
Clay Mine. Board members who
took part in the committee for all
or part of the past year include
Richard M. Brown (president),
John Chute, Tom Johnston, and
Robert Crouse. LEAF was
represented directly by Richard
Brown and John Chute (alternate).
During that time we have at
" tempted to understand and
evaluate the data provided to us by
Envirosafe’s consultants and
employees who were studying the
, suitability of the Narvon Clay Mine
site as a repository for hazardous
waste materials.
After participating in the PPC
for the past year and aftercareful
consideration of available data,
the Lancaster Environmental
Action Federation has decided to
strongly oppose the, siting of a
hazardous waste facility at Narvon
in Eastern Lancaster County. Our
. opposition is based on the following
points:
1. We believe much of the
hazardous waste targeted for
Narvon could be recycled' or
rendered harmless. The wastes
are being buried in the ground
simply because this is the least
expensive means of disposal. We
believe industry and government
should redouble their efforts to
encourage the reuse of these
wastes which should be viewed as
a valuable resource-not just
something to throw away. If waste
Tractor Mounted
Various H.P. tractors
LOCATION:
volumes can be reduced by
recycling, then the need for landfill
sites such as that proposed at
Narvon would be greatly reduced.
2. We believe that Lancaster
County, the most agriculturally
productive non-irrigated county in
the United States, is not the place
for a hazardous waste landfill.
There are many places in less
populated areas where agriculture
is not a major industry that would
be suitable for such a facility.
Although the Narvon site has
soils that meet the regulatory
requirements for landfilling, it was
not picked because of its unique
geological qualities, but rather
because of its proximity to
generators of hazardous wastes.
Also, the state of Pennsylvania had
a better “regulatory climate.”
3. Our specific objections to the
Narvon site as a repository for
hazardous wastes include the
following:
a. The greatest threat from the
proposed facility appears to be the
pollution of surface and subsurface
water supplies. In the short term,
if the facility were designed and
operated as indicated by in
formation supplied by ESI, the
impact on water resources should
be minimal. However, after
closure,- the problems could
become acute.
....EPA is reasonably certain
that hazardous constituents and
by-products will migrate out of
most facilities and migrate beyond
either of the suggested con
tainment areas at some time after
the containment periods. Second,
EPA is not certain that, once these
hazardous containments migrate
jQut of the facility, they can be
readily and effectively intercepted
and removed so that they do not
migrate to points of water use.
“Finally, EPA doubts whether it
can assure that the facility owner
or operator will implement- ef
fective remedial measures
whenever releases occur, par
ticularly for an extended period of
time or after the originally
established and funded post
closure period. In short, EPA
believes that relying on con
tainment during the operating and
post-closure-care periods and on
application of remedial measures
thereafter will, in many cases, fail
to provide long term human health
and environmental protection.”
We concur with this position
stated by EPA in the Federal
Register. A’though ESI has ex
pressed a willingness to create an
annuity to provide funding for post
closure monitoring and main
tenance in perpetuity, we question
whether any amount of funds
would be sufficient to correct the
problem and to reimburse nearby
property owners for damages
incurred should a breach of the
containment area take place.
b. Since a breach of this landfill
will eventually occur, placing it at
the headwaters of the Conestoga
River is the wofst possible siting-of
a hazardous waste facility. The
2,500 farmers who have invested
thexr entire personal assets in the
farms of this region have too much
to lose from the adverse publicity
of having a hazardous waste site in
their watershed. Many farms have
between $500,000 and $1 million
invested in land, machinery,
buildings and stock. Also, there is a
fledgling vegetable co-op just
starting which could be devastated
by adverse publicity such as that
which occurred after the accident
at TMI.
The residents of the Conestoga
Watershed who depend on surface
or ground water for drinking could
be faced with the possility of
having to buy water or find other
sources if their supplies become
contaminated.
c. Access to the site by way of
Narvon Road is not acceptable.
•-v ... This road is steep, narrow and can
To illustrate our concerns, we
quote from the Environmental
Protection Agency’s Sup-
World trade
roundup
WASHINGTON, DC
The Foreign
Agriculture Service of
the U.S. Department of'
Agriculture reported
the following recent
developments in world
agriculture and trade
last Wednesday:
Grain and Feed
Argentina recently
signed a trade
agreement with Cuba to
supply 100,000' tons of
corn annually during
1982-85. The agreement
also includes annual
minimum shipments of
soybean meal, dry
beans, tallow and non
fat dry milk. Reportedly
no credit arrangements
are included and sales
will be based on
prevailing international
market prices.
Argentina exported
about 100,000 tons of
com to Cuba incalendar
1981.
Austria is likely to
export nearly 600,000
tons of wheat this
season, double any
previous level, as a
result of expectations of
a near-record grain
outturn. East Germany
and Yugoslavia may
import the bulk of ex
cess Austrian supplies.
Austrian domestic
prices are well above
current world prices,
indicating government
subsidies on Austrian
wheat exports this
season may reach about
$35 million.
Lancaster Farming, Saturday, October 9,1982—A23
plementary Information con
cerning the regulation of hazar
dous wastes which appeared in the
Federal Register, Vol. 46, No. 24,
Thursday, Feb. 5, 1981, pp. 11126-
11136.
“Many hazardous wastes placed
in land disposal facilities will not
degrade to a point where they are
no longer hazardous, or will do so
only very slowly... Moreover,
current scientific knowledge about
the degradation of hazardous
wastes placed in land disposal
facilities is imperfect. For these
two reasons, it is necessary to
assume, at this time at least, that
hazardous wastes and hazardous
constituents placed in a land
disposal facility will remain
hazardous for very long periods of
time.
. “There is good theoretical and
impirical evidence that the
hazardous constituents which are
placed in land disposal facilities
very likely will migrate from the
facility into the broader en
vironment. This may occur several
years, even many decades, after
placement of the waste in-the
facility, but data and scientific
prediction indicate that, in most
cases, even with the application of
best available land disposal
technology, it will occur even
tually
not accommodate the predicted
truck traffic patterns for this
facility. Even if the road is
upgraded, the constant stream of
heavy truck traffic carrying
hazardous wastes will pose a
constant danger to local residents.
The additional traffic generated
on Eoujte 322 will present a real
problem for farm and buggy
traffic. An increase of 27% in truck
traffic on an already heavily
traveled highway is considerable.
d. Because of the continued state
of flux of the regulations covering
the design and management of
hazardous waste disposal sites and
because of the changing political
and economic climate, we question
the abilities and intentions of
appropriate state (Department of
Environmental Resources (DBR)
and federal (EPA) agencies to
monitor the operation and closure
of this facility.
4. As in any undertaking of this
magnitude, the greatest impact
will be on the local residents. The
following are items of concern to
the many people in the area near
this proposed facility that we feel
must be addressed by all agencies
and individuals involved in the
permitting process.
a. Property values
b. Air pollution
c. Surface water runoff and
erosion :
d. The ''proposed facility’s
demand on local water supplies
e. The potential for con
tamination of nearby wells and
springs
5. We have reservations about
the results of the consultants’
studies and information supplied
by ESI. Because of the nature and
structure of the Public Par
ticipation Committee, access to
and evaluation of’ independent
sources of information was limited
and there was no corroborating
data from outside consultants or
the staffs of the DER or the EPA.
Although members of the com
mittee studied all available date
and put forth substantial effort in'
doing so, we did not have enough
background information or ex
pertise to accurately evaluate the
data provided. Since most of the
information we examined was
provided by ESI and its con
sultants, we believe a potential for
bias exists.
6. We believe ESI exhibited a
lack of concern in its dealings with
the citizens of the Narvon area and
the n Public Participation Com'
mittee. The following are a list of
events that disturb us:
a. John Chute, a resident of East
Earl, joined the LEAF Board of
Directors in January, 1982 and was
elected as LEAF’S alternate to the
PPC. Mr. Chute attended and
participated in all the meetings
from March 10 (#8) until August 19
(#l5) except one. Yet, during that
time, he did not receive minutes or
notices .of the meetings on a
regular basis, nor copies of any of
the materials marked “con-
which were made
available to ail other committee
members.
LEAF’S purpose in encouraging
John to attend the PPC meeting
was to provide much needed input
from residents of the Narvon area.
Until that time, therehad been no
representative on the PPOwho
lived in the area of the proposed
hazardous waste landfill.
Although some' of these om
missions might have been due to
lack of communication or simply
oversights, we believe there was a
pattern of deliberately excluding
John from the workings of the
committee.
b. At the May 20, 1982 meeting,
the ESI representative, with the
concurrence of at least one
member of the committee tried to
pressure the committee into
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