November 19, 2020
To the Division of Water Resources - Tennessee
Re: NPDES Permit #TN0081566; Renewal
I mailed in a comment about the renewal and reauthorization of U.S. Nitrogen’s waste discharge into the Nolichucky River. I now present my oral explanation on U.S. Nitrogen dumping pollution into the river which is somewhat more philosophical than legal. It is intended not only to describe displeasure with industries waste history and contemporary pollution, but also to our civil servants who have managerial and administrative responsibilities to our state and national agencies given the important task of protecting our land, air and water.
The Federal Water Pollution Control Act of 1972 or Clean Water Act (CWA), is to “Restore and Maintain the Chemical, Physical, and Biological integrity of the nation's waters by preventing point and non-point pollution. The CWA preamble declares that: “Our nation’s waters should be swimmable and fishable”. Yet our government officers responsible for the law, regulations, policy and implementation continue to seek any “loop hole” in the law to continue the practice of using our waterways for sewer disposal sites.
One such caveat is the Total Maximum Daily load. This item of law puts restrictions on heavily polluted waters to receive further pollution from a specific chemical but does not restrict the pollution of clean waters for the same chemical until it too has a total maximum load for that chemical. When in the discussion of water quality, you state that polluted waters cannot be polluted but unpolluted waters can, the listener is stymied? In the case of U.S. Nitrogen who wished first to discharge into Lick Creek heavy in Nitrates they needed to alter their plans and pollute the Nolichucky.
Numerous requests to the Tennessee Department of Environment and Conservation on multiple water quality concerns have yielded little results. It has been more than six years since I asked TDEC to acknowledge that the intent of our water quality laws is far more important than the caveats within the laws which allow for the authorization of discharged pollutions into our public waters.
I have made comment on Nuclear Fuels Service’s discharge where we know radio-active material has been released into the Nolichucky. I have commented on gravel operations immediately along the river where a NPDES authorization was required and authorized knowing sediments and sediments containing pollution are released into the river. Witnessing employees of a county recycle center washing wastes into the river resulted in no action by TDEC. Then there is U.S. Nitrogen where I have commented, appealed and challenged with Pro Se litigation the discharge authorization for more than six years.
Nearly all the rivers of Tennessee in a short span of time have been altered by human activity to where the chemical, physical and biological integrity are but a remanent of their pre-industrial and community development self. An easy study of our waters including the Nolichucky will bear out that species have been eliminated, declined in numbers or are in poor health, the chemical nature of the waters have had foreign chemicals and biological organisms from farm, home and industry from thousands of point source locations authorized and unauthorized, as well as a myriad of non-point activities.
Chronic permitted and un-permitted impacts of pollution to our surface waters is unwise, unwarranted and demands a greater over-site by our water quality agencies to work for water protection. How is it that whenever industry approaches with the offer of a few jobs and a few dollars with a large amount of profit for themselves that our elected officers fall over themselves in an effort to collect.
Most individual citizens have little time in their daily and annual activities for over-site of the natural environs around them, they are far to occupied with life.
They expect, without merit, that government agencies; whether county, state or national will protect our lands, air and water as necessary for present and future generations.
It is a fallacy that the Tennessee Department of Environment and Conservation nor the U.S. Environmental Protection Agency is looking out for the wisest approach to environmental concerns. I am not saying that we do not have professional and hard-working civil servants to protect our waters. I am saying that the political action from high, influenced by corporate money, focusing more on the dollar than any other issue, has historically and currently continue to degrade our open spaces and the natural habitat of our land, air and waters.
Please stop this ignorance. Focus on the wisdom where the human species coexists with the natural world. Focus on the changing climate, habitat fragmentation, the loss of open spaces, the native species that have for millennium adapted to the local ecosystem. Discontinue our abuse to nature before we all are standing in our wastes without the pleasure of clean waters, clean air, natural landscapes and diverse flora and fauna.
Take a long look at this specific waste water discharge permit, use it to reverse the earlier authorization and demand that U.S. Nitrogen assures their discharge will be near zero in pollutions and that wastes do not impact the chemical, physical and biological integrity of the Nolichucky River by focusing on the true intent of the CWA. Do not allow these pollutions to occur in our waters.
Stan Olmstead – Natural Resource Advocate
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