County Commissioners Voice Concerns about Facility
Oct. 4, 2017
North Dakota Dept. of Health
Division of Air Quality
918 E. Divide Avenue
Bismarck, ND 58501-1947
Re: Radioactive Materials License to Waste Management for operation of
the Tobacco Garden Processing Facility
Director O’Clair,
We the members of the McKenzie County Board of County Commissioners
request a delay of issuing Waste Management of North Dakota, Inc. a license for
the operation of the Tobacco Garden Processing Facility until we have time to
thoroughly review the materials that were only sent to our staff September 28,
2017, less than a week ago.
Mr. Reice Haase of HRD made a presentation to our Board yesterday
afternoon. In his presentation he noted that he spoke with our Planning
Director, Jim Talbert, over 18 months ago that they were searching for
potential sites for a facility. No other
details were disclosed at that time and there has been no other contact,
discussions, or communication with our staff concerning their plans and
intents. Whether intentional or not, we
feel these plans have been kept from us and now sprung on us without time to
properly respond.
Upon receiving the information a few days ago we have reached out to
the Twin Valley Township Board and found that they are opposed to the project
but felt they had no recourse to object to their License. We have informed them that since the
injection wells are regulated by the NDIC, the Township has limited ability to
affect changes in the location and regulations surrounding the operations and
activities of the injection wells. However, the Dept of Health licenses the
disposal of solid waste including NORM and TENORM materials, and we encouraged
them to contact the NDDoH, Division of Air Quality to express their concerns.
In a cursory review of the materials provided we note items that need
further review.
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The site address provided, 12268 38th
St NW, Watford City, ND 58854 is not an address that has been issued by the
County’s GIS Coordinator. They have not
requested nor received an address which is a part of our 911 emergency response
requirements.
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They have not met with or contacted the County’s
Emergency Manager or the District Fire Chief to review plans and contingencies
for any fire or emergencies that may happen at the site during construction or
operation of the facility.
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No site plans or building plans have been
submitted for review by our Fire Inspector or Building inspector.
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The Radiation Safety Manual that was provided
seems very general without sufficient specifics on handling spills, accidents,
or precise procedures if incidents were to occur. There does not seem to be any
detail on the number of monitor wells or specifics on how incidents will be
addressed if the monitor wells detect contamination and the procedures that
will be taken in such an event.
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There is no mention of annual training and
drills with first responders and emergency management.
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The location of entries and exits to the site
raise safety issues. There are currently
no deceleration or acceleration lanes or turn lanes provided off of the county
road. Sight lines are limited in this area because of terrain and must be
analyzed. Waste Management’s estimates
are that at least 50 trucks per day may be entering and exiting the facility.
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Waste Management stated that there would be no
TENORM on the site and yet their application and safety manual seem to
contradict this assertion.
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The Water Resource Board has reported that the
Rural Water Service has recently finished a waterline directly adjacent to this
property and they need to assess potential dangers to the waterline and water
supply that may be affected by this facility.
During their presentation to the Board yesterday we noted and applaud
Waste Management’s statements that they were going to require the testing and
documentation of testing of the material that they will accept at this
facility. They also mentioned that
dosimeters will be worn by workers at the perimeter of the site to detect
radiation that may escape the site. They further assured us that any truck
coming to the site without documentation that the materials had been tested for
the amount of picocuries would be rejected. They further assured us that any
material that exceeded background radiation would be rejected. The Waste Management representatives stated
at the onset of their comments that this facility will not accept any
TENORM. When or if a license is issued
we request that these procedures be a part of their requirements since they
have publicly assured us that they will follow them.
The materials provided seem to have been hastily put together without
full consideration of site issues and safety protocol. Waste Management representative indicated
that it was their hope and anticipation that construction would begin in less
than 2 weeks and be operational before the end of this month. We therefore request that this application be
put on hold until we can fully review the impacts to the site, roads and safety
concerns. We appreciate the Department
of Health and the Division of Air Quality’s oversight to protect our citizens
and environment.
Sincerely,
McKenzie County Board of County Commissioners,
Douglas Nordby, Chairman
Vawnita Best, Vice Chairman
Kathy Skarda
Gene Veeder
Tom McCabe
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