Meeting
Wednesday - February 15, 2012 @ 3:15 P.M.
Sierra Club Office -1365 Fruitville Road
Sarasota, FL 34236
CHANGES NEEDED
AT DEP _____ Florida Department of Environmental Protection
(DEP) Secretary Herschel T. Vinyard needs to replace present employees that are leading efforts to “gut" environmental
regulations and should not be retained in positions of authority. DEP needs to foster an environment where employees can be
candid without fear of retribution. People who have been conscientious enough to stay on in the Department but who have not
been utilized to the fullest extent need to be consulted.
DEP must strengthen nitrate policies. Presently, the Department's
policies regarding nitrates are grossly inadequate. The result is increasingly serious pollution of the groundwater by dairies,
poultry, swine, and feedlot operations. Present policy permits operators to be exempt from regulation if the operators promise
to use best management practices (BMPs). No personnel or monitoring is provided to ensure BMPs are practiced.
While ManaSota-88 has no problems with proper reuse of wastewater
effluent, the Departments wastewater reuse rule needs to be strengthened. Weakening requirements for wastewater reuse is not
an option. Buffer zones between wells and reuse projects, between public use lands etc., should not be reduced. Consideration
needs to be given to data which shows high nitrate levels in citrus areas irrigated with treated effluent to data showing
buildup of salts on golf courses with resultant loss of grasses; and to information regarding the using of effluents on golf
courses and subsequent bleeding-off of pesticides and fertilizers.
The Department needs to adopt a policy that minimizes and stops
cross-media pollution. As an example, removing pollutants from drinking water and dumping them on the land where they can
leach into the groundwater or run off into surface waters is not acceptable.
LOSS OF
HABITAT _____ Habitat alteration and subsequent destruction
are creating a serious threat to the survival of wetland and upland species. If the wetlands policy Manatee County is pursuing
is implemented, those species not yet endangered may be soon.
Developers will be permitted to destroy valuable wetland habitat.
Their "allowable impacts" to wetland species will be compensated for by acquiring uplands or paying to destroy the wetlands.
What this proposal amounts to is another give-away to developers at the expense of the environment and the future of Florida.
The major factor in most cases of species endangerment, the
initial decline in numbers and geographic range is due primarily to habitat alteration. As a result, the small populations
of species that survives become more vulnerable to environmental catastrophes. Even attempts at species preservation through
amelioration of habitat destruction is often not enough for the species to recover.
There are other factors, when populations are reduced in size
and isolated, harmful genetic processes result. This serves to further threaten the survival potential of the species.
Rather than attempting to serve development interests through
adopting a wetland policy that will ensure destruction of much of our remaining wetland habitat and species, Manatee County
would be much better served through the adoption of an incentive program to ensure preservation of these rapidly dwindling
resources.
PHOSPHOGYPSUM _____ No evidence has been submitted to the EPA,
the Florida Department of Environmental Protect, the Florida Industrial and Phosphate Research Institute (FIPR Institute),
or anyone else demonstrating that the use of phosphogypsum protects the public health to the same degree as EPA's prohibition
on its use.
The use of phosphogypsum in building materials is contrary
to the national goal, U.S. Code Section 2661, which states, "The air within buildings of the United States should be as free
of radon as the ambient air outside of buildings."
The use of phosphogypsum in building materials is also contrary
to Florida's indoor radon standard of "As Low As Reasonably Achievable not to exceed .02WL." It is reasonably achievable to
prevent increases in indoor radon by not putting phosphogypsum in building materials.
ManaSota-88 also notes that phosphogypsum, due to its extremely
high radium content, would not qualify for use as fill under a building.
The FIPR Institute would have millions of tons of radioactive
waste spread throughout the state. It is impossible for any regulatory agency to keep track of this material over the next
1,600 years, which is the half-life of radium. This is precisely why EPA found it was necessary to prohibit the use of phosphogypsum.
The high volume use of phosphogypsum would create a long-term
waste management problem of major proportions.
Disposal of phosphogypsum in lined and capped stacks with perpetual
maintenance plans is the best waste management technique possible for phosphogypsum. Human and environmental exposure are
kept to a minimum from this radioactive waste that contains approximately 70 times more radium than background soil.
Risking public health is not an option in disposing of radioactive
waste.
Supporters of the use of phosphogypsum continue to barrage
EPA officials with vague information regarding the purported safe use of phosphogypsum in road construction, soil conditioning
and agriculture.
There is no way to prove how long any phosphogypsum-concrete
mixture will remaIn solid and safe. A road of mixed concrete (or any other hardening material) and phosphogypsum will
ultimately crack and ·break within a few decades and eventually turn into radionuclide-contaminated sand. There is no way
to test when the breakdown will occur other than to wait and see what happens as time passes.
As far as using phosphogypsum as a soil-conditioner: the process
results in a buildup of radium in the soil as a result of long-term use. There is increased risk to agricultural workers from
their exposure to radium and its products. A significant radium transfer to man can occur via radiation uptake by agricultural
crops.
The FIPR Institute continues to endorse the use of phosphogypsum.
They are apparently willing to bet our children's health and safety that a build-up of radium in our soils is of no importance
and that the phosphogypsum road-building process will remain stable for the duration of the hazard (radium has a 1630 year
half-life). It appears they are simply betting they will be gone by the time a serious problem becomes evident.
Phosphogypsum use is a travesty of good science and engineering.
It is a serious violation of public health principles and existing federal policy. ManaSota-88 will continue its opposition
to any use of phosphogypsum.
PHOSPHATE SEVERANCE
TAX _____ The Phosphate Severance Tax can be more effectively
used. This will require a change in the law. Since it's beginning, the Florida Industrial and Phosphate
Research Institute has served the interests of the phosphate
industry to the exclusion
of the public interest. The state needs to stop funding a phosphate
propaganda mill with this tax. A change in the law should be made to permit funneling the tax to our state agencies to monitor
and oversee repair of the serious damage this industry continues to cause.
PHOSPHOGYPSUM USE
WAIVERS__ ManaSota-88 has advised EPA Administrator Lisa P.
Jackson not to issue any waivers to permit farmers to use phosphogypsum as a soil enhancer. In some instances this translates
into the initial dumping of 20 metric tons per hectare of this carcinogenic waste. This process is followed by bi-annual application
of 10 metric tons per hectare. This results in more than 4 picocuries per gram of radium-226 being incorporated into the soil.
In contrast, background soil in Florida contains about 0.5 picocuries per gram of radium-226.
While farmers may be unaware of increased health risks from
applications of this waste, there is a health hazard involved to the workers who spread phosphogypsum. The potential for uptake
of radionuclides into food crops poses a health hazard as well. Additionally, we are seriously concerned with the migration
of these known carcinogens into our ground and surface waters.
NUCLEAR
POWER _____ManaSota-88 advised Secretary of Energy Dr. Steven
Chu of our strong objection to the Department of Energy's (DOE) efforts to resurrect the uneconomical and extremely hazardous
nuclear power industry. The amount of federal money poured into nuclear energy tops billions of dollars each year, while research
into clean renewable energy sources and energy efficiency improvements is starved for funds.
Despite government subsidies, nuclear power plants continue
to pose a serious threat to public safety. Another major accident is likely to occur within 10 years.
No reactor design is inherently safe.
Nuclear power costs are prohibitively expensive, costing more
than energy generated by fossil fuels and much more than electricity derived from efficiency improvements.
The Nuclear Regulatory Commission (NRC) continues to fail to
adequately address the serious problem of radioactive waste disposal and plant decommissioning.
In the interim, ManaSota-88 will continue to work to convince
our state, local and federal governments to provide support for renewable energy projects.
Examples of the energy that could be easily saved: If the U.S.
converted to the best available lighting technology, there would be a significant decrease in U.S. energy use. If the
U.S. increased its average car fuel efficiency, U. S. oil use would decrease.
GROUNDWATER
STRATEGY _____ Groundwater contamination presents a serious
problem because treating water before use is expensive and does not reduce the contamination in the aquifer. Rehabilitating
aquifers is extremely costly and not always feasible. Therefore, DEP and EPA need to act to prevent additional groundwater
contamination while it is still well below the level that would present a health risk.
Permitting deliberate contamination of groundwater is irresponsible
and shows no concern for future groundwater use needs. So-called wellhead protection plans will not work because too little
is known about the fate and transport of pollutants within an aquifer system.
EPA has to acknowledge that complete clean up of groundwater
contamination will be impossible at some sites and that containment of pollutants may also be difficult, if not impossible.
Perhaps, the irresponsible policies permitting injection of pollutants into the groundwater will change.
NUCLEAR POWER
AND WASTES ____ Radioactive reactor produced waste will eventually
migrate into the environment with ensuing long-term health costs. There are no good "choices" of disposing of radioactive
reactor produced waste. During the past 50 years both the federal government and nuclear industry have failed to develop a
method to isolate the long-lived nuclear reactor produced waste.
Permanent "disposal" does not exist, therefore:
1. No new nuclear power plants should be permitted and;
2. Liability for the damage that has and will occur must remain
with the producer of the waste.
ENERGY
POLICY _____ ManaSota-88 continues to recommend that the Unites
States implement an energy policy for energy efficiency as its major component. New standards for greater improvements in
the fuel economy of new cars needs to be adopted as well as allowing states the right to apply highway funds for mass transit.
And, as we have recommended for some time, meaningful national efficiency standards for light bulbs and appliances need to
be adopted.
Energy currently wasted by American cars, homes and appliances
equals more than the energy potential from oil and gas reserves in all of the Alaskan lands and the U. S. Outer Continental
Shelf that have been targeted for drilling.
WCIND
FUNDING_____ The majority of waterways originally
dredged within the West Coast Inland Navigation District (WCIND) were dredged before permitting was required. In
most cases canals were dug as a source of fill for coastal wetlands to maximize the number of waterfront lots for the development.
There was little or no thought given to the environmental consequences that occurred during the original dredging of these
canals. As a result of inappropriate waterfront development, inadequate stormwater runoff control , and habitat destruction,
many of the original canals dredged have silted in and are restricting motor boat access for some waterfront property owners.
Instead of wasting taxpayers money on environmentally
damaging maintenance dredging projects, WCIND should instead embark on a program of habitat restoration, stormwater
runoff control, and enforcement of existing best management practices to reduce the problems of erosion and siltation.
FIPR INSTITUTE
FIASCO____ Phosphogypsum utilization is a top research
priority for the FIPR Institute. The FIPR Institute has funded numerous projects attempting to justify the widespread dispersal
of radioactive phosphogypsum. This research has been less than objective.
The FIPR Institute has not funded adequate studies on the critically
important issue of soil radiation standards on reclaimed lands.
The FIPR Institute continually attempts to mislead the public
concerning the hazards of low level radiation. Increased exposure to avoidable radiation is not insignificant compared
to unavoidable natural exposure. The uptake of radionuclides in vegetables and milk that results from the use of phosphogypsum
on mined lands cannot be viewed as insignificant. Such analysis is not science but rather political activism regarding what
is a politically acceptable health risk.
Unless there is an immediate change in policy, it is time to
stop funding this phosphate propaganda mill with a portion of the severance tax. The revenue could be better used by our state
agencies to monitor and oversee repair of the serious damage this industry continues to cause.
_____
Tax-deductible contributions should be mailed to: ManaSota-88, P.O. Box 1728, Nokomis, Florida
34274
