Turnkey Landfill Expansion

For those interested, there is a proposal in Rochester to expand the Turnkey landfill bringing it closer to one of Dover’s public drinking water re-charging stations along the Isinglass river. At this point Dover has not been consulted and the public response period has ended. Our Community Services Director (John Storer) has sent a letter to the department of environmental services (DES) looking for additional water quality protections and adequate studying to ensure Dover is not negatively impacted by this expansion project. There is also a traffic flow concern as the proposal will relocate Rochester Neck Road. At this point, we should all understand the importance of keeping our public water supplies clean and free of toxins. We are hopeful that the agency meant to do that (DES) will agree with our position and ensure we are not paying for this 20 years down the road with a toxic water supply.

Here is the letter sent to DES from John Storer:

Jaime M. Colby, P.E.
Solid Waste Management Bureau
Waste Management Division
NH Department ofEnvironmental Services
PO Box 95, 29 Hazen Drive
Concord, NH 03302

Subject: Proposed Expansion of TLR-III Refuse Disposal Facility (Turnkey Landfill)
Comments submitted on behalf of the City of Dover

Dear Ms. Colby:

The City of Dover, New Hampshire submits these comments on the proposed expansion of the Waste Management TLR-III Refuse Disposal Facility. The City has concerns regarding odor control management, increase in vehicle traffic, and most importantly the potential to contaminate one of our downstream public water supplies.

The City owns and operates a water intake structure on a property abutting the Waste Management property, which in turn abuts the Isinglass River in Rochester. The City withdraws water directly from the Isinglass River, which is then pumped to an infiltration basin that provides recharge to two public water supply wells in the Hoppers sand and gravel aquifer deposit. The proposed expansion of the Waste Management TLR-III Refuse Disposal Facility is of great concern to the City. It is imperative that water quality of the Isinglass not be adversely affected by this or any of the activities on the Waste Management property. We request that NHDES mandate an aggressive water quality monitoring program to track any potential contamination.

A cursory review of the application reveals the presence of 1,4 dioxane has impacted groundwater at the current site and that the origin of the 1,4 dioxane release is a matter of speculation. Unfortunately the discovery of a contaminant like 1,4 dioxane above NH AGWS eliminates the use of the water for drinking water purposes. If water is to be used for public consumption it would require a very expensive treatment system be installed to remove it. Unfortunately the City is well versed in the hardship involved in wells being contaminated from abutting properties. The technical, financial, and often times legal aspects in finding alternative sources or treating contaminated source water is challenging particularly when a responsible party and the regulatory community are involved. The time required to sort out solutions, construction, and who pays for it all do not address the immediate water deficit the community has to deal with until the source is restored.

The proposed application is thousands of pages and it’s an enormous task for a community to review it with existing staff who are not experts in the area of siting, constructing and operating a landfill of this magnitude. Ultimately, the City and its residents must rely on the NHDES with their expertise in solid waste, wellhead protection, and stormwater run-off to provide the technical review to insure the protection of the State’s resources. The City of Dover and the other residents of Rochester and Barrington are relying on NHDES to look out for their interests now, the ensuing 40 years while the project is built out, and long after it is closed and no longer generating money for its owner.

While the City understands that the NHDES has provided a comment period and needs to proceed with the review of the application, the City requests that the comment period be extended for another 15 days. The magnitude and proximity to the City’s water intake structure is a critical infrastructure component and the City needs additional time to evaluate the potential impact. Should DES not grant an extension of the comment period, a commitment from NHDES to consider additional technical review comments that are brought to light by the City or its technical experts in the next 15 days would be helpful.

City of Dover’s residents in the northwestern half of the community were previously inconvenienced for a substantial period of time with odor issues emanating from the Turnkey facility. After a prolonged period of complaints, Waste Management effectively addressed the odor issues. It is imperative that the odor issue not reoccur and adversely and unfairly affect the quality of life of downwind residents. We hope this is definitively addressed, including a mandate that daily cover material be actively used to seal the open disposal areas.

Lastly, The City of Dover currently receives a considerable volume of truck traffic on its roads related to trucks dumping at the Waste Management facility. We understand the expansion of Turnkey will include the relocation of Rochester Neck Road. The City wants to be assured that the proposed changes do not generate additional traffic volume to accommodate the proposed expansion. There should be a Traffic Management Plan that restricts trash haulers to prime arterial routes along State highways.

Thank you for consideration of these comments. Although the official comment period may be closing, the City will continue to work with its public water supply hydrogeologists to review the expansion. It’s imperative we actively protect the drinking water supply for Dover.

Sincerely,

John B. Storer,
Community Services Director, City of Dover

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