Thursday, July 7, 2016

EXPEDITED FOIL Request + 90 days comment re: 7-0346-32/07 i3 Electronics Inc SPDES NY0003808

Hi Sandra, Tim, Reginald, Teresa,

FYI -- I have submitted FOIL Request :: W009352-070616

For the following documents:

In the public notice for the i3 Electronics SPDES permit NY#0003808 renewal, Application ID: 7-0346-00032/00007, I found this: QUOTE: State Environmental Quality Review (SEQR) Determination: Project is an Unlisted Action and will not have a significant impact on the environment. A Negative Declaration is on file. A coordinated review was not performed. ENDQUOTE I would like a copy of the SEQR "Negative Declaration" and all supporting documents. I would like CLEAR original documents, with searchable text. (not bad, unreadable scans) Thanks

The response I received says this:
"You may expect the Department's response to your request no later than 8/4/2016"

However, this is PAST the close of the comment period for NY3808 SPDES permit.

Can you please treat this request with expedited processing?

This information is a critical component to the package of documents which should have been provide to us LOCALLY for review. We should not have to drive to Albany as your public notice states. These data are critical for my comments on the docket and to evaluate whether SAPA and SEQR procedures were followed.

Additionally, I am asking for an immediate extension of the public comment period to 90 days so that our team can have adequate time to review this material.

My Assemblywoman Donna Lupardo joins us in this request for 90 days, as well as a request for additional public informational sessions, and public hearings in Endicott, and in downstream communities.

On behalf of Concerned Citizens of Endicott, and NY Friends of Clean Air and Water, I am making the additional PRELIMINARY commants/demands:
  1. 90 day comment period
  2. Multiple informational sessions in Endicott and downstream communities of Owego and Waverly, with personnel from i3 there (Pelto / Speranza) to answer questions
  3. Multiple public hearings in Endicott and downstream communities (Owego/Waverly) with 30 days advance notice, and a court stenographer present, were people can give oral testimony.
  4. FULL REVIEW of environmental impacts as per SEQRA (Type-1 Action => EIS)
  5. Copies of application, SEQR Negative Declaration, draft permit, and other relevant documents in public libraries in Endicott and in downstream communities (Owego, Waverly) available for review THROUGHOUT the duration of the 90 day comment period. (This may require a restart)
  6. Site tour for up to 10 of us, with ability to videorecord and publish.
  7. Stipulation: Local site-generated wastes ONLY-- no commercial, for-profit waste dumping operation in Endicott!
  8. i3 Electronics must post a $5M bond for cleanup costs from potential spills.
  9. DEC must perform a physical inspection of the plant by an independent engineer to assess the integrity of the tanks, piping and other equipment, and i3 must make repairs prior to the issuance of the permit should non-compliance be found.
  10. DEC must establish a protocol for doing CONTINUOUS MONITORING of the effluent and allow the public easy access to this data.
  11. DEC must establish a protocol for frequent and random site inspections, to check for proper operation, and operator qualifications.
  12. DEC must establish a protocol for establishing the qualifications of plant operators.
  13. DEC must establish a protocol for FINES for non-compliance with safety regulations or provisions of the Clean Water Act, including spills, and shut down the plant should another spill happen until the integrity of the equipment has been independently verified. (This site/operator has a LONG HISTORY of contamination due to intentional dumping, neglect, and incompetence)
  14. i3 Electronics must FOLLOW THE LAW with regards to notification of DEC and the community in the event of spills or equipment failures which endanger the public.
  15. DEC must perform an Ambient Air Test at 5 locations within 1/2 mile of the facility.
  16. Lastly, we want a member of our team to be able to obtain a grab sample of the effluent on an unannounced, random date/time for independent lab testing PRIOR to the close of the comment period.
Again, these are only my PRELIMINARY comments. Additional technical comments will be forthcoming when we are able to obtain all of the documents, and have adequate time to review.

Best Regards,

May you, and all beings
be happy and free from suffering :)
-- ancient Buddhist Prayer (Metta)

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