Public Comments Concerning Renewal of NPDES Permit No. CA 0005894
for Evergreen Pulp, Inc. Samoa Pulp Mill
Comment ID / Comment / Commenter NameComment #1 / We have not changed our positions on the dumping of toxins by Evergreen Pulp Mill. It's going to take much stronger standards and some kind of measurable monitoring of what this company discharges into our ocean.
There's got to be increased penalties for violations, because, first, it's so late in achieving any kind of resolution after years and years of pollutions and secondly, if those who are determined to ignore or intend to do what they will to evade by more discretionate (sic) dumping, when caught they ought to pay enough to really hurt their right to continue in business. What else makes better sense in times like these? If not it's bound to go right on.Our oceans have a right to a life of their own, having only our good overseeing to somehow keep some track and order to their survival against the likes of Evergreen. / Jack Nounnan
Comment #2 / The Samoa Pulp Mill has been a source of serious water pollution into Humboldt Bay since at least 1991 when settlement of the Surfrider/EPA suit resulted in a penalty payment of $2.0 million. The recent $463,000 penalty assessed against Evergreen Pulp for excessive waste discharge into Humboldt Bay from 2005 through 2007 (and excess waste discharge during the first 8 months of 2008, for which penalty has apparently not been assessed), as stated in the document to which these comments are addressed, demonstrate that this long history of environmental threat associated with this facility has not yet come to an end. The Citizens Pulp Mill Committee is a watchdog group of people living in or near Eureka, CA formed in the 1995 out of concern for the negative environmental and health effects of pulp production on Humboldt Bay. While we do not pretend to have the expertise required for a technical critique of the document in question, we believe ordinary people living near a polluting facility should-and in fact have a duty to-have input into the regulatory process governing such a facility. Our comments fall into two categories (1) specific to the proposed Renewal Order as presented, and (2) relating to what we see as a serious absence in this (and in many similar) regulatory documents.
(1) Because Orders such as that in question here must necessarily be technical in nature, the average citizen is handicapped when it comes to making an informed critique of specific items. Having said this, two criticisms concerning the content of the draft document as presented occur to us:
(A) Too much testing, monitoring and reporting is left to be carried out by the regulated facility itself; this is like asking the fox to guard to hen house.
(B) Concerning Table E-3 Effluent EFF-001, minimum sampling frequency for the vast majority of the potential Bay pollutants listed is “annually"; we question that this is frequent enough for adequate protection.
(2) We believe that regulatory orders themselves should contain provisions to insure that citizens most affected are assisted to have informed input into the ongoing regulation of the facility to which those orders are directed. In this regard we request that Board Order No. R1-2008-0073 provide, as a part of the renewal permit itself, that at least one annual public education workshop and one annual public comment meeting be held in Eureka (the county seat of Humboldt County) focused on waste discharge into Humboldt Bay from the Evergreen/Samoa Pulp Mill. These meetings should be well advertised and conducted by a representative (or representatives) of the North Coast Water Quality Control Board. Evergreen Pulp should be required to make monitoring data available for both meetings. / Patrick Eytchison,
Citizens Pulp Mill Committee
Comment #3 / I do not support Evergreen Pulp Mill. They have been a health concern for as long as I have lived here. They have repeatedly violated environmental laws and then claimed to be "environmentally friendly". They should not be granted a new permit. If they are granted this permit, they should have to meet more stringent standards and have increased penalties. They are now claiming to have economic problems and announcing layoffs. This is no excuse for breaking the law and endangering the health of animals and people. / Xandra Manns
Comment #4 / Whereas Evergreen Pulp Mill has been guilty of numerous violations of environmental laws and has thereby endangered the health of the people of HumboldtCounty and the animals that live in the bay, we the undersigned ask the California Regional Water Quality Control Board to include stricter standards and monitoring of emissions in Evergreen's new permit. Furthermore, we support increased penalties for violations. / Petition signed by 20 individuals
Comment #5 / I live in West Eureka where I can clearly see the Evergreen Pulp Mill plant from my second story window. Evergreen tries to pass themselves off as friends of the community. In fact, I can see and smell the toxins they put into the air especially at night when they think no one is watching. Now we hear that they are also polluting the ocean. I have a garden full of flowers to attract the birds. Evergreen's poisons endanger these birds and other animals as well as the people who live here. Eureka has a very high cancer rate.
Evergreen does not deserve a new water discharge permit. If they do get this new permit, they need to be monitored much more closely than they have been in the past. They need to be heavily fined for violations. If I break the law, I go to jail. Evergreen breaks the law and continues to make money. / Ann White
Comment #6 / I live in West Eureka. I can smell the Evergreen Pulp Mill from my house. In the past there have been times where I could see particles of grime in the sky, and found layers of it on my car. Once my father, who was sick with Non-Hodgkin's Lymphoma, was hospitalized with respiratory problems during a period of documented emission violations on behalf of the plant. He literally turned blue.
According to EPIC, the rate for Blood cancers (like Lymphoma) is twice the national average in HumboldtCounty. This is also true in several other counties in Northern California and Southern Oregon with Pulp Mills.
My father would write you a letter as well but he can't because he died of Lymphoma.
Evergreen doesn't deserve a new water discharge permit. They regularly break the law. They need bigger fines for their violations. Also, they need to be fined sooner. By the time they are fined, their violations have long since passed. Environmental laws are there for a reason. They need to be fully enforced. / Leila Binder
Comment #7A / This letter is to request that Evergreen Pulp Mill NOT be granted a new Water Discharge Permit. If this is not possible, I ask that the new permit include stricter standards for emissions, increased penalties and independent monitoring to be paid for by Evergreen.
Evergreen has a history of violations of clean air and water standards. The list of System Upsets, Breakdowns and Reported "Deviations" from 2000-2005 is 58 pages long. From January 2005- January 12, 2006 they had "Potential Facility Emission Issues" averaging once every 5 days. (source: North Coast Unified Air Quality Management District) We who live near the Pulp Mill can see and smell that these problems have not been completely solved. Now we find that they have been dumping poison in the Ocean. This is criminal.
Rex Bohn of Evergreen Pulp Mill said that they are working on fixing the problem everyday. I do not believe this. Instead, it is clear to me that it is cheaper for them to pay the fines than replace old dated equipment. The amount they have spent on new equipment is a very small step toward what would be required to bring them into compliance. They have not shown that this is their goal. Instead, they try to do the minimum and pollute whatever they can get away with.
Please act to protect the people of HumboldtCounty, the ocean and the animals that live in it. / Carol Binder
Comment #7B / This is an addendum to my earlier letter in view of recent events. Evergreen Pulp Mill has announced that they will shut down temporarily due to a downturn in the market for pulp. If they are to operate in the future, they need to do so without poisoning our air and water. Please do not be distracted by pleas of financial troubles and the importance of the mill to the economy of HumboldtCounty. It is Evergreen Pulp that has endangered the future of pulp workers and made promises to the people of HumboldtCounty that they had no intention of keeping.
I attended the many hours of hearings on their requests for air quality permits and variances. An outside consulting group did an evaluation of the mill and reported that it was old and poorly maintained. Since then Evergreen has spent some money on the mill, but only because of a lawsuit. However, this is just a fraction of what must be done to replace old equipment and make it possible for them to meet environmental standards. They bought the mill cheap and in my opinion they had no intention of spending the kind of money it would take to bring it into compliance with air and water emission standards.
Stay strong in protecting the environment and the people of HumboldtCounty and California. We need the stricter standards in the new water permit. / Carol Binder
Comment #8 / As a concerned citizen, I urgently feel the extreme importance of not allowing our waterways to be contaminated and our fish populations destroyed. We need stricter standards and increased monitoring so that Evergreen ceases contamination and destruction of the ocean. I urge greatly increased penalties and consequences for violations. / Vicki Caraway
Comment #9 / Please do not grant Evergreen Pulp Mill a new water permit. My mother has had to leave the area for extended periods to avoid their pollution. I am concerned about Eureka’s cancer rate. At least, make them clean up their act.
It is clear to me that they bought Evergreen knowing that it was old and having no intention of spending the millions it would take to bring it into compliance. Now they are claiming financial problems. I am not sympathetic. Please make Evergreen meet strict standards and obey the law or close down. / Monty Caid