As a Butte-Silver Bow resident, I am concerned about the open sewage lagoons for Love's Truck Stop next to Ramsay.

I have a degree in Industrial Safety and Hygiene and have worked on the most contaminated sites in the United States. When I read about the proposed open-air human waste sewage lagoons, red flags raised everywhere since the last 16 years of my career before retirement were in hazardous waste site clean-up.

I contacted the Montana Department of Environmental Quality with questions. The answers only raised more concerns:

1. Love's site covers 28 acres. Two lagoons, 3 acres and 2 acres in size, will be on site. Five acres of sewage lagoons?

2. Love's chose open sewage lagoons because a loophole in Montana Law allows this type of sewage treatment to circumvent the usual public review and comment process. What is Love's trying to hide?

3. Apparently Love's told the DEQ Ramsay refused to allow it to tie into Ramsay's sewage lagoon, which left it with no choice. This is misleading. Ramsay's lagoon is only approximately 1/3 acre in size, designed for only household waste water for 42 households, and uses biological decomposition to neutralize the waste.

Love's is a commercial site that will operate 24 hours a day. Two entirely different purposes.

4. About 4,000 gallons of human waste will enter Loves' lagoons daily. That equals 1,460,000 gallons of human commercial waste each year. The odor will likely be smelled from a considerable distance.

5. The lagoon treatment will be coagulation and floculation (1 process) but with no skimming or filtration. Internet information is abundant on this process. Simply put, large solids will separate and sink to create Class B biosolids (sludge) that will have to be dredged and then disposed of. Class B biosolids cannot be used for fertilizer for any human oriented crops grown in agriculture, including animal feed. Only Class A biosolids (treated with multiple processes in treatment plants) can be used for agriculture [Title 40 CFR (Code of Federal Regulations) Section 503]. Many coagulant and floculant agents themselves will cause cancer and must be separately removed.

6. According to DEQ no plan exists for disposal haulage of the sludge. Attempted without proper equipment, public roads and highways could be contaminated because the sludge will not be dry and water from the sludge could drip on public roads.

7. Water from the lagoons will be sprayed on fields for livestock grazing. But, EPA 903-9-75-017 provides great detail on how water from only 1 treatment process must not be used for this because the plants grazed on will contaminate the animals consuming the plants and enter human consumption through the meat. Only water that goes through multiple processes including disinfection is to be used for this type of application.

8. According to DEQ, no actual proposed collection process exists for wastes such as degreasers, cleaning chemicals, soaps, cooking oils, food waste products, liquid waste from Love's on-site tire repair shop, truckers' showers, site outside cleaning operations, or even fuel spills. So, in reality, these will probably end up in the lagoons.

9. The only DEQ oversight will be an inspection every 5 years, meaning regulatory oversight will essentially be nonexistent. And, no company or corporation is going to really police itself.

10. All this means increased potential for spread of pathogens; things like Hepatitis A, B, and C; Salmonella; Legionella; viruses; bacteria like E. Coli; parasites; molds; and quite an extensive list of chemicals, pharmaceuticals, and insect borne diseases (example: West Nile Virus) since there will be a lot of patrons from different areas of the country. The internet is abundant with information on this.

11. Commercial open sewage lagoons are not currently common in this county. But, Love's lagoons approval could definitely start a trend.

In my opinion, reason exists for serious concern. Maybe that's why Love's wanted to avoid a public review and comment process. Makes you think, right?

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