Hudspeth county Merco
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Dan Pearson, Executive Director TNRCC, requests Motions for Reconsideration by Bill Addington and Milburn Dodge be denied.
8/15/97

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Above is a photo copy of TNRCC Executive Director Dan Pearson's Response to Motions for Reconsideration, dated August 15, 1997. The excerpted paragraph is from page 5 of the response. The text of that page is detailed below.

Below are links to the scanned images of Dan Pearson, Executive Director's Response to Motions for Reconsideration Filed by Bill Addington and Milburn Dodge. The gif images of each page of the motion average about 20kb.

Page 1, Page 2, Page 3,
Page 4, Page 5, Page 6, Page 7

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3. Concerns expressed by Ms. Dodge

Ms. Dodge complains of the odor associated with the sludge and expresses concern that the sludge trespasses into her property when transported by wind and rain, which results in her property being devalued.

According to the TNRCC region 6 office, there have been no odor complaints relating to the Merco site since July 29, 1996. That complaint investigation found no nuisance conditions. Properly digested and stabilized sludge may have an earthy odor when it is first applied, but the odor will soon disappear. Citizens are advised to place a complaint call to the TNRCC Region 6 office if there are any objectionable odors originating from the beneficial use site.

The registration approval letter sent to Merco states that the land application site shall be operated in a manner to prevent public health nuisances. Where nuisance conditions exist, the operator shall take necessary action to abate such nuisances. Some sewage sludge and sewage sludge application methods create dust or spray that can be transported off-site. Methods that may create dust or spray include splash plate, beat drying and incorporation. Merco does not employ any of these methods. Merco spreads drying bed sludge (appr 15%-30% solids) on the range land using spreaders. Since the sludge particles (moist) are heavier than air, they settle down before traveling too far. In addition, the buffer zones at this site should be adequate enough to prevent the offsite movement of sludge. Therefore it is unlikely that sludge is trespassing Ms. Dodge's property. The TNRCC is unaware of any land application site in Texas causing a depreciation of value for adjoining land.

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