Environmental Questions for Niagara Bottling LLC.

Interesting chemical questions directed to Niagara Bottling LLC.
These are questions we need to be concerned within our neighborhoods too.

August 20, 2008

 To:        Rob Kelly
From:    Ronald E. Ney, Jr., Ph.D.
 Subject: Consumptive use application by Niagara Bottling LLC

There are many l concerns that I have concerning Niagara Bottling LLC, bottling plant that I wish SJRWMD and Niagara Bottling LLC would answer.
  • What safety measures will be in place to prevent phthalates, plastic particles (nano-particles) and dioxins from getting into lakes, rivers, groundwater and air?
  1. Will any chemical releases endanger children, adults, pets and wildlife?
  2. The following questions are on chemicals and degradation products that are discharged into the wastewater and solid waste.
  • Will plastic particles be discharged?
  • Will the plastic particles absorb or adsorb any chemicals, if so, which ones and how much?
  • Will the nano-plastic particles absorb or adsorb any chemicals, if so, which ones and how much?
  • What chemicals will be in the wastewater and solid waste and how much?
  • What chemical extraction and determinative methods are used?
  • How where the methods validated and who did the peer review of the methods?
  • Will phthalates be discharged?
  5. The following question concern discharges into the air.
  • What chemicals will be discharged?
  • Will plastic particles and or nano-particles be discharged?
  • Will phthalates be discharged?
  6. Are sanitizers and chlorinated chemicals used and discharged?

 7. What chemicals and what amounts will be stored on the site?

 8. Will any Laws and Treaties of the United States for Protecting Migratory Birds similar to those listed below be violated or any others?

    • Lacey Act
    • Weeks-McLean Law
    • Migratory Bird Treaty Act
    • Endangered Species Act
    • Other Domestic Laws

9. Will any international treaties not listed in 8 be violated because of the contaminated discharge or its reuse on land? If requested I can provide additional list.

 10. The following questions deal with the statement, A report that Niagara prepared for the water management district predicts the company’s water withdrawal could lower some lakes in that part of the county by more than an inch.”
What predictive techniques were used?
  • I would like a copy of these predictive techniques.
    What is the accuracy of the predictive techniques?
    How were the predictive methods validated?
    Who peere reviewed the predictive techniques?
    What comments did the peer reviewers rendered on the predictive techniques?

Thank you,

  Dr. Ron Ney
 Ø Certificate of Achievement and entered into the 16th edition of AMERICAN MEN AND WOMEN OF SCIENCE, January 1987.

Ø In 199-1995, included in Marquis WHO’S WHO IN SCIENCE AND ENGINEERING, Marquis WHO’S WHO in America.

 Ø In 1997, included in the International Who’s Who, Cambridge England
 Retired Supervisory Chemist USEPA (USDA & FDA) and former NREP & Registered Environmental Professional State of California
  • Science Advisor in the Office of Solid Waste Disposal, USEPA; Liaison to EPS’s Office of Research and Development, and Universities Centers of Excellence Research.
  1. Chief of Environmental Chemistry, USEPA; for Fate and Transport of Pesticides in Air, Water, Soil, Plants and Animals, and Modeling. Wrote the data requirements for 40CFR § 158.290 and§ 158.1300 Subpart N.
  2. Department of Agriculture’s Pesticide Registration Division, Supervisory Chemist for Pesticide Tolerance Review for Pesticides in or on food, meat, dairy, eggs, etc. and started the regulations on Fate and Transport of Pesticides in Air, Water, Soil, Plants and Animals.
  3. Food and Drug Administration, Laboratory Group Leader for Total Mercury Analysis.
  4. Assistant Referee for the Association of Official Analytical Chemist for Total Mercury determination in treated seed.
  5. Collegiate Professional Teaching Certificate to teach chemistry, science and biology.
  6. Adjunct Assistant Professor/Instructor for College Chemistry (general, organic and biochemistry), Topics in Environmental Issues, Topics in Environmental Risk in Real Estate Transactions and Real Estate Appraisal.
  7. Principal Real Estate Broker and Certified Real Estate Appraiser.
  8. Author of Where Did That Chemical Go?, Fate and Transport of Organic Chemicals in the Environment, Your Guide to Safety and Chemicals: What you need to know.
  9. Member on the Dioxin Disposal Advisory Group in the USEPA in the early 1980’s.
  10. I have explained environmental data in court cases for the USEPA and with the DOJ and have served as an expert witness on environmental cases.

I have reviewed and/or supervised the review of data on plants, animals, air, soil and water to make regulatory decisions and enforcement decisions (actions) and other type reviews.

 1.   I have reviewed about 10,000 pesticides labels for chemical names, crop restrictions, etc.
 2.   I have reviewed about 3,000 reports for pesticide petitions for tolerance (chemical residues in crops), rotational crops, planting restrictions, etc. I wrote many data requirements for this under FIFRA, which were adopted by FFDCA (pre USEPA).
 4.      I have reviewed about 500 reports for environmental chemistry data on fate and transport of pesticides in air, water, soil, plants and animals. These data requirements were written and started by me.
 5.      I have reviewed microbial studies proposed by NASA for research in space.
 6.     I have reviewed studies for the disposal of radioactive material at Yucca Mountain.
 I have reviewed many pesticide studies on fate and transport submitted by the USACOE to USDA and USEPA.

 

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