Attention: Allan Moore
Solid Waste Program Manager
Great Salt Lake Advisory Council https://deq.utah.gov/great-salt-lake-advisory-council/index.htm
January 10, 2018
Utah Division of Solid & Hazardous Waste Department of Environmental Quality
195 North 1950 West
Salt Lake City, UT 84116
Re: Promontory Landfill Class V RDCC Project No. 59842
At a meeting of the Great Salt Lake Advisory Council (“Council”) held today, Council members voted unanimously to send this letter to identify initial questions, issues and concerns related to Great Salt Lake (“GSL” or the “lake”) that the Council believes need to be addressed in the permitting process associated with the proposed change to the Promontory Landfill, referenced above, from a Class I to a Class V landfill.
Great Salt Lake Advisory Council Duty to Advise and Assist the Division of Environmental Quality in its Responsibilities for Great Salt Lake
The Great Salt Lake Advisory Council (“Council”) was established by House Bill 343 in the 2010 session of the Utah State Legislature. Council members are appointed by the Governor and confirmed by the Utah Senate.
The duties of the Council include:
- Advise the Governor, the Department of Natural Resources (“DNR”), and the Department of Environmental (“DEQ”) on the “sustainable use, protection, and development” of GSL; and
- Assist DNR and DEQ and their boards in their responsibilities for GSL.
The Council submits this letter pursuant to those statutory responsibilities and requests your Great Salt Lake Advisory Council (continued) January 10, 2018
- consideration of these questions, comments and concerns.
Economic & Ecological Values of the Resource
A 2012 economic study commissioned by the Council estimated economic output generated by GSL at $1.3 billion, including $1.1 billion from evaporative mining, $136 million from tourism and recreation, and $57 million from the harvest of brine shrimp. The study estimated that those industries resulted in $375 million in paychecks and supported 7,706 local jobs. These economic contributions are dependent upon a healthy GSL ecosystem.
The Great Salt Lake also has significant ecological value. It plays a critical role for birds, including some of the largest concentrations of certain species of waterbirds in the Western hemisphere and, in some cases, the world. Over five million birds from 257 different species rely on the lake to live, feed, rest, breed and nest. The lake plays a particularly critical role for migratory birds. Birds come to the lake by the millions to eat and rest during migration, and other species stay to breed, nest and raise their young. The lake contains abundant food for birds, including very important brine shrimp and other macroinvertebrates. These ecological values depend upon a healthy ecosystem.
Questions and Concerns Regarding Proposed Class V Status for Promontory Landfill
The letter is not intended to reflect a detailed analysis of the application, nor or an exhaustive list of potential issues to be addressed in the permitting process. Rather the letter attempts to identify questions and concerns broadly shared by Council members. Those questions and concerns include the following:
- Adequacy of measures designed to mitigate impacts associated with fugitive dust, debris, and materials not deemed hazardous, but that have sufficient risks posed to human health and the environment (i.e. coal combustion residuals or material which technically meets a listing or exhibits a characteristic which would normally meet the hazardous waste definition) that will be generated from the site itself;
- Adequacy of measures designed to mitigate impacts associated with dust, debris, and materials not deemed hazardous, but that have sufficient risks posed to human health and the environment (i.e. coal combustion residuals or material which technically meets a listing or exhibits a characteristic which would normally meet the hazardous waste definition) that will result from transportation of materials to the site;
- Sufficiency of existing studies to determine the scope and potential migration of leachate generated by stored waste at the facility; specifically for long term storage and degradation of liners over time and the potential environmental consequences of leaks to Great Salt Lake;
- The adequacy of plans and infrastructure designed to collect leachate from waste and ensure that it does not contaminate groundwater, endanger wildlife, or enter the lake; both now and into the future.
- Given the density difference of leachate and GSL water, there are concerns that leachate would ‘float to the top’, thus creating a toxic surface lens; Design standard adequacy in this environment to handle runoff equal to or greater than a 100-year rain event;
- The potential for containment failure, particularly as it relates to earthquakes, subsidence, seiche waves, and liner degradation over time;
- Sufficiency of studies and plans to secure the protection of avian resources and their critical food chain;
- Sufficiency of plan design to address fractured bedrock beneath the site and movement of groundwater through it, which creates natural pathways for leachate and associated toxins to contaminate groundwater and for that contamination to spread;
- How the permittee will address the Coal Combustion Residuals Federal Rule for recordkeeping and reporting requirements as well as the requirement for each facility to establish and post specific information to a publicly-accessible website;
- Adequacy of project design to address the risk of large volumes of materials (toxins) in close proximity to Great Salt Lake. (With coal combustion residuals a significant portion of the waste stream in the United States, and this landfill seeking the license to accept such waste, the likelihood is high that significant volumes of coal combustion residuals would eventually make their way to the Promontory landfill. Such waste contains heavy metals like arsenic, lead, mercury, as well as other toxic substances that can migrate from a waste repository by windblown dust, groundwater or other means.) The location of this site poses a particular challenge given its close proximity to, and location immediately uphill from, GSL. That location means that, if these concerns are not adequately addressed along with ample safeguards and planning for the unexpected, the landfill could pose a catastrophic threat to GSL, a natural resource of hemispheric—if not global—importance.
Unique Nature of the Site and Associated Risks. The location of this site poses a particular challenge given its close proximity to, and location immediately uphill from, GSL. That location means that, if these concerns are not adequately addressed along with ample safeguards and planning for the unexpected, the landfill could pose a catastrophic threat to GSL, a natural resource of hemispheric—if not global—importance.
At a minimum, the Council believes further studies are needed to determine the full extent of the risks and the adequacy of the measures designed to address them. Those studies include a more extensive study of groundwatermovement on Promontory and how this facility could affect ground and surface water resources, as well as the adequacy of the facility to (i) capture and process leachate; (ii) prevent the escape of fugitive waste and other debris; (iii) prevent fly ash or other toxic dust from entering the environment from the landfill or from transportation to the landfill; and (iv) withstand natural disasters such as earthquakes, seiche waves which have occurred, and will likely occur again in this area, as well as degradation of the liners over time.
Thank you for your consideration and for the opportunity to pose these important questions and provide these initial comments.
If there is information that the Council could provide to assist the Department of Environmental Quality in evaluating this proposal, please let us know.
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