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Natural Spikes
The environmental advocates of HEAL Utah check the state’s online database of groundwater-permit applications the way some people check Facebook. On Aug. 5, 2013, staff came across a permit application for the renewal and expansion of the Sunnyside Cogeneration Associates (SCA) landfill in East Carbon. At the time, it was open to public comment until Aug. 22, 2013. HEAL Utah asked for the public comment period to be extended while it researched the proposal with the collaboration of environmental attorneys.

A representative of Exelon, the energy company that owns the SCA power plant, wouldn’t comment on specific concerns about the coal ash plan other than to say that all technical questions would be addressed during the groundwater permit application process.

The Utah Department of Water Quality (DWQ) denied Heal’s request for an extension. HEAL Utah filed a public-records request Aug. 9 for information pertaining to the expansion of the landfill. The DWQ responded to the request Aug. 28—six days after the end of the public comment period—and gave HEAL permission to access and make copies of additional information. The additional information from the DWQ, HEAL says, was a 2007 report from one of the monitoring wells dug to check the groundwater adjacent to the landfill for potential contaminants.

HEAL filed public comments complaining of inadequate information made available to the public. Then, HEAL says, on Dec. 4, the DWQ posted 16 additional monitoring-well reports onto its website. HEAL quickly dug into the reports and had Brigham Young University geologist Steve Nelson begin crunching the numbers and analyzing the data. But only two days later, on Dec. 6, 2013, the DWQ gave Sunnyside Cogeneration Associates the go-ahead to move forward with expansion.

Walter Baker, director of the DWQ, says there was “no shortcut in the process,” and that it’s not uncommon for permit applications to not include all the data the division has about a particular groundwater application.

“Not everything is on the website,” Baker says. “If someone would like additional information that would not normally be included in the process, they can request it.”

Baker says his agency “bent over backwards” to provide as much information as possible about this permit.

But HEAL says the 16 additional reports were vital—and also incredibly late, too late to be included in comments that could have informed the public’s opinion before the expansion was approved.

At the heart of the debate over the future of SCA’s big pile of ash is whether this landfill poses any peril to the groundwater beneath. The landfill lacks a liner to separate the hundreds of thousands of tons of ash from the groundwater below, but the site is bounded by a layer of Mancos shale, which, DWQ says, acts as a barrier against contaminants leaching into the groundwater. The new expansion will also utilize sediment traps to collect drainage running from the benched slopes of the expanded landfill to the bottom of the disposal area.

When HEAL obtained the additional monitoring reports—three months after the end of the public-comment period—they turned them over to BYU’s Nelson, who used the different well reports to compare the chemicals appearing outside the landfill with those occurring right under it. The DWQ says that there are a number of chemicals that could be considered contaminates registered in the area, but says that those chemicals occur naturally.

But according to HEAL’s complaint, Nelson’s analysis—which he carried out independently and is not affiliated with BYU—shows that three troublesome chemicals—chloride, sulfate and TDS or “total dissolved solids”—maintained a steady concentration outside of the landfill, but within the landfill’s 1,000-meter boundary, these chemicals “dramatically” spiked. His spatial analysis shows concentrations five to seven times higher within the landfill’s boundaries compared with outside it. For TDS, for example, Nelson found that 13 of 30 reported values from DWQ’s own data show the landfill being out of compliance.

In HEAL’s complaint, Nelson says SCA’s existing landfill is in “chronic violation” of its allowable contamination limits for TDS alone.

The DWQ has not yet responded to Nelson’s analysis of the groundwater, but said in response to public comments that spikes of noncompliance of certain chemical concentrations aren’t the giant pile’s fault, but are just part of the natural geological landscape, including the effect of six years of drought in the area.

Nelson’s comparison of reports from wells under the pile and outside of it challenges that assumption, according to HEAL’s complaint. If drought were to cause spikes within the landfill, then, logically, spikes would occur outside of it as well, and at a similar rate—but they don’t.

Nelson compared the wells with Whitmore Springs, which is upstream from the pile, and found drastic differences even during times of drought. Nelson’s data shows increases by a factor of nearly seven in chloride and sulfate from a monitoring well under the landfill compared to sources outside it.

While the biggest spikes appeared to be in TDS, chloride and sulfate, Nelson’s research also sounded a warning about four different monitoring wells under the pile that are spiking out of legal compliance for reported concentrations of selenium. While not as significant as the others, selenium can take a nasty toll on animals that ingest it, and the ill effects of too much of the trace element can be passed up the food chain. If humans take in too much selenium through eating contaminated food or drinking contaminated water, there is a danger of acquiring selenosis—a nasty ailment that can cause hair loss, gastrointestinal disorders, fatigue and even neurological impairment.

The “protection value,” or upper limit, of allowable selenium pollution established in the permit for these groundwater wells is .0125 per liter of water. Nelson found that Whitmore Springs, uphill from the pile, never exceeded this limit even during the drought period, whereas “up to 41 percent of [selenium] concentrations in monitoring wells are out of compliance with the protection limit.”

Incomplete Data
It’s not just the analyzed data that Nelson and HEAL found troubling, but also the unknown factors.

Though Sunnyside Cogeneration Associates first got approved for its coal ash landfill in 1992, the earliest publicly available reports are from 1998, six years after the pile started building up.

But while the existing landfill is monitored by five wells, only one monitoring well has been dug to monitor the groundwater for the expansion—which, when completed, will cover 34 acres and be within two miles of town.

The SCA expansion will also lack a monitoring well that’s upgradient, meaning there won’t be an upstream monitoring well to compare with the well on the site of the new ash pile.

DWQ scientist Daniel Hall said in an e-mail that “the uphill cliff topography also does not allow for access to an up-gradient well location.” Hall also wrote that the same number of monitoring wells wasn’t needed for the expansion because the agency is more knowledgeable about coal ash than it was previously.

“When the first ash landfill was permitted over 20 years ago, less was known about the leaching potential of the coal ash, the site hydrogeology and natural background quality of the underlying aquifer,” he wrote.

But Nelson says in the HEAL complaint that there’s no documentation of the first six years of monitoring. The complaint says that if DWQ has learned enough about coal-ash contamination in the past 20 years to justify less monitoring of a new landfill, then the homework should prove it—not just to HEAL, but to the public and the people of Sunnyside and East Carbon.

Hall says that permits can always be re-opened and considered after passage if new data finds inaccurate readings of groundwater quality. But Nelson’s report, however, contradicts this sentiment, given his assessment of the DWQ’s own reports that found drought-defying spikes of illegal and hazardous groundwater contamination.

In his brief to the DWQ, Nelson concludes, “The strong evidence of releases from SCA #1 that have not been recognized and addressed by DWQ is disturbing.”

It’s Not Your Backyard
It can sometimes be difficult for environmental advocates to make people appreciate how often they use resources—water, dirt, air—that are so widely available and are easily taken for granted. And when it comes to coal ash, HEAL supporters need a bunch of Salt Lakers to care about a landfill hundreds of miles away that won’t directly impact them.

For HEAL director Chris Thomas, coal ash is just another part of an industry that provides the power for most of Utah. While Rocky Mountain Power doesn’t own Sunnyside Cogeneration Associates, it does buy its power and, according to a 2013 Integrated Resource Plan for PacifiCorp—the company that owns Rocky Mountain Power—the company does operate 16 “coal combustion byproduct” surface impoundments and six landfills.

“We buy power from Rocky Mountain Power, and the Sunnyside coal plant provides some of that power,” Thomas says. “So while most of us are blissfully ignorant in some ways about where our power comes from and what effect it has, it’s not so for those people who live in East Carbon and Sunnyside ... they’re impacted on a daily basis by it.

“We should know what’s going on down there and ask for it to change,” he continues.

Hunt, a coal miner, understands firsthand the importance of balancing jobs with regulations that can stifle rural economies. But when it comes to the coal-power plant and the truckers who haul the sizzling ash through town to the landfill, it’s easy to draw a clear line when it means having another 34 acres of ash landfill within two miles of town—jobs or no jobs.

“There are some who might be able to look past what the corporation they work for does, because it’s not affecting their kids,” Hunts says. “But you don’t have an ash dump a mile away from the place where you ride bikes with your kids. It’s just not right.”