The Jordan Valley Water Conservancy District proposes a discharge of selenium-tainted water into Great Salt Lake via a 21-mile long pipeline. This proposed project poses many threats to the Great Salt Lake Ecosystem. We urge the public to submit comments to the Utah Division of Water Quality concerning the discharge permit for this project. Comments are due February 1, 2011. JVWCD Project Overview (an excerpt from the DWQ website): "This project is a part of the larger groundwater cleanup project currently underway to clean up ground water contaminated from historic mining activities in the Oquirrh Mountains in southwest Salt Lake County. The cleanup project makes use of reverse osmosis, a process where high pressure forces contaminated water through a semi-permeable membrane. The contaminants are separated from the water as it moves through the membrane and are trapped. Drinking quality water is allowed to flow free. The byproduct water—primarily dissolved salts and traces of selenium—remains. The Utah Division of Water Quality received a request from Jordan Valley for a Utah Pollution Discharge Elimination System (UPDES) permit to discharge this byproduct water via a 21 mile pipeline running from the Jordan Valley facility in West Jordan to the mouth of Gilbert Bay along the south shore of the Great Salt Lake (see a Discharge Location Map). UPDES permits are granted to facilities that demonstrate they can comply with the requirements of the Clean Water Act and the Utah Water Quality Act. UPDES permits include effluent limits and permit conditions that insure the beneficial uses of the receiving water are protected." Please help protect the Great Salt Lake by submitting comments to the Utah Division of Water Quality regarding this UPDES permit. Comments may be submitted in writing to: Kim Shelley, Environmental Engineer, Utah Division of Water Quality
P.O. Box 144870
Salt Lake City, Utah 84114-4870
kshelley@utah.gov This e-mail address is being protected from spambots. You need JavaScript enabled to view it Please read the press release and visit the DWQ website for more information about the project and to view the draft UPDES permit. Not sure what to include in your written comments? View Utah DEQ's tips for submitting public comments. Additional ideas are offered below. FRIENDS of Great Salt Lake has a number of concerns regarding this draft permit: Cumulative Impacts, Monitoring and Analysis -
1. If approved, the permit will approve a system that will be in place for at least 40 years. Although it will be evaluated and renewed every 5 years, it is possible that loading and concentrations from the mining contaminants could have significant impacts to wetlands along the Jordan River and Great Salt Lake where natural processes retain and recycle selenium and mercury.
What happens if selenium levels begin to increase? What happens if methylation of mercury goes up or things begin to spin out of control? What are the alternatives to discharging into the Jordan River or Great Salt Lake? How will DWQ address Kennecott Utah Copper’s (KUCC) Outfall 012 which is located within 50’ of the JVWCD pipeline and is a tandem contributor of contaminants to the Lake?
2. The Comprehensive Sampling and Analysis Plan is Missing - A critical omission in the draft permit for public review is the Comprehensive Sampling and Analysis Plan. JVWCD is supposed to provide the Plan to the Executive Secretary of the Utah Water Quality Board by February 1st. Presumably the Plan would include the nuts & bolts of the sampling, monitoring, and analysis regimes for 001 Outfall (Gilbert Bay), the transitional wetlands created by this outfall, the open waters of Great Salt Lake, Outfall 002 (Jordan River), and wetlands along the river.
Without the Plan we can only guess what the scope of monitoring and sampling will be, what metrics will be implemented, and who exactly is accountable for submitting detailed and timely reports to the Division for review. (The draft permit suggests coordination and “cooperation” with KUCC as a neighboring discharger in some sampling and monitoring activities). How are we supposed to know what accountability criteria are in place to ensure the protection of the resource, how these criteria reconcile with the draft permit, and who is overseeing what part of the sampling and monitoring?
FRIENDS and members of the conservation community believe that under no circumstances should a discharge permit for JVWCD be approved without ample time to review and comment on the Comprehensive Sampling and Analysis Plan.
Selenium
3. No Selenium Data Have Been Collected Since 2007 - The draft permit allows JVWCD to discharge a selenium concentration of .54 ug/L (ppb) through the 001 Outfall - the same concentration currently permitted by KUCC’s 012 Outfall 50’ away. This is not without contention from FRIENDS and other conservation interests. No data on selenium levels in the Lake or in bird tissue have been collected since 2007 when the work on a numeric standard for selenium was in progress. During that study period, increasing trends in selenium levels in Great Salt Lake were observed but monitoring did not continue after the standard was determined. Two very important areas that were not studied in the scope of work were groundwater sources and airborne deposition to the Lake. Dust events from Kennecott’s tailings impoundment could be a contributing source of selenium to the Lake, but we don’t know that because it was never studied.
In 2009, the U.S. Geological Survey (USGS) identified a potential area of groundwater discharge of selenium along the south and eastern shore of Gilbert Bay in the vicinity of the Kennecott property. Further study by USGS to quantify and monitor the amount, source and chemical quality of this “missing” selenium load is in progress. It’s clear that there is a significant knowledge gap about concentrations of selenium in the open waters of the Lake.
In an attempt to encourage effective regulatory decisions to protect the resource, we recommend that the Division not approve the permit without first reviewing the USGS monitoring work. Ideally, more bird egg tissue analysis and water sampling would be added to the mix before the permit is approved. We would certainly like to see a lower selenium concentration level in the permit, as well as monitoring in the open waters of the Lake where loading or accumulation of these concentrations may occur.
How Can the Division Allow for a Mixing Zone that Doesn’t Exist?
4. Since 2007, the Lake level has dropped over 3’ in elevation. The current lake level in Gilbert Bay is 4194.5’. The elevation of the 001 Outfall is 4208’ – a 13.5’ difference. JVWCD’s selenium discharge of .54 ug/L is supposed to be diluted by 2:1 with water from Great Salt Lake in a “mixing zone” that extends for 200’ beyond the end-of-pipe discharge point. The theory is that the concentration of the contaminants is cut in half in a mixing zone. Mixing zone models typically come from river systems where flows are constant and a certain area for mixing the contaminants is required. Since the discharge currently flows in an open channel that extends over 3/4 of a mile from the end of the proposed discharge point to the open waters of the Lake, with no other water flowing into it, it’s impossible for any mixing to occur within that channel, let alone within the first 200’ from the end of the pipe. (Another red flag here). This condition creates a problem because it exposes undiluted contaminants to the soils, biota and wildlife attracted to this manmade “transitional wetland.” Many scientists have suggested that this transitional wetland – which in effect constitutes an attractive freshwater nuisance for birds – should not exist. We agree.
Relying on a mixing zone under these conditions is problematic at best. We know this from our work on the Kennecott UPDES permit for the 012 Outfall. The Division should find a better way to ensure that the selenium concentration is effectively diluted. Perhaps more water for mixing within the pipeline is the answer but the uncertainty of this condition is untenable.
Mercury
5. Currently there is no water quality standard for mercury in Great Salt Lake. We know that 3 species of ducks that use the Lake are in trouble because of high concentrations of methylmercury in their tissue. To date, JVWCD has not fully characterized the total and methylmercury concentrations in Zone B or the shallow aquifer of the Jordan River. Expert resources have raised concerns about the possibility that methylation of the waste stream might actually occur in the pipeline.
Upon approval of the draft UPDES permit, JVWCD will have one year to fully characterize the aquifer. We think this is a cart before the horse arrangement and the permit should not be approved until this information has been reviewed by DWQ and the public. | 
