Earthjustice and the Sierra Club filed formal comments with the state Friday calling for more study of the new combustion waste landfill that will serve Sunflower Electric's 2100 MW power plant expansion at Holcomb, Kansas.
The permit application and associated documents show that the company plans to amass some 540 million cubic feet of coal ash, water treatment sludge and scrubber residues only a mile from the Arkansas River. The site of the landfill is over a state-designated sensitive groundwater area, and what the Kansas Geological Survey describes as highly permeable sand dunes. The landfill design fails to require an adequate cap and impermeable liner under the waste to protect the underlying Ogallala aquifer over the long term. The dump site adds to an existing landfill that has been operated for 20 years with the monitoring wells in the wrong location, and therefore insufficient data is available to assess pollutant migration.
The waste material will never break down but could leach into a highly vulnerable and important ground water resource. The Ogallala is the area's primary source of public drinking water, and water for agricultural and industrial purposes. Experts have questioned what will happen after the owner is no longer required to maintain the facility, after the vegetative cover dries up and cracks, and erosion accelerates percolation of tainted water down into the aquifer and perhaps the river.
"In light of the US Supreme Court's ruling on CO2 last Monday and the announcement yesterday that Sunflower is already thinking of scaling its project back, it's clear that coal is a bad investment," said Earthjustice attorney Nick Persampieri.
Steve Miller, spokesman for Sunflower Electric Cooperative, told Harris News Service after the Supreme Court ruling on global warming pollution, "The ruling puts a huge amount of uncertainty in the marketplace." He went on to say that all 150 coal-fired plants on the drawing board across the country "just became a lot more uncertain…the financial community probably will be unwilling to loan money."
Holcomb Combustion Waste Landfill Fact Sheet
The facility: This project is an expansion of the existing landfill, which serves the 360 MW Holcomb 1 coal fired power plant. The expansion will accept coal combustion waste from Sunflower Electric's 2100 MW coal plant expansion. The footprint of the landfill will increase from 115 to 188 acres, but the capacity of the unit will increase from 4.6 million cubic yards to 20 million cubic yards. When full, the landfill will contain 540 million cubic feet of waste. It will rise some 80 feet in the air and measure more than 1/2 mile on each side.
Ownership: In June of 2006 the ownership of this facility was transferred from Sunflower Electrical Cooperative to a new corporation called Holcomb Common Facilities LLC, which is also the permit applicant. The landfill is located in Finney County, Kansas.
The landfill will accommodate fly ash and bottom ash from the combustion of coal, water treatment sludge, scrubber residues and miscellaneous site wastes. Coal combustion waste in lagoons and landfills can leach toxic substances such as barium, arsenic, mercury, lead, cadmium, chromium and selenium. A recent EPA draft report indicated that cancer risk for adults and children who drink groundwater contaminated by coal combustion waste dumps is well above EPA regulatory goals. For more info contact Earthjustice Project Attorney, Lisa Evans, at 781-631-4119 or firstname.lastname@example.org.
KDHE's Bureau of Waste Management has detected arsenic, chloride, cadmium, lead and mercury in groundwater down gradient from fly ash industrial landfills elsewhere in Kansas.
The design of the expansion does not include an impermeable, synthetic liner. It is called an "insitu" liner consisting merely of compacted ash. The applicant is relying on the waste materials to absorb water, "set up" like cement and reduce percolation of precipitation. Sunflower will place a soil and vegetation "cap' over the landfill as it is filled up. After the existing landfill used by Holcomb 1 had operated for some 18 years, KDHE found that groundwater under the site was moving to the northwest and away from the original groundwater monitoring wells. A fourth monitor well, somewhat down gradient from the landfill, was not drilled and tested until November of 2002. Monitoring data is insufficient to predict the performance of the expansion. The applicant is relying primarily on mathematical models and laboratory tests for the new design.
The landfill sits about one mile south of the Arkansas River and two miles to the southeast of the city of Holcomb. Groundwater currently flows in the general direction of the City. The Kansas Geological Survey designates this area as primarily eolian sand or dune sand, which is highly permeable. See www.kgs.ku.edu/general/geology/index.html. Click on FI (Finney Co.) on the Kansas map. The KDHE has designated this area as a sensitive groundwater area for the placement of industrial lagoons. See www.kdheks.gov/indust/ProposedLinerRegs.htm.
Additional Analysis Needed
Experts retained by the Sierra Club feel that laboratory tests may underestimate the rate of percolation. The models and lab tests did not address cracking in the waste layers that will speed percolation, nor the effect of rainfall before placement of the cap. They are concerned about the degradation of the vegetative cap due to drought when the owner is no longer required to maintain it. They note that this type of waste material does not degrade over time, even far into the future, and percolation of contaminated water to groundwater will increase after monitoring has stopped.
Sunflower Electric has bought up agricultural water rights in the area and will be diverting this water as supply for the expanded power plant. A hydro-geological study should be performed to determine what affect this change will have on the movement of groundwater under and near the site. The risk to all public and private drinking water wells in the area needs to be assessed. The applicant should likewise evaluate a scenario where all pumping ceases at this site. It is conceivable that the Holcomb power complex could be shut down earlier than anticipated if it becomes uneconomic due to increasing carbon dioxide regulation.
Nick Persampieri, Earthjustice, (303) 623-9466
Craig Volland, Sierra Club, (913) 334-0556
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