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Friends of Great Salt Lake
ldefreitas@xmission.com
From: Robert L. Baskin, Ph.D., PG
Re: Review of Hydrogeologic Study of Promontory Point Resources LLC Phase 1 Landfill Cell for Class I
Landfill Permit Modification for Promontory Point Resources, LLC.
Dear Ms. de Freitas,
I have completed a review of the “Hydrogeologic Study of Promontory Point Resources LLC
Phase 1 Landfill Cell for Class I Landfill Permit Modification for Promontory Point Resources, LLC”
(‘Study’) and “Appendix A ‐ Construction and Testing Report for the Promontory Point Monitor Wells
Box Elder County, Utah for Promontory Point Resources, LLC” (‘Appendix’). I have some serious concerns
regarding the Phase 1 Landfill Cell location and monitoring program.
While the technical aspects of the Study were done appropriately and with reasonable
documentation, there is additional work that needs to be conducted to provide an understanding of the
groundwater system in the Promontory Point Landfill (‘PPL’) area. The results from the hydrogeologic
study indicate three major areas of concern: (1) the fractured nature of the geology make reliable
prediction of flow paths and monitoring of groundwater quality nearly impossible; (2) groundwater flow
directions, gradient, and the speed at which groundwater might travel all indicate a direct hydrologic
connection between groundwater on the PPR property and Great Salt Lake (‘GSL’); and (3) the Study
shows that groundwater and any fluid contamination from a landfill leak would move south/southwest
and either discharge into GSL or into the Compass Minerals Concentrated Brine Inlet Canal (‘Brine
Canal’), both of which would have irreversible consequences. I have addressed each of these concerns
below.
Faults, Fractures, and Groundwater
The site of the PPL is problematic for a landfill. Not only is it adjacent to the Great Salt Lake, it
was built on intensely fractured rock formations that are located at the junction of two major normal
faults. Promontory Point lies at the junction of the Carrington Fault and two sections of the Great Salt
Lake Fault Zone: the Promontory and Fremont Island sections (fig. 1). Promontory Point is characterized
by intensely folded, faulted, and highly‐fractured rock formations, abrupt changes in topography at
nearby fault scarps, and numerous springs (both active and inactive) that lie along the boundary of, and
feed into, GSL. The Study documentation from Loughlin Water Associates LLC, and separate
documentation prepared by Tetra Tech Inc., both describe the characteristics of the specific geologic
formations in the area and repeatedly acknowledge the “intensely” fractured nature of the area:
Limestone and Shale ‐ “At its base is intensely‐folded, dense, yellowish‐gray cherty argillite and
medium‐gray to pinkish limestone, which is highly deformed as a result of shearing along the contact
with the underlying quartzite unit (Crittenden, 1988).” “ …where it is shown to be in fault contact with
the Geertsen Canyon Quartzite.” (emphasis added)
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Geertsen Canyon Quartzite ‐ “The formation is highly‐ to intensely‐fractured/jointed and is cut by a
series of northwest‐trending high‐angle faults.” Study at 10 (emphasis added)
Browns Hole Formation ‐ “The unit is observed to be highly‐ to intensely‐fractured/jointed.”
Mutual Formation ‐ “The Mutual Formation at the project site is highly‐ to intensely‐fractured and
jointed (Crittenden, 1988).” Study at 11 (emphasis added).
“It is not surprising that the unconsolidated and semi‐consolidated deposits are more permeable than
the bedrock. Although bedrock is intensely fractured where exposed at the ground surface…” Study at
19 (emphasis added).
And, in the Tetra Tech material descriptions on the Boring Logs...
Boring B‐100 ‐ “QUARTZITE, dark gray, hard, intensely fractured...” (emphasis added) reported at
approx. 8 feet below ground surface (‘BGS’). Also “Wet at 6.5 feet below BGS, possible perched GWT.”
(Ground Water Table)
Boring B‐102 ‐ QUARTZITE, dark gray, hard, intensely fractured, highly weathered...” (emphasis added)
at approx. 17 feet below ground surface (‘BGS’). Also, “Groundwater not encountered above 15 feet
BGS” inferring that groundwater was encountered below that point.
While the findings of the contractors and subject matter experts hired by Promontory Point
Resources LLC (PPR), repeatedly describe the characteristics in the Study area as “highly‐ to intensely
fractured/jointed,” they seem to ignore their own Study results, the work done by Crittenden (1988),
the Utah Geological Survey (2019), and additional fault mapping efforts by Dinter and Pechmann (1999,
2000, 2014, 2015 and others) and detailed subsurface mapping by Baskin (2014). The description of the
fractured nature of the Study area alone should have caused concern about the siting of the landfill,
raised multiple red flags during the initial approval process, and be considered in any discussion on the
use and subsequent development of the site. Just because a fault or fracture system can’t be identified
at land surface doesn’t mean there isn’t a fault or fracture system below the surface.
In addition to the proximity of the landfill to the intersection of two major faults, numerous
studies and experts have warned of the dangers to groundwater of landfills located on or near fractured
rock. To cite a few examples of many: “An extreme example of . . . aquifer heterogeneity . . . is flow
through fractured rock. The design of monitoring well systems in such an environment is a nightmare
and usually not more than a blind gamble.” (Haitjema, 1991)
“The presence of fractured bedrock, fissures, cavernous calcareous strata, and non‐isotropic
lenticular aquifers (such as former river beds) make the reliable prediction of flow paths from point‐
source leaks from lined landfills more difficult or even impossible and make the monitoring of
groundwater for incipient leachate pollution highly unreliable and virtually impossible.” (Lee and Jones‐
Lee, 2015)
“Therefore, in addition to misconceptions about the nature of the spread of leachate from lined
landfills, incomplete or unreliable assessment of the geological features of the subsurface system, and
complex hydrogeology can further reduce the probability that the typical groundwater monitoring well
array will intercept any plume of leachate‐contaminated groundwater at the point of compliance for the
MSW landfill monitoring program.” (Lee and Jones‐Lee, 1993)
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The Study states that calculated groundwater velocities in the Study area “range from about
0.01 ft/day to 9 ft/day.” Comparing the specific descriptions of geologic formations in the Study area
against a simple calculation of fracture flow velocities as described by Cook (2003), groundwater
velocities may be much greater than those calculated during the Study. Cook explains “Assuming a
hydraulic conductivity of 10‐5 m/s and a hydraulic gradient of 10‐2, calculations result in a groundwater
flow rate of approximately 3 m/yr. If fractures are present, spaced 1 m apart, and the fracture aperture
is only 250 µm (~0.01 inch), then the water velocity in the fractures will be 35 m/day (~115 ft/day).” The
terminology about “highly‐ to intensely fractured/jointed formations,” as cited from the Study and
Boring Logs, suggests a much greater number of fractures/joints than one fracture/joint every meter.
Any potentially harmful contaminant that breaches landfill containment could spread significantly
faster—ten times or more—than the 0.01 ft/day to 9 ft/day cited in the report and could be impossible
to stop or recover.
Additionally, changes in hydraulic gradient due to greater‐than or less‐than normal precipitation
could change the speed at which groundwater moves through the system. At these speeds,
contaminants could reach the GSL within days rather than years, and with sampling only scheduled to
occur semi‐annually, contamination could easily reach the GSL and continue undetected for weeks or
months. An additional concern is that monitoring of the wells for the Study occurred over a short period
of time following years of relatively low precipitation. As such, data collected during the Study may not
represent normal groundwater conditions in the area, or even conditions this year, which had
particularly heavy high precipitation.
Groundwater Flow Directions, Gradient, and Speed
Statements regarding groundwater flow direction, gradients and speed at which groundwater might
travel are remarkably consistent throughout the entirety of the Study report. As repeated in various
forms in the Study, groundwater generally moves in the direction of the GSL “from higher elevations in
the bedrock into the semi‐consolidated fanglomerate and unconsolidated Lake Bonneville deposits
towards the GSL.” The hydrologic connection between groundwater on the PPR property and GSL is also
demonstrated consistently throughout the Study and supported by physical measurements of
groundwater gradients and water chemistry. The Appendix describes this connection between GSL and
the groundwater at the Promontory site using water chemistry as evidence: “The groundwater at the
Promontory site is heavily impacted by activities related to the GSL. Larger concentrations of arsenic,
calcium, chloride, magnesium, potassium, selenium, sodium, sulfate and TDS at the downgradient
monitor well locations all indicate impacts from the GSL that are unrelated to PPR activities.” (emphasis
added) Study Appendix A at 9. Additional statements in the Study report that groundwater movement is
towards GSL:
“Groundwater on the PPR property flows from north to south, generally in the direction of the
topographic surface. Groundwater flows from higher elevations in the bedrock into the semi‐
consolidated fanglomerate and unconsolidated Lake Bonneville deposits towards the GSL. Groundwater
exits the bedrock and enters the fanglomerate at some point between upgradient Well MW‐5 and
upgradient Well MW‐9. Groundwater exits the fanglomerate and enters the Lake Bonneville deposits
between Promontory Point Road and the flooded salt evaporators.” Study at 13 (emphasis added), and
discussions of groundwater flow, including beneath the landfill cell, as westerly towards the GSL at 14,
15, and 17.
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No Study of Groundwater Discharge Locations
The hydrologic connection between groundwater beneath the PPR property and GSL is well
established in the Study and supported by physical measurements of groundwater gradients and water
chemistry. Although there is some conjecture that the groundwater may be discharging before it
reaches the Compass Minerals Concentrated Brine Inlet Canal or even into the brine canal, there is no
evidence in the Study to support this assertion nor is there any discussion of where groundwater
discharge occurs. No samples or discharge sites for the groundwater were identified or evaluated during
the Study. However, although the Study finds the conditions of “[t]he presence of brine in the salt
evaporators may affect groundwater levels on the site and groundwater flow directions between the
fence line and the salt evaporators,” there is no question groundwater will still discharge along the
margins of the lake and eventually reach GSL. The Study never addresses the active springs south of the
brine canal, and claims about apparent leakage of brine from the canal were not supported or
investigated in the Study. Springs and brine discharging south of the brine canal demonstrate a
hydrologic connection between groundwater north of the Compass Minerals Concentrated Brine Inlet
Canal and groundwater discharge south of the canal. The source(s) of water discharging south of the
brine inlet canal are not known and were not investigated by the Study.
Another indication that there is a direct connection between groundwater in the monitoring
wells and GSL is that water levels in wells MW‐1, MW‐5, MW‐4, and the 12” well all mimic changes in
GSL water levels. This is significant even though monitoring of MW‐4 and the 12” well only occurred for
a short period of time.
The location of groundwater discharge is an important aspect of understanding the hydrologic
system yet discharge locations near or into GSL were not clearly identified in the Study. The Study did
not discuss and made no attempt to identify exactly where groundwater from the site would discharge,
citing only that groundwater may be blocked from reaching the GSL. The groundwater from the site
must discharge somewhere. If a breach in the landfill containment system were to occur, any fluid
contaminant would move southwest and either discharge into GSL or into the Compass Minerals
Concentrated Brine Inlet Canal. The introduction of contaminants into the Compass Minerals
Concentrated Brine Inlet Canal puts Compass Minerals and the hundreds of millions of dollars of
economic benefit it provides to the State of Utah in jeopardy.
Implications of Study Findings on Fractures, Groundwater Flow, and the Failure to Investigate
Discharge Locations
Great Salt Lake is one of approximately six known areas in the world with an extensive microbial
carbonate population (fig. 2) and is considered an “Ecologically Significant Natural Area” (GSLI, 2018).
Microbial bioherms and similar biogenic carbonates form a stable base for adherence of benthic
biological forms such as brine fly larvae and provide a base for critical primary production. Changes in
climate, increasing water use, and the introduction of waste materials from human activities adjacent to
the lake threaten the stability of the lake and the organisms depending on it for their survival. Loss of
the bioherms through changes in water chemistry or by the introduction of biocidal compounds would
be catastrophic to the ecosystem of GSL and the industries that operate on or adjacent to GSL, tourism,
waterfowl hunters, and other activities that rely on a healthy GSL ecosystem.
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The combination of the fractured nature of the land under and surrounding the landfill, the flow
direction of the groundwater from the landfill into GSL, and the Study’s failure to investigate
groundwater discharge locations provides strong evidence that the Study is insufficient to ensure the
landfill will not become a hazard to the GSL or parts of its ecosystem at some point in the future.
Further, the three downgradient groundwater monitoring locations are not sufficient to ensure either a
lack of fractures under the landfill or that contaminants from leaks in the landfill, whether from the
sump or from leaks in the liner itself, will be detected. (Lee and Lee 2015). “It is recommended that
regulatory agencies, as part of the permitting of a proposed landfill, conduct a site‐specific evaluation of
the ability of the proposed monitoring well array to detect leachate‐polluted groundwaters at the point
of compliance all along the downgradient edge of the landfill from leaks that occur from holes, rips,
tears or points of deterioration in the HDPE liner. In making this evaluation it should be assumed that
the leak would occur through a two‐foot long area at any point in the landfill footprint, including
especially near the downgradient edge of the landfill.”). More evaluation of the site and more robust
detection systems are needed to ensure that any contamination originating in the landfill will be
confined to the landfill, detected, and removed from the site before it reaches GSL or affects its
ecosystems. Any contamination by landfill pollutants entering the GSL could have potentially significant
and even catastrophic effects.
Additional Comments/Questions
1) Wells were pumped but no interference test was conducted. This would have been a simple test to
perform and provide information on the hydrologic connection between wells. Page 13 provides some
indication that there is a hydrologic connection between the wells, however, a simple interference test
would quantify the connection. “Water levels in Well MW‐4 have fallen about 0.5 feet since the
transducer was first installed in mid‐August 2018. This drop in the water level is comparable with
groundwater level changes over the same period in Wells MW‐1 and MW‐5.”
2) A water sample from GSL should have been collected (N and S) to compare with water from the
monitoring wells. A simple Stiff diagram or Piper diagram would have indicated the type of water that
sampled and if water from Great Salt Lake was affecting the water quality of groundwater in the wells.
3) At page 9‐10 of Appendix A, the report states that “[a]fter background levels are established for
each constituent, a Ground Water Quality Protection Standard will be determined by the DWMRC. For
constituents with background levels that are less than the respective Ground Water Protection
Standards, the protection standards are likely to be set at the respective Ground Water Protection
Standard.”
Using these generic standards does not account for many constituents such as organic compounds
and radionuclides that may impact GSL. If these constituents are not going to be analyzed as part of the
monitoring program, it will not be possible to determine if those contaminants are introduced into the
groundwater, GSL, or the Compass Minerals Concentrated Brine Inlet Canal. Since a landfill is involved,
numerous contaminants could be coming off the trash which may never be identified with the limited
analytical schedule. Unidentified and unanalyzed contaminants may still have impacts on the GSL
ecosystem, the brine shrimp industry, and/or on Compass Minerals products and profits.
4) There are multiple published techniques and numerical models that could be used to better
understand the groundwater system and identify faults and fracture systems in the area of Promontory
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Point. Of course, now that the landfill has already been constructed, conducting a geophysical study to
determine if there are faults or a fracture system beneath the landfill site is problematic. I have included
some additional references about techniques to locate and characterize fracture systems and assess
groundwater flow in fractured systems in the References Cited section.
5) Determining formation permeability and identifying fracture architectures from rock chips acquired
during drilling/augering is difficult at best. Were any cores collected during the hydrogeologic
investigation? If so, were the cores subjected to any geotechnical evaluation to determine if the cores
were fractured or they were permeable? Where the wells/borings logged or downhole photography
acquired to look at the possible occurrence of fractures?
6) The presence of “gypsum and clay” and CaCO3 cementation/“infilling” requires groundwater flow
through the system. The presence of springs and discharge locations downgradient from the landfill and
monitoring well locations demonstrates that groundwater continues to move through the system in
spite of the presence of interstitial materials infilling fractures. Again, was the complete infilling of
fractures by “gypsum and clay” and CaCO3 cementation determine by examining rock chips or by coring
and geotechnical analysis of the cores?
Unresolved Issues
Page 12 of the Study includes two issues of concern with no explanation identified in the Study: “It is
unusual for groundwater levels to rise through winter months under dry climatologic conditions. Water
levels in 2018 rose more than one foot higher than peak water levels in 2017 despite the winter of
2017/2018 being relatively dry.” This is an import question as the purpose of the Study was to
understand the hydrogeologic setting in the area of the landfill to insure that any contaminant release
to the groundwater system would be contained/controlled within the boundaries of the PPL. Since this
question was not answered, the hydrogeologic setting is not understood. This is a good example of
where additional data and a numerical model may have been beneficial.
Figure 6 shows an almost daily fluctuation (rise and fall) in the water level in MW‐5 of about 0.1 to 0.3
feet. “The cause of these regular water level fluctuations is unknown, but may be due to the effect of
earth tides on the low‐porosity bedrock (Marechal and others, 2002).” The plot shown in the Study
documentation does not contain sufficient information to determine the onset times of water level
changes. The data may also be related to short‐term fluctuations in GSL water levels or diurnal
variations in groundwater use by phreatophytes. Additional details on the onset times of water level
fluctuations would help resolve this issue. (emphasis added)
References Cited
Baskin, R.L., 2014, Occurrence and Distribution of Microbial Bioherms in Great Salt Lake, Utah:
University of Utah, Ph.D. dissertation, 190 p., 47 figs.
Cook, P.G., 2003, A Guide to Regional Groundwater Flow in Fractured Rock Aquifers: CSIRO Land and
Water, Glen Osmond, SA, Australia Seaview Press, vii, 108 p. : ill. ; 25 cm. Online at
http://pandora.nla.gov.au/pan/103522/20091110‐1348/lwa.gov.au/files/products/river‐
landscapes/px020312/px020312.pdf
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Crittenden, M.D. Jr., 1988, Bedrock Geologic Map of the Promontory Mountains, Box Elder County,
Utah: U.S. Geological Survey Open‐File Report 88‐646. Available online at
https://ugspub.nr.utah.gov/publications/open_file_reports/ofr‐698/ofr‐698.pdf
Dinter, D.A., and Pechmann, J.C., 1999, Sublacustrine paleoseismology‐Evidence for recent earthquakes
on the East Great Salt Lake fault, Utah: Association of Engineering Geologists Program with
Abstracts, 42nd Annual Meeting, p. 62‐63.
Dinter, D.A., and Pechmann, J.C., 1999, Multiple Holocene earthquakes on the East Great Salt Lake fault,
Utah‐Evidence from high‐resolution seismic reflection data [abs.]: EOS, Transactions of the
American Geophysical Union, v. 80, no. 46 (supplement), p. F734.
Dinter, D.A., and Pechmann, J.C., 2000, Late Quaternary slip rates and recurrence intervals of large
earthquakes on the East Great Salt fault, Utah‐Estimates from high‐resolution seismic reflection
data [abs.]: Geological Society of America, Abstracts with Programs, 2000 Annual Meeting, v. 32.
Dinter, D.A., and Pechmann, J.C., 2014, Paleoseismology of the Promontory Segment, East Great Salt
Lake Fault: Final Technical Report to the U.S. Geological Survey. Online at
https://earthquake.usgs.gov/cfusion/external_grants/reports/02HQGR0105.pdf
Gattinoni, P., and Scesi, L., 2018, Short review of some methods for groundwater flow assessment in
fractured rock masses: Italian Journal of Groundwater ‐ AS26‐ 342: 07 ‐ 17. DOI: 10.7343/as‐2018‐
342.
Haitjema, H., 1991, Ground Water Hydraulics Considerations Regarding Landfills: Water Res. Bull.
27(5):791‐796.
Lee, G.F., and Jones‐Lee, A., 2015, A Flawed Technology of Subtitle D Landfilling of Municipal Solid
Waste, Online at http://www.gfredlee.com/Landfills/SubtitleDFlawedTechnPap.pdf.
Lee, G.F., and Jones‐Lee, A., 1993, Groundwater Quality Monitoring at Lined Landfills: Adequacy of
Subtitle D Approaches: Report of G. Fred Lee & Associates, El Macero, CA. Online at
www.gfredlee.com/Groundwater/GW‐MONITpaper93.pdf
Science Advisory Board, 2010, Report on Fractured bedrock Field Methods and Analytical Tools: Science
advisory Board for Contaminated sites in British Columbia. Online at
http://www.sabcs.chem.uvic.ca/fracturedbedrock.html
USGS Fractured Rock Geophysical Toolbox Method Selection Tool: Online at
https://www.usgs.gov/media/videos/usgs‐fractured‐rock‐geophysical‐toolbox‐method‐selection‐
tool.
Utah Geological Survey, 2018, Bedrock geologic map of the Promontory Mountains, Box Elder County,
Utah, (GIS reproduction of USGS OF 88‐646 [1988 ]): Open‐File Report 698dr
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