By Chuck Schlarb
The following are my main concerns:
Nevada is the driest state in the union. It gets less rainfall than any other state on the continent. For this reason alone, the project should have been rejected at the onset as too potentially damaging to a limited natural reserve that is irreplaceable. Any loss of which is unforgivable, especially if condoned by a regulating agency. As a matter of fact, it is specifically mandated by law that such an action not be taken. There is no proven technology that will prevent aquifer contamination, regardless of the assurances from Jungo Land & Investments, Inc.(JLII) & Golder Associates. The National Environmental Protection Agency (NEPA) still maintains that all landfill liners will eventually fail.
The US EPA Solid Waste Disposal Criteria (August 30, 1988a) stated,
"First, even the best liner and leachate collection system will ultimately fail due to natural deterioration, and recent improvements in MSWLF (municipal solid waste landfill) containment technologies suggest that releases may be delayed by many decades at some landfills."
The US EPA Criteria for Municipal Solid Waste Landfills (July 1988b) stated,
"Once the unit is closed, the bottom layer of the landfill will deteriorate over time and, consequently, will not prevent leachate transport out of the unit."
This failure will pollute the aquifer. That is why a Nevada statute was enacted in the first place. Follow the law. Reject this proposal on this basis. There are no mitigation measures that are 100 percent effective, especially those that have been proposed by JLII.
In 1995 the United States Geological Survey (USGS) conducted an investigation in Desert Valley. A decade later JLII has tried to use this study to further their financial goals by misquoting it and for reasons unknown NDEP has let them. The report is WRIR 95-4119, it was conducted by David L. Berger. In this report, Mr. Berger states unequivocally that the predominant wind direction in the valley is from the west.
"An active dune field, in the southeastern part of the study area (pl. 1A),covers about 12,000 acres of the valley floor. (An active dune field is one in which the dune ridges slowly migrate in the direction of the prevailing wind.) This section of the dune field in Desert Valley is the trailing edge of a much larger dune field that totals about 31,000 acres, extends about 28 mi to the east, and terminates in Paradise Valley (fig. 1)." - Page 3 WRIR 95-4119
Unless a reader intentionally misconstrues the author's intent, this is proof that JLII assertions of the exact opposite are false. So, the dunes start in Desert Valley (trailing edge) and terminate in Paradise Valley. The winds blow west to east. This statement by Berger is backed up by National Weather Service climate data regardless of what citations JLII uses in their submissions. If you are still unsure just ask NDOT where the sand dunes come from along Highway 95 between Desert Valley and Paradise Valley, they'll set you straight.
JLII and Golder have also stated in handouts and presentations that the aquifer under Desert Valley is isolated or "perched", unconnected to other hydrologic basins. This is false as well. To again quote Mr. Berger:
"The components of the ground-water budget for the aquifer system beneath the study area were estimated using empirical techniques and refined using a ground-water flow model. Under predevelopment conditions (pre- 1962), the total flow through the aquifer system beneath the study area was about 11,000 acre-feet per year (acre-ft/yr). The flow components are (1) total inflow that
includes about 7,300 acre-ft/yr of recharge from precipitation, about 2,700 acre-ft/yr of infiltration beneath ephemeral rivers that traverse the northern part of the study area, and about 1,100 acre-ft/yr of subsurface inflow from the Quinn River and Kings River Valleys, and (2) total outflow that includes about 9,100 acre-ft/yr discharge by evapotranspiration and about 2,100 acre-ft/yr
subsurface outflow." - Page 1 Abstract WRIR 95-4119
2,100 acre feet per year subsurface outflow doesn't sound like an isolated aquifer. If pressed, JLII and Golder will first claim that no pollution of the aquifer will take place and even if it does then the aquifer is isolated, neither of which is the truth. By misquoting a published study or deliberately misinterpreting it, they have falsified data needed by NDEP to make an informed decision about the proposal. For these reasons, NDEP should reject this project.
Chuck Schlarb is a resident of Winnemucca.[[In-content Ad]]
