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Holcomb Combustion Waste Landfill Fact Sheet

1. 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.

2. 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 the south 1/2 of Section 20 and north 1/2 of Section 29, Township 24 South and Range 33 West in Finney County, Kansas.

3. Waste characterization. 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 Earth Justice Project Attorney, Lisa Evans, at 781-631-4119 or levans@earthjustice.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.

4. Landfill design. 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.

5. Site Characteristics. 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 (5.5 MB).

6. Additional Analysis Needed. Experts retained by the Sierra Club feel that laboratory tests may underestimate the rate of percolation. The models & 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.

7. Other scenarios. 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.

Go to the Sunflower Landfill Press Release

Alert: Holcomb Landfill Comments Needed