DERR-2024-007720

NRD Trustee – Comment Response Summary, Section 8 8-1
SOUTHWEST JORDAN VALLEY GROUND WATER CLEANUP PROJECT
STATE OF UTAH NATURAL RESOURCE DAMAGE TRUSTEE

COMMENT RESPONSE SUMMARY
AUGUST 31, 2004

Response to Common Comment No. 8 – No Discharge of Reverse Osmosis Treatment
Plant Concentrates to the Jordan River

Many individuals and groups commented on the proposal to discharge the concentrates from the proposed
Jordan Valley Water Conservancy District (JVWCD) reverse osmosis (RO) water treatment plant to the
Jordan River. JVWCD obtained a UPDES discharge permit from the Division of Water Quality (DWQ)
in the fall of 2003, and it would have relied on that discharge permit as part of its operations under the
Joint Natural Resource Damage (NRD) Proposal. Commenters expressed concern about the potential
environmental impacts on the Jordan River and downstream wetlands that might arise from the
concentrate discharge. In response to the concerns expressed in those comments, JVWCD withdrew the
permit for discharge to the Jordan River on January 14, 2004. On January 20, 2004, DWQ acknowledged
receipt of the letter and withdrew the permit.

The Trustee convened a Stakeholder Forum in order to improve public involvement in the ongoing review
of remediation work by Kennecott. JVWCD asked the Stakeholder Forum to consider alternatives to
discharge of concentrates to the Jordan River. The Stakeholder Forum considered 15 alternatives for
disposal of Zone B and shallow aquifer concentrates, including a “no action” alternative. After
considering the public comments, the work of the Stakeholder Forum, and discussions with the Trustee,
JVWCD revised the Joint Proposal to eliminate the discharge of any concentrates to the Jordan River.
Instead, the Proposal was revised to include three alternative options. In July 2004, the Trustee decided to
reopen the public comment period to allow for additional public comment on the changes to the Joint
NRD Proposal.