I submitted this complaint to the following agencies yesterday afternoon.
Utah Division of Air Quality, Utah Division of Water Quality, Utah Department of Environmental Quality, and Utah DOGM Minerals Regulatory Program.
I will post an update when I get some responses.
This letter is a formal complaint and request for action by Raphael Cordray, personally, and behalf, Utah tar Sands Resistance (UTSR).
This complaint alleges that MCW Energy is operating a tar sands processing plant near Vernal in violation of State and Federal environmental laws and regulations. MCW Energy is performing unlawful activity by building and operating a tar processing facility without environmental permits.
My search of public records reveals that no current permits are existing as required by law and for public safety. This Tar Processing facility is adjacent a residential area putting homes and families at risk.
MCW has no Air pollution control permit.
MCW has no Storm Water discharge permit
MCW has no NPDES Process Water discharge permit
MCW has no permit for RCRA Waste Streams yet appears to create RCRA waste streams
There are chemicals and processes on site that require permitting and regulation yet the MCW facilities and tar processing operations are currently unpermitted and unregulated.
MCW stands to gain a huge financial benefit from this illegal activity by placing human health and the environment at risk. MCW is defrauding investors by making numerous false claims on their website.
MCW has used public leaders including, Kevin Van Tassel and Governor Herbert to create an illusion of legitimacy for this illegal project.
I am aware that a Right Of Entry (ROE) permit 6166 was issued to MCW on February 2nd by SITLA. I also reviewed the related “Final Agency Action” letter from Kevin Carter of SITLA to MCW dated Nov. 17 2015.
ROE 6166 executed contract
I am concerned about the content of the ROE. The ROE claims to authorize the dumping of process water by MCW tar processing facility in unlined pits on the site. Where is the public process and proper environmental impact research in an ROE? A tar sands factory needs more than an ROE to operate yet state of Utah records indicate that MCW has been operating illegally on this site for years.
The ROE permit 6166 states:
“SITLA authorizes and approves Permittee’s use, storage and disposal of Produced Water on the Permitted Property.”
SITLA does not regulate produced water. How & Why are they “authorizing” it?
We request that you take immediate action and close this illegal operation. We demand that the environmental impacts to our air, water and the land from this toxic experiment be disclosed and addressed. We formally request that ALL relevant laws and rules be effectively applied and enforced to this project.
Please contact me if you need any further information.
I look forward to your responses.
Raphael Cordray, personally and for,
Utah Tar Sands Resistance