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About that Contaminated Soil at Camelot Landfill

Local News, Notes and Events
Posted by WhosPlayin on 2012/11/4 14:50:00 (1675 reads)

Open in new windowOn Thursday, I attended a quarterly meeting usually held between the two major landfill operators in Lewisville (Waste Management and Republic Services), and various local stakeholders, including the Indian Creek H.O.A, Coyote Ridge Golf Club, and the cities of Lewisville, Carrollton, and Farmers Branch. A representative from the Municipal Solid Waste (MSW) section of the Texas Commission on Environmental Quality (TCEQ) was also present. About 24 people were present. It was good to see all of the parties around the table talking about what is going on with the landfills, and making sure they all understand each other.

Some of the information discussed is relevant to the citizens of Lewisville because of our city's opposition to the Camelot landfill expansion, and the opposition to Camelot's request to use contaminated soil as alternative daily cover (ADC). So although I've not independently researched and confirmed any of this, I wanted to share it, and our readers can take it for what it's worth.

Some of the homeowners present at the meeting had questions about the use of contaminated soil as ADC. Sam Barrett, Waste Section Manager for TCEQ's DFW Region gave some explanation that clarified the matter.

Barrett explained that the contaminated soil proposed for use - and used at many other facilities actually consists of soil that is contaminated with no more than 1,500 parts per million (ppm) total petroleum hydrocarbons (TPH). The soil can be less contaminated than that, but no more contaminated. Expressed as a percentage, that would be dirt with 0.1% contamination. Further, it's not just any kind of contamination that is acceptable. The goal is to keep the material from leaching any more than 1 ppm to water that it comes in contact with. Some hazardous wastes that are hydrocarbons are not allowed even if under 1,500 ppm, such as benzene. Those wastes, Barnett says, must go to one of several specially authorized facilities around the state.

The soil comes from a variety of sources, such as remediation of old gas stations, or in many cases, removal of soil around parking lots where oil drippings from cars have over time washed into the soil. It also comes from construction projects where soil being removed. TCEQ considers it better for the environment to put this contaminated soil in a landfill that to leave it in place, where it is presumably already able to leach into groundwater and surface water.

Soil from a construction project is what initially brought on this request to use it as ADC. The Parkland Hospital construction project in Dallas has generated a lot of contaminated soil, and that soil has already been buried in its own special "cell" at Camelot. No special permit or allowance was needed for that, because that is legal under their current permit. What Camelot wants to do is dig up this soil and use it at the end of each day to cover up the working face of the landfill - where the waste is actively being deposited.

State regulations require that MSW operators cover the working face each day with a 6" layer of clean soil. This works to reduce odor, and cut down on rainfall entering the waste pile. Normally, operators must dig up soil from their own premises or purchase it to use as ADC. Republic Services, the operator of the landfill, and Farmers Branch, its owner, would prefer to have customers pay them to take contaminated soil rather than having to buy it. This also extends the life of the landfill, they say, since they would otherwise just bury the contaminated soil in one spot, then cover it with clean soil. By using the contaminated soil as ADC, they are able to prevent space being taken up with clean soil.

Barnett made it clear that landfill operators are held accountable for the waste they accept, and can be fined if they accept something they shouldn't. Representatives of Republic Services explained that they have several levels of review for waste streams, and that no employee's pay or bonuses rely on how much waste they accept. There is, they say, no incentive for them to accept overly-contaminated soil, but there is plenty of motivation not to.

It was also explained that when contaminated soil is used at the working face, there must be a berm in place, so that any rainwater making contact with it will be captured rather than running off where it could eventually enter bodies of water.

I must say that hearing more about how this works put my mind a little more at ease. My concern is mostly about contaminating our air, or the Elm Fork of the Trinity River, which runs adjacent to Camelot.

There's more information regarding the groundwater contamination and remediation efforts. I'll share that in another post. I just wanted to get this information out there. Maybe I'll get time to talk more in depth with some of the folks involved.

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Poster Thread
RNeil
Posted: 2012/11/4 23:11  Updated: 2012/11/6 2:58
Quite a regular (Verified User)
Joined: 2011/6/1
From:
Posts: 57
 Re: About that Contaminated Soil at Camelot Landfill
A couple of notes regarding the comment "State regulations require that MSW operators cover the working face each day with a 6" layer of clean soil. This works to reduce odor, and cut down on rainfall entering the waste pile." State regulations require MSW operators to use a daily cover, but their options are not limited to 6" of soil, nor does it have to be clean soil when they use soil.

It all depends on what is approved in their operating permit, including temporary aprovals. Other options range from spray-on "Biocover" to filter cake (a byproduct of raw water treatment) to foundry sand to coal combustion bottom ash to slag and so on. Even reusable and non-reusable geosynthetics tarps are an option (my personal favorite is the Tarpomatic -- seriously, that is the actual name). It is up to the state to approve a given material at a given site. But as I pointed out before, use of contaminated soils is fairly common at landfills.

Also, as I pointed out previously, the use of daily cover addresses multiple concerns – not just odor and rainfall. It also is used to control runoff direction, airborne trash, and scavenging and disease vector pests (birds, rats, flies, etc.). But the most important concerns addressed are (1) to minimize moisture entering into the landfill, and (2) fire control.

While most people think of a landfill as a "dump", it is far more complex in design. Perhaps the biggest surprise to most people is that there is no desire to set up an environment where garbage can break down chemically or biologically. By design, it is not a compost heap in any sense of the word. Any moisture entering the landfill will ultimate percolate to the bottom, picking up chemicals along the way.

This product is known as leachate. An ideal landfill would have none, but that is an impossible goal. For one thing, some moisture is inherently present in the trash itself. But keeping additional water out of the landfill as much as possible is critically important to minimizing leachate, because leachate is the mix that potentially contaminates groundwater beneath the landfill. For that reason, daily cover serves a key role in controlling rainfall runoff by helping it stay at or near the surface as much as possible. Runoff is then collected in a channel around the base of the landfill. Because the runoff should be very low in contaminants, it can be treated by a sewage treatment plant.

Fire control is also critical. I wrote about it previously, but it is worth mentioning again. A landfill that catches fire is similar to a coal mine that has an underground fire. The fire can go on for decades. Needless to say, this would be a disaster for a landfill. By keeping the exposure area during the working day small, and covering that patch, the risk of fire from equipment spark, waste compaction, human error or even lightning is greatly limited.

So if using contaminated soils as daily cover is not unusual, why should Camelot be viewed any differently? Again, if you look back at my previous posts, you will see that there are several reasons to be concerned. For starters, the EPA has designated Denton County as a "serious nonattainment" zone, and we are under significant pressure to clean up our air.

As a side note, for the last three years, the American Lung Association has given our area a score of "F" and ranks the DFW area as "12th worst air quality in the country for ozone". Do we really want someone not just accepting and containing petroleum contaminated soils, but then spreading them out in a thin layer where the contaminants can and will exit the soil and either enter the leachate or escape into the atmosphere? This is the total opposite of what we should be doing to clean up our air.

But it is the other concern that I wrote about that should be equally troubling: the impact of using contaminated soils in a landfill that is separately requesting a massive expansion and has a history of groundwater contamination when it should all be considered as one single request. It should not be piecemealed, attempting to get approval for contaminated daily cover under one shell while attempting to expand the landfill hides under another. TCEQ should force Farmers Branch to submit this as one request, so that the whole of the impact can be considered in one comprehensive evaluation.

Don't forget: this landfill sits literally on the banks of the Trinity River. Any failure to control contamination to the enviroment could be incredibly catostrophic. That failure could potentially go undetected right up until it is too late to undo.

-RNeil

P.S. If anyone is itching to learn more about ADCs and regulations, the starting point is Subtitle D (yes, THAT Subtitle D you have been hearing about) of the Resource Conservation and Recovery Act, Title 40 of the Code of Federal regulations: “Protection of Environment,” Chapter I—Environmental Protection Agency, Subchapter I (Solid Wastes), parts 239 - 282. ADC in particular is Part 258, Subpart 21. However, I won't claim it makes for entertaining reading.
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Poster Thread
Runfellow
Posted: 2012/11/5 1:10  Updated: 2012/11/5 1:10
Guest Columnist (Verified User)
Joined: 2011/3/17
From: Lewisville, TX
Posts: 294
 TL;DR
Short, paraphrased version of everything above

Original Post
Talked to a guy from the TCEQ. The guy said contaminated soil may not be as bad as it sounds, and it has to go somewhere. The contaminated soil is already at the Camelot landfill in its own section, and Farmers Branch wants to use it as daily cover. So it may not be all that terrible, but we should be careful.

Councilman Ferguson's Comments
The law isn't very clear on the issue of daily cover, but there are a lot of ways to do it. The process also serves a lot more purposes than the ones Steve listed. Landfills are complex structures, and they leak. There are other concerns, like fire safety and air quality. Denton County air sucks. The two permits, one for the expansion, the other for contaminated soil, should be combined. If anything goes wrong, everybody will be up a creek in more ways than one.

-BC
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