On 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.