Transcript Georgia Inert Landfill Regulations

Georgia Inert Landfill Regulations
The transition away from permit-by-rule status
Michael Smilley, PG
Golder Associates Inc.
Atlanta, Georgia
OUTLINE
Background
Permit-By-Rule
Permit-By-Rule
Result
Amended Rules
Potential Impacts of Regulations
Important Dates
Questions
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BACKGROUND
Low Perceived
Risk
Inert Solid
Waste
High Perceived
Risk
Construction
and
Demolition
(C&D) Waste
Municipal
Solid Waste
(MSW)
Hazardous
Waste
Cover Soil
Cover Soil
Cover Soil
Cover Soil
Reporting
Reporting
Reporting
Reporting
Site Controls
Site Controls
Site Controls
Site Controls
Monitor Explosive Gas
Monitor Explosive Gas
No Gas Requirements
Groundwater
Groundwater
Groundwater
Post Closure Care
Post Closure Care
Post Closure Care
Liners
Liners
Double Liners
Required
Investment
Thousands$
Millions$
Millions$
3
Millions$
BACKGROUND
INERT SOLID WASTE LANDFILLS
Earth-like products, concrete, cured asphalt, rock, bricks, yard
trimmings and land clearing debris
Not likely to produce leachate of environmental concern
Liquid that percolates
through or is generated
by the decomposition
of waste material
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PERMIT-BY-RULE
PERMITTING OF INERT SOLID WASTE LANDFILLS IN GA
Permit by rule provision (GA EPD 391-3-4.06) – since 1989
Notification
within 30 days of operation
Map
Documentation
from local jurisdiction of compliance with E&S
Operational requirements
Permitted
Facilities Documented Online
Over 2000 inert landfills in Georgia as of
March 2011
(2285 based on 2011 list)
Over 1100 inert landfills in Georgia as of
August 2012
(1133 on EPD Database as of August 2012)
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PERMIT-BY-RULE
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PERMIT-BY-RULE
Final Cover – 2’
Inert Waste Only
1’ Cover Soil
Layers of Least Practical
Volume
Grading
100’ Buffer
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PERMIT-BY-RULE
REGIONAL PERSPECTIVE (US EPA Region 4)
Permit By Rule –
Land Clearing and
Inert Debris (LCID)
Landfills (<2 acres)
Permit By Rule –
Structural Fill Landfills
Clean Debris
Land Clearing Debris
General Permits
http://water.epa.gov/scitech/swguidance/standards/criteria/nutrients/region04.cfm
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PERMIT-BY-RULE RESULT
- How common are these?
- Recognized Environmental
Condition (REC)?
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PERMIT-BY-RULE RESULT
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PERMIT-BY-RULE RESULT
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PERMIT-BY-RULE RESULT
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PERMIT-BY-RULE RESULT
ACCORDING TO EPD RECORDS:
 Proper closure - 225
1210 are individual subdivision lot inert waste pits that have
been abandoned without notifying the homeowner.
1100 still operate or have failed to notify the EPD of closure.
Fewer than 100 submit the quarterly disposal reports.
Many other environmental impacts exist.
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PERMIT-BY-RULE RESULT
Weatherwood Subdivision
Evacuated 30 families after elevated
methane levels were detected in
homes.
Methane levels were generated by a
construction debris landfill under
homes.
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PERMIT-BY-RULE RESULT
INERT WASTE REALITY
Env. Sci. Technol. 1997, 31, 911-917
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AMMENDED RULES
NEW RULES FOR INERT LEVELS:
Buffers
Survey
Controls
Siting Requirements
Explosive Gases Control
Sequence of Filling (Documentation)
Spreading/Compaction/Monthly Cover
E&S
Vegetation
Fire Protection
Limited Access
Final grading
Final Cover
Post-Closure Care
Insurance Requirements
REQUIRES A
PROFESSIONAL
ENGINEER
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AMMENDED RULES
Cover
Inert Waste Only
1’ Cover Soil
Layers of Least Practical
Volume
Grading
Monitor Explosive Gas
100’ Buffer
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AMMENDED RULES
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AMMENDED RULES
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AMMENDED RULES
TOTAL ADDITIONAL COSTS
Published estimated by Hawkinsville City Manager –
$150,000 initially and $12,000 per year.
Post-Closure Care
The design must provide post-closure care for 30 years.
Can be reduced but cannot be less than 5 years.
http://www.romenews-tribune.com/view/full_story/18906698/article-Inert-landfill-operators-object-to-rule-change?instance=home_news_lead_story
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AMMENDED RULES
GEORGIA HOUSE BILL 320
Subsection
(k) – Any inert waste landfill which, as of January 1, 2014, has
been certified by a professional engineer registered in
accordance with Chapter 15 of Title 43 as being in full
compliance with all permit by rule requirements established in
the rules and regulations of the division as they existed on
January 1, 2012, may continue to operate under such permit
by rule requirements.
Yea – 159
Nay – 8
Not Voting – 8
Excused - 5
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AMMENDED RULES
Inert Landfill Compliance
Certifications
-
PE will review the historical facility
documents and certify compliance.
-
“ I ________ (certifying P.E.) certify
that the inert landfill listed above
is/was in compliance with the
following sections of the Rules for
Solid Waste Management in Georgia
(Rules), as they existed on January
1, 2012….”
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AMMENDED RULES
INFORMATION REQUIRED DURING SUBMISSION
• Copy of required initial notification
• Assurance that only earth-like products….placed in landfill.
• 100 feet of property line or structure [Survey Plan]
• Field evaluation concerning layering of materials [photos]
• Grading and drainage plans
• Fire prevention measures
• Copies of all tonnage reports
• Other documents demonstrating compliance [zoning, erosion
and sediment control plans; NPDES; community affairs
regional impact.
July 17, 2015
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AMMENDED RULES
New Inert Landfills
Existing Inert Landfill
[In Compliance]
Certification Submittal
[December 31st 2013]
DENIED
Existing Inert Landfill
[Out of Compliance]
?
APPROVED
Cease Accepting Waste
[December 31st 2013]
NEW RULES
OLD RULES
Complete Closure
[June 1st 2015]
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POTENTIAL REGULATION IMPACTS
POTENTIAL IMPACTS
Operator Opinion:
Takes
many existing inert landfills out of compliance
Makes them cost prohibitive
Increases incentive for illegal dumping
EPD
Opinion:
Decreases
the number of inert solid waste operators
Emphasizes the beneficial reuse of materials
Market
opportunities for waste companies?
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POTENTIAL REGULATION IMPACTS
Recession End*
Recession Start*
3500000
$1,800.00
$1,600.00
3000000
$1,400.00
2500000
$1,200.00
2000000
$1,000.00
1500000
$800.00
Tonnage Reported
(tons)
$600.00
1000000
$400.00
500000
$200.00
* National Bureau of
Economic Research
July 17, 2015
C&D Tonnage
MSW
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S and P Price
8/14/2013
4/1/2012
11/18/2010
7/6/2009
2/22/2008
10/10/2006
5/28/2005
1/14/2004
9/1/2002
$0.00
4/19/2001
0
POTENTIAL REGULATION IMPACTS
BENEFICIAL REUSE
Composting Facilities
Mulching Facilities
Concrete Recycling
Windrows at the ACC Commercial Compost Facility
July 17, 2015
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POTENTIAL REGULATION IMPACTS
UNKNOWNS
• Does the EPD have the capacity to oversee these changes?
•State
budgets continue to shrink
•EPD office closures in Savannah and Columbus
•920 employees in 2002 reduced to 852 in 2011
•Proper closure?
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SCHEDULE
IMPORTANT DATES
Deadline to receive compliance certification

December 31, 2013
Deadline
to stop accepting waste if you don’t receive a waste
handling permit

December 1, 2014
Deadline
to complete closure of inert landfill if permit was not
obtained

June 1, 2015
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QUESTIONS?
?
Turtle Mound Shell Midden
http://upload.wikimedia.org/wikipedia/commons/7/7e/TurtleMound1915_ge0496.jpg
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