Donate
Support LEAN
Make a donation today.
Subscribe
| Sign up for our newsletter and action alerts. |
|
|
|
LDEQ Notice On Chef Landfill Permit Insufficient |
|
|
The DEQ public notice and request for public comments on the Draft Water Discharge Permit for the Chef Menteur Landfill is insufficient to address the critical situation existing at the Chef Menteur Landfill.
See the LMRK Debris Disposal In New Orleans East Interactive Map to see the management of water during the Chef Menteur C&D Landfill filling process.
The Chef Menteur Landfill disposal cell (waste cell) is completely
covered with very deep water. There currently exist at the Chef Menteur
site basically an underwater landfill covered with waste contact
stormwater. The Retention Pond and Final Settling Pond that were
designed to hold waste water prior to discharging to the Maxent Lagoon
are also filled with waste contact stormwater. Wastewater has
accumulated in the waste cell and impoundments since July 12, 2007 (10
month). At the end of February of 2008 these was approximately 2 feet
of freeboard in some areas of the berms of the impounded areas and flow
between impoundments over the berms in other areas. Since that time
the area where the landfill is located has received substantial
rainfall.
The situation at the Chef Menteur Landfill, as it exists today,
requires much stricter discharge permit conditions to insure that toxic
chemicals from the submerged waste are not discharged from the site and
the situation requires the implementation of a remedial action plan to
restore the integrity of the waste cell, retention pond and final
settling pond to isolate the cell and impoundment areas from the
surrounding environment. Dewatering and discharging of the waste water
from the waste cell and ponds without taking appropriate waste water
treatment measures and remedial activities could result in toxins
contaminating the aquatic environment, disruption of the waste
previously deposited in the waste cell, failure of the walls of the
waste cell and ponds, and structural failure of the overall landfill
site leading to off site contamination events with long lasting
consequences.
The site currently has water flowing and seeping into, out of
and between the impoundments. Seepage has been observed along the
railroad tracks prior to February 2008. The seepage area was under 8
- 10 feet of water at the end of February 2008.
Water in the unnamed impoundment has been observed flowing into
Impoundment B. Water has also been observed flowing across the road
between impoundments B and C. The impoundment freeboard is none
existent in some areas.
There is a need to drain the impoundments carefully with proper
chemical treatment techniques and proper disposal of all the impounded
waters, monitoring of the receiving water body and proper evaluation
and remediation of the side walls and seepage areas of the
impoundments. This current situation at the landfill is substantially
different from the usual discharge of wastewater from a C & D
landfill. DEQ must require these activities and strengthen the
chemicals, chemical limits and monitoring requirements of the discharge
permit as part of their actions on this application. The following
activities must be required by DEQ to be performed by Waste Management
of Louisiana at the Chef Menteur Landfill and surrounding areas in
conjunction with the discharging of wastewater from the Chef Menteur
Landfill site.
-Identify the areas where water is overtopping the berms and
seeping into and out of the impoundments. Stabilize and remediate the
areas contributing to inflow and outflow.
-Set up a portable wastewater treatment unit to adequately treat
the impounded wastewater to meet industrial waste water discharge
limits. Toxic and industrial solid waste as well as hazardous waste was
disposed of in the Chef Menteur landfill
co-mingled with the hurricane debris waste. This waste has been
submerged underwater for a long period of time. Waste was last
deposited in the landfill on August 14, 2006. Waste water was last
removed from the landfill on July 13, 2007. Thus the waste water in
the waste cell and impoundments on the site have been contaminated with
toxic chemicals from the waste deposited in the disposal cell. In
addition the waste water in the cell and impoundments have been
determined to have concentrations of Ammonia, TSS, Heavy Metals and TOC
in excess of the wastewater permit limits established for C & D
landfills. The permit application proposed to treat the wastewater by
retention, flocculation and recirculation as necessary. These
treatment methods have proved to be inadequate and are totally
inappropriate to treat the toxic chemicals in the waste water at the
Chef Menteur site. The use of a portable treatment unit adequate to
treat toxic organics and heavy metals to non detectable limits is
necessary to protect the environment in the area of the Chef Menteur
landfill. Flow requirements and restrictions through the portable
treatment unity must be established in order to lessen the impact on
the receiving water body. In the application the proposed flow was
estimated to be 0.483 million gallons per day. This flow rate was to
occur during intermittent discharge events. Taking into account the
large volume of waste water to be treated and discharged, DEQ must
require that the allowable flow rate not negatively impact the
integrity of the cell and impoundment and does not negatively impact
the receiving water body. DEQ must establish monitoring requirements
and discharge limit for the waste water that will include monitoring
for Volatile Organic Chemicals, Semivolatile Organic Chemicals and RCRA
Heavy Metals with effluent limits of non detectable concentrations.
Monitoring frequency should be first established as once per day until
the effectiveness of the treatment unit is established. In order to
determine the impact of the discharge on surface water quality, of
critical importance is the requirement for monitoring of the receiving
water body on a frequent basis for toxic chemicals and physical and
chemical characteristics both up stream and down stream of the
discharge point and mixing zone. Such monitoring is necessary to
protect the quality of the receiving water body.
-Establish a draw down rate that allows for examination and
evaluation of the integrity of the side walls of the impoundments,
identification of the seepage areas, and monitoring of the interim cap
in the waste cell.
-Remediate the side walls and areas of seepage and inflow and
outflow that are contributing to migration of the water and waste water
into and out of the cell and impoundments.
-Track the impact on the interim cap over the waste disposed of in
the waste cell during discharge events and remedial activities.
-Require monitoring of water levels inside the waste cell and
impoundments and the surrounding water bodies on an ongoing basis
throughout the discharge and remedial activities.
-Identify the areas of hydraulic connections between the
impoundments and cells and the surface and groundwater resources of the
area.
-Require the establishment of air monitoring stations surrounding
the landfill site and in the community to monitor for particulate
matter, hydrogen sulfide, sulfur dioxide, methane and non methane
organic carbon. It has been reported that hydrogen sulfide and sulfur
dioxide emissions are a current problem in the area of the landfill.
As the interim cap and disposed of waste is impacted by the wastewater
drawdown, the problem of sulfur emissions may increase. During
remedial activities to insure the integrity of the impoundments and
remediate seep areas, dust emissions may become a problem and air
monitoring is an appropriate requirement.
-Require the clean closure of the waste in the disposal cell. The
waste in the waste disposal cell has been submerged under water for a
long period of time and will continue to be submerged. This submerged
condition will continue during the closure process, post closure period
and after the three year post-closure period. The site conditions
over the last 10 months demonstrated the need for removal of the waste
from the disposal cell. Even after the wastewater is treated and
discharged, the waste in the cell will still remain in the shallow
groundwater and will be covered by stormwater. The waste must be
required to be removed and properly disposed of.
The
hearing tonight deals with more than just a waste water discharge
application. The situation consist of a landfill that is underwater
and waste water impoundments whose integrity is questionable. If DEQ
grants the wastewater permit according to the terms of the draft
permit, a major off site pollution situation will continue to occur
and could reach catastrophic levels with damages to the Maxent Lagoon,
surrounding surface and groundwater resources, aquatic and terrestrial
environment and the health of this community.
The DEQ must take the appropriate actions and require
chemical and physical treatment of the waste water, much broader and
stricter discharge permit conditions to insure that toxic chemicals
from the submerged waste do not impact the surrounding aquatic and
terrestrial environment, requires the implementation of a remedial
action plan in conjunction with the treatment of the waste water in
order to restore the integrity of the waste cell and ponds, and removal
of the waste from the disposal cell to isolate the surrounding
environment from the threats posed by the waste.
|
|
