| LDEQ Notice On Chef Landfill Permit Insufficient |
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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 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. |
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