Closure and Post-Closure Armando Barrera – Environmental Permit Specialist Municipal Solid Waste (MSW) Permit Section

Agenda What is closure and post-closure care What occurs at waste processors, recyclers & disposal sites What to include in closure and post-closure care plan Where to find forms

General Timeline of a Disposal or Processing Facility Remove Waste Final Cover Continued Monitoring Permit Revocation Closure and Post-Closure Construction Waste Transfer Waste Disposal Site Monitoring Operation of Facility Development Plan Operating Plan Review Public Notice Application and Authorization

General Definitions Closure Post-Closure Care Stop taking waste Remove all waste, residues, and recovered materials from storage and processing units Cover disposal sites with a final cover system Maintain right of entry Maintain final cover from erosion, lack of vegetation, or ponding water Continued Gas and Groundwater Monitoring Maintain Leachate Collection

Applicability Processing Facilities Disposal Facilities Closure Certification Voluntary Revocation Final Cover Closure Plan Post-Closure Care Plan Monitoring Certification Voluntary Revocation

Processors Recycling Facilities Transfer Stations Composting Facilities Liquid Waste Processing Facilities Medical Waste Processing Facilities

Closure Processes Remove all waste, waste residues, and any recovered materials Dismantle and remove all facility units or decontaminate Evacuate all on-site material and feedstock to an authorized facility Disinfect all waste management units/areas If there is evidence of a release, an investigation may be required

Notice of Final Facility Closure Publish a public notice in the newspaper of largest circulation in the area Notice to the Executive Director Post a sign at the entrance to the facility Information in the notice Name Address Physical Location Authorization Number Last date of received waste

Certification of Final Facility Closure Submit a certification verifying that final facility closure has been completed within 10 days. Signed by an independent licensed professional engineer. Request for voluntary revocation.

Disposal Facilities Type I Landfills Type IV Landfills Type I & IV Landfills Type I AE Landfills Type IV AE Landfills Type I & IV AE Landfills

Final Cover System Designed & constructed to minimize infiltration and erosion. 2 feet of soil 18 inches of clay-rich soil 6 inches of earthen material Quality tested every acre

Liner System Properties for MSW Units If there is a Synthetic Bottom Liner Synthetic membrane equal or less permeable than the bottom liner Minimum 20 mils 60 mils for HDPE Clay-Rich Soil Layer 18 inches Coefficient of permeability <1 x 10-5 cm/sec Erosion Layer 6 inches Sustaining Native Plant growth Seeded or sodded immediately

Final Cover Properties-Class 1 Cells Clay-Rich Soil Layer 4 feet Coefficient of permeability <1 x 10-7 cm/sec Membrane Layer Synthetic membrane equal or less permeable than the bottom liner Min. thickness of 20 mils 60 mils for high-density polyethylene to ensure seaming Top Soil Layer 18 inches Coefficient of permeability <1 x 10-5 cm/sec Erosion Layer 6 inches Sustaining Native Plant growth Seeded or sodded immediately to minimize erosion

Alternative Final Cover Designs Must achieve an equal reduction in infiltration as the clay-rich soil cover layer Must provide equivalent protection from wind and water erosion

Alternative Final Cover – Water Balance Limits percolation by use of silty and clayey soils until the water is removed by evapotranspiration No less than two feet of thickness Requires modeling unless Statewide Design Table is used Financial Assurance must cover most expensive final cover option in the facility permit Guidance (RG-494) is available

Closure Plan Lays out the steps necessary to close all MSW landfill units at any point during the active life of the unit. Includes: Final Cover Design Installation Methods and Procedures Estimate of Largest Area requiring a final cover Estimate of maximum inventory of wastes ever on-site Schedule for completing closure activities Final contour map with final contours, top slope, side slopes, surface drainage features, & protection of any 100-year flood plain

Closure Implementation Place copy of closure plan in operating record 45 days before initiating closure, write notification to ED. Place notice in record. Before 30 days after unit receives last receipt of waste, begin closure activities. Within 180 days, complete closure activities. Certification signed by an independent licensed professional engineer Inspection report from regional office Affidavit to the public and record in the deed Begin Post-Closure Care

Post-Closure Activities Maintain: integrity and effectiveness of the final cover the leachate collection system the groundwater monitoring system the gas monitoring system

Length of Post-Closure 30 Years for Type I and Type I AE 5 Years for Type IV and Type IV AE Can be decreased based on documentation and certification. Can be increased if it is necessary to protect human health and the environment

Post-Closure Care Plan Describes the monitoring & maintenance activities required, and the frequency Information for person responsible for overseeing the post-closure care activities Description of the planned uses of any portion of the closed unit Detailed written estimate, in current dollars

Completion of Post-Closure Care Submit a certification, signed by an independent licensed professional engineer, verifying that post- closure care has been completed in accordance with the post-closure plan. Submit a request for voluntary revocation of the facility permit.

Cost Estimates Included in the application and applies to Landfills Storage and Processing Facilities Recycling Facilities that store combustible materials. Financial Assurance

Closure Cost Estimates For Processors In current dollars Cost of hiring a third party Disposition of all processed and unprocessed materials Maximum inventory of all wastes Based on a per cubic yard and/or short ton measure If conditions change, cost estimates should be adjusted accordingly. Decrease in costs would not be acceptable unless strongly justified with data.

Estimates for Combustible Materials Estimate Maximum amount of combustible materials stored outdoors. Calculate the disposal cost for each type of material. Estimate loading costs Loading Cost = Max Amount of Material in cubic yards x $0.80 per cubic yard Loading Cost = Max Amount of Material in tons x $1.00 per ton Estimate the cost of hiring a third party to transport Number of Truckloads to transport max amount of material (weight limit, load capacity) Transportation Cost = # of truckloads x mileage to disposal facility x $2.50 per mile Total Estimated Cost = Loading Cost + Transportation Cost + Disposal Cost

Closure Cost Estimates for Landfills In current dollars Cost of hiring a third party Closing the largest waste fill area that could potentially be open Areas that have not received final cover Review permit conditions on an annual basis and verify active areas match closure cost estimate areas. If conditions change, cost estimates should be adjusted accordingly. Decrease in costs would not be acceptable unless strongly justified with data.

Post-Closure Cost Estimates for Landfills In current dollars Cost of hiring a third party to conduct post-closure care activities. Annual and periodic costs for gas and groundwater monitoring. If correction action must be taken, a cost estimate for hiring a third party to perform the activities is required.

Example Items in the Cost Estimate Engineering Costs – Surveys, Closure Inspection, Testing, Contract Administration Construction Costs – Mobilization of Personnel and Equipment, Final Cover Clay, Geosynthetic Clay Liner, Membrane Cover, Drainage Aggregate, Vegetation, Site Fencing Storage Unit Closure Costs – Waste Disposal, Material Removal Well Monitoring – Landfill Gas, Groundwater Leachate Management – Operation, Maintenance and Disposal Contingency – 10% of Sum of Engineering Costs, Construction Costs, Maintenance Costs, and Management Costs Third Party Administration and Project Management Costs – 2.5% of Sum of Costs

Sources of Estimates Published Cost Estimator Manuals (e.g. RS Means) Written quotes from an independent contractor not affiliated with the facility. Verifiable Data based on Actual Operations

Financial Assurance – 30 TAC Chapter 37 Trust Agreement Payment and Performance Bonds Letter of Credit Certificate of Insurance Financial Test Government Guarantee

Voluntary Revocation Certification of Closure and Post-Closure from independent licensed engineer Inspection report from agency regional office Affidavit to Public Deed Recordation Submit Form TCEQ-10359

Website – www.tceq.texas.gov

Available Forms

Texas Administrative Code References Closure and Post-Closure Procedures for Landfills and Processors Title 30 Chapter 330 Subchapter K Cost Estimates for Closure and Post-Closure Title 30 Chapter 330 Subchapter L Closure Procedures for Recycling Facilities Title 30 Chapter 328 Subchapter A Closure Procedures for Composting Facilities Title 30 Chapter 332 Subchapter C Closure Procedures for Medical Waste Facilities Title 30 Chapter 326 Subchapter F

Thank you for coming Armando Barrera Environmental Permit Specialist Waste Permits Division Armando.Barrera@tceq.texas.gov