the path less traveled Termination of Post Closure Care Hosier Road Landfill – Suffolk, VA

01 02 03 04 05 06 overview What is Post Closure Care? Will it ever end? 03 How do we get there? 04 Facility Information 05 Stages of Termination Landfill Gas Monitoring Leachate Collection Groundwater Monitoring 06 The Wrap Up

What is Post Closure Care? The requirements placed upon solid waste disposal facility after closure to ensure environmental and public health safety for a specified number of years after closure. Maintain Final Cover Maintain Leachate Collection Maintain Groundwater Monitoring Maintain Gas Monitoring

You have to be in compliance! When will it end? The requirements placed upon solid waste disposal facility after closure to ensure environmental and public health safety for a specified number of years after closure 10 years if you stopped taking waste before October 9, 1993. 30 years if you stopped taking waste on or after October 9, 1993. There’s a catch! You have to be in compliance!

Facility information Hosier Road Landfill

Facility Information Unlined pre-regulatory facility; 67 acres EPA evaluated due to pesticide disposal; given Superfund Status (currently delisted) 1967 1985 trench and fill  mass fill Capped with soil liner system 1991 Leachate collection system installed 1993 Groundwater monitoring initiated 1994 Official Closure 1995 Gas monitoring initiated Clock start 10 year PCC…

Facility Background Groundwater Exceedances Landfill Gas Migration Assessment Monitoring 1993 GPS Exceedance - Cobalt Corrective Action Required Landfill Gas Migration Exceedance 2007 Moving beyond property boundaries Leachate Collection Started 1991 Pump and haul operation Arsenic First metals exceedance

Termination Path options Request Terminate for all aspects of post-closure care Allows you to stop all compliance requirements at once Request Partial-Termination of post-closure care Allows you to stop specific compliance portions one of more at a time. Landfill Gas, Leachate, Groundwater

Landfill gas Landfill Gas Migration In compliance for the next 3 years Designed and Constructed a Mitigation trench to prevent landfill gas migration Trench dug down to seasonal groundwater low Liner place on furthest side Collection/Vent piping installed Backfilled with recycled tire chips Gas probes were back in compliance within 30 days of trench completion (2009) In compliance for the next 3 years Requested Partial Termination of Post Closure Care Approved by VDEQ 2013

Leachate Collection System is designed to collect leachate seeps from the waste mass System is comprised of four 4,000 gallon tanks fed by a gravity trench at each slope Liquid collected in the tanks are hauled off site for disposal Costing thousands of dollar to haul offsite Tanks were experiencing rapid recharge and an instance of overflow

Leachate Collection Evaluation of Leachate Quality The majority of parameter concentrations in the collection tanks are below the groundwater protection standards Liquid in the tanks is significantly different than in the waste mass The liquid in the collection system did not fall within the typical range of concentration for indicator constituents for leachate Collection system appeared to be collecting infiltration from precipitation events or groundwater only

Leachate Collection Request for Leachate System Abandonment Developed and implemented an abandonment plan for the system with regulatory approval Simulated System Abandonment and Monitored for six months Requested to abandon the leachate system Approved for abandonment by VDEQ in February 2014 Fully Abandoned in July 2015

Groundwater Compliance In Assessment Monitoring until exceedance for Cobalt Moved into Corrective Action Only one well in exceedance for cobalt; located on edge of waste mass Alternate Point of Compliance (APC) well requested; VDEQ Approval 2015 APC well is in compliance for Cobalt! City requested a release from Corrective Action, but during review, APC well has new exceedance for Cadmium

Groundwater Compliance Evaluated options to remediate the Cd concentrations: Would take too much time for Natural Attenuation Difficult to eliminate metal contamination quickly City did not want to have a long term cost to remediate an extremely low level of concentration.

UECA! Uniform Environmental Covenant Act A servitude that imposes activity and use limitations on contaminated real property, allows for the long-term monitoring and enforcement of any risk-exposure controls placed on the property (i.e., restrictions on land uses/disturbances and prohibitions on using the impacted aquifer) in a statutorily defined, voluntary agreement “environmental covenant”). Such a covenant runs with the land and would be binding on subsequent land purchasers and tenants of the property. It would also be listed/recorded in the local land records office

UECA! Resources: VDEQ provides a template in 9 VAC 15-90-30 VDEQ FAQ Page: http://www.deq.virginia.gov/Portals/0/DEQ/Land/Guidance/UECA.pdf Regulations (9 VAC 15-90-00): https://law.lis.virginia.gov/admincode/title9/agency15/chapter90 VDEQ provides a template in 9 VAC 15-90-30 VDEQ Contact Point: Ms. Michelle Hollis UECA Coordinator (804) 698-4014 michelle.hollis@deq.virginia.gov

JOB DONE!! The wrap up 2.16.2017 UECA Finalized 2.24.2017 Corrective Action Terminated 9.18.2017 Full Termination of Post Closure Care 12.12.2017 Monitoring Wells and Gas Probes Abandoned City has to inspect the facility every 5 years and report to VDEQ (no sampling for groundwater or landfill gas involved) JOB DONE!!

Aaron J. White, PG www.hdrinc.com 249 Central Park Avenue, Suite 201 Professional Associate Project Manager   249 Central Park Avenue, Suite 201 Virginia Beach, VA 23462 D 757.222.1500 aaron.white@hdrinc.com www.hdrinc.com