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Performance-Based System for Post-Closure Care at MSW Landfills California Integrated Waste Management Board Post-Closure Maintenance Period and Financial Assurances for Post-Closure Maintenance Workshop December 6, 2004 GeoSyntec Consultants
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Speaker Michael Caldwell, PG Michael Caldwell, PG Sr. Director, WM Environmental Protection, Groundwater ProgramSr. Director, WM Environmental Protection, Groundwater Program More than 18 years of RCRA solid and hazardous waste experience More than 18 years of RCRA solid and hazardous waste experience Member of ITRC Alternative Landfill Technologies PCC Team Member of ITRC Alternative Landfill Technologies PCC Team Representing WM as a member of the EREF PCC Technical Advisory Panel Representing WM as a member of the EREF PCC Technical Advisory Panel
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GeoSyntec Consultants CIWMB Regulatory Standard 27 CCR §21900: 27 CCR §21900: “The operator of a solid waste landfill may be released from post-closure after a minimum period of 30 years upon demonstration to and approval by the CIWMB, the EA, and the RWQCB that the solid waste landfill no longer poses a threat to public health and safety and the environment”“The operator of a solid waste landfill may be released from post-closure after a minimum period of 30 years upon demonstration to and approval by the CIWMB, the EA, and the RWQCB that the solid waste landfill no longer poses a threat to public health and safety and the environment”
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GeoSyntec Consultants The EREF Performance-Based Methodology is Designed to: Provide the Solid Waste Community with a Tool to Make Technically-Defensible Decisions Regarding PCC for MSW Landfills Provide the Solid Waste Community with a Tool to Make Technically-Defensible Decisions Regarding PCC for MSW Landfills To achieve the objectives of 27 CCR §21900 to demonstrate that the landfill does not pose a threat to HH&E To achieve the objectives of 27 CCR §21900 to demonstrate that the landfill does not pose a threat to HH&E
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GeoSyntec Consultants USEPA Reference to a Performance-Based Approach to Ending PCC “… In an approved state, the Director may allow an owner or operator to cease managing leachate if the owner or operator can demonstrate that the leachate no longer poses a threat to human health or the environment.” “… In an approved state, the Director may allow an owner or operator to cease managing leachate if the owner or operator can demonstrate that the leachate no longer poses a threat to human health or the environment.” (40 CFR §258.61(a)(2) “Concentrations at the points of exposure, rather than concentrations in the collection system, may be used when assessing threats.” “Concentrations at the points of exposure, rather than concentrations in the collection system, may be used when assessing threats.” EPA530-R-93-017, Section 6.6.3
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GeoSyntec Consultants A Performance-Based System for Post-Closure Care at MSW Landfills: A Procedure for Providing Long-Term Stewardship under RCRA Subtitle D
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GeoSyntec Consultants GeoSyntec, MD (Project Management) GeoSyntec, MD (Project Management) EREF EPCC Project Team Tech. Advisory Panel Industry Regulators Researchers Tech. Advisory Panel Industry Regulators Researchers Industry (Technical Resources and Data) Industry (Technical Resources and Data) Project Team Experts Project Team Experts Other Resources ITRC ASTSWMO Industry Leaders State Regulators Trade Associations Other Resources ITRC ASTSWMO Industry Leaders State Regulators Trade Associations
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GeoSyntec Consultants EREF Project Attributes Scientifically-based method that addresses PCC on a modular basis Scientifically-based method that addresses PCC on a modular basis New paradigm for data collection New paradigm for data collection Conservative assumptions & approach Conservative assumptions & approach Rigorous post-decision monitoring Rigorous post-decision monitoring ConfirmationConfirmation SurveillanceSurveillance Will promote proactive landfill practices Will promote proactive landfill practices e.g., leachate recirculation, liquid wastes, A-Cap, etc.e.g., leachate recirculation, liquid wastes, A-Cap, etc.
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GeoSyntec Consultants EREF EPCC Project Objectives Provide a rigorous technical approach to assess and optimize PCC activities Provide a rigorous technical approach to assess and optimize PCC activities Allow More Effective Management of Existing PCC Funds Allow More Effective Management of Existing PCC Funds Assess conditions early, evaluate landfill status, and monitor for the effects of change with two levels of protective monitoring Assess conditions early, evaluate landfill status, and monitor for the effects of change with two levels of protective monitoring Provide Increased Certainty for Operators and Regulators within existing regulations Provide Increased Certainty for Operators and Regulators within existing regulations Develop a Standardized, Performance-Based System to Define, Manage, & Ultimately Exit PCC. Intent is to: to Define, Manage, & Ultimately Exit PCC. Intent is to:
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GeoSyntec Consultants Possible Outcome of Implementation of the EREF EPPC Methodology (Not >10 Years After Closure) Continue PCC – Post-closure care (and additional data collection) is still required. Continue PCC – Post-closure care (and additional data collection) is still required. Optimize PCC – Post-closure care must continue for at least one element but optimization of activities does not pose a threat to HH&E Optimize PCC – Post-closure care must continue for at least one element but optimization of activities does not pose a threat to HH&E End of Regulated PCC – The landfill does not pose a threat and de minimus management of end-use obligations are maintained (referred to as “custodial care”) End of Regulated PCC – The landfill does not pose a threat and de minimus management of end-use obligations are maintained (referred to as “custodial care”)
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GeoSyntec Consultants Assessment of MSW Landfills in Peer- Reviewed Technical Literature The quality of leachate and LFG in a landfill can be correlated to the “phase” of the life of the landfill; The quality of leachate and LFG in a landfill can be correlated to the “phase” of the life of the landfill; The factors that affect a landfill as it progresses through each phase of its life are understood and can be identified for a particular landfill; and The factors that affect a landfill as it progresses through each phase of its life are understood and can be identified for a particular landfill; and The future trends of leachate and LFG can be predicted based on known, current quality and knowledge of that phase of its life. The future trends of leachate and LFG can be predicted based on known, current quality and knowledge of that phase of its life. EREF EPCC Report (pending 1Q 2005)
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GeoSyntec Consultants
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Project Status Final draft of EREF PCC reviewed by technical team and TAP Final draft of EREF PCC reviewed by technical team and TAP Report expected in 1Q 2005Report expected in 1Q 2005 ITRC preparing draft report for team member review ITRC preparing draft report for team member review Significant input from regulatory community including CIWMBSignificant input from regulatory community including CIWMB Final report expected to be complete by May 2005Final report expected to be complete by May 2005
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GeoSyntec Consultants Thank You! Contacts: Mike Houlihan, PE, GeoSyntec Consultants mhoulihan@geosyntec.com mhoulihan@geosyntec.com Michael Caldwell, PG, WMI mcaldwell@wm.com Ed Repa, PhD, EREF erepa@erefdn.org
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GeoSyntec Consultants EREF EPCC Technical Advisory Panel Environmental Research and Education Foundation Edward Repa, Ph.D. Project Manager Research Institutions Debra Reinhart, Ph.D., P.E Assoc. Dean, Civil & Environmental Engineering University of Central Florida EREF Board Member Public Sector N.C. Vasuki, P.E., DEE CEO, Delaware Solid Waste Authority SWANA Private Sector David Burt, P.HG. Sr. Director, Environmental Protection, Waste Management, Inc. Clarke Lundell, P.E. Director, Engineering, Republic Industries Regulatory Agency Liaisons EPA (OSWER) ASTSWMO (Paul Farrell, VADEQ)
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GeoSyntec Consultants Project Team Experts Groundwater Protection Mr. John Gallinatti, GeoSyntec, CA Containment Systems Dr. Rudy Bonaparte, GeoSyntec, GA Geotechnical Issues Mr. Mike Houlihan, GeoSyntec, MD Landfill Gas Mr. Pat Sullivan, SCS Engineers, CA Leachate Dr. Morton Barlaz, NC State Univ. Dr. Jeremy Morris, GeoSyntec, MD Data Analysis Dr. Robert Gibbons, Univ. of Illinois (Chicago) Risk Assessment Toxicology Public Policy
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