PowerPoint Presentation

MSW Efficiency Project Phase II : New Forms for Type I Landfill ApplicationsMatthew UdenenwuWaste Permits Division

2015 TCEQ Environmental Trade FairOur discussion this morning will be about the forms the MSW Program has developed as part of the Efficiency Projects we have been working on over the last couple years.1IntroductionClosure Plan

Closure Cost Estimate

Transportation Data and Coordination

Post Closure Care Plan

Post Closure Care Cost Estimate

We will see some details from the forms for the aspects of a permit application for a Type I landfill that pertain to closure and post-closure care, cost estimates and transportation data. But, before we do that, let us refresh our memories on why and how we got to these forms.

2BackgroundWe identified and acknowledged certain process challenges that continue to make the processing of Permit Applications cumbersome and inefficient. We set out to find solutions that address those challenges, and one of the end results of that effort is the forms we will show in this presentation. The process challenges we that saw include: NEXT SLIDE -:3Variability in SubmittalsThis graphic shows how the application submittals we receive vary from one to another. So, we receive application for Landfill X and the geology report is over 1600 pages and then we receive another, Application Y and the geology report is 200 pages. This raises the questions: is one missing vital information or is the other just overblown? How do we achieve some uniformity in submittals?4Permit Application Deficiencies

This chart shows 9 Permit Applications we declared technically complete not to long ago. So, we receive and review Permit Application D and have only a total of 98 deficiency comments, Even though Application D had only 98 NOD comments, it underwent 4 rounds of NODs; then we receive and review Permit Application F and have a total of 527 deficiency comments. Application F underwent 5 rounds of NODs and the Applicants requested for and was granted extension of time to respond to the NODs on 3 occasion during the review process.

These raise the question, are the applicants not doing a good job with their applications or are some of reviewers being too picky or not doing proper review?

And what is the implication of too many NODs, too many rounds of NOD iterations, too many extensions of time?5Application Review TimesIncrease in the total review time! This graphic shows the number of days that each of the nine applications were in review. Recall Application D with 98 NOD Comment? it was in review for about 1500 days, F was in review for over 800 days. Now, our goal is to complete technical review within 365 days of the receipt of a Permit application, not counting days in Contested Case Hearing. As you can see, only one application appears to meet this review timeframe goal. So, what to do? We performed necessary analysis of the problem. NEXT SLIDE:-

6Perform Problem Analysis

We found that most the deficiency issues emanate from these 13 Elements of a Permit Application. To address the issues associated with each of the 13 elements, we broke down each element into sub-elements and into review items as set out in the rules. We then developed documents that set out the scope of review and the criteria for determining technical adequacy in addressing each rule review item. We then compiled the technical review adequacy criteria document for each of the 13 elements and determined that some of them lent themselves to conversion into forms.

7Steps to Forms The Forms Ready Closure Plan

Post-Closure Care Plan

Closure Cost Estimate

Post-Closure Care Cost Estimate

Transportation Data and Coordination ReportsIn DevelopmentGeneral Facility Design

Threatened and Endangered Species Location Restrictions

Waste Acceptance Plan

These are the elements we determined would work well as forms. Thus Far, 5 of the forms are ready to be released for use. The remaining 4 are in various stages of development. That is the Background!

Now, let us see the major parts of the 5 forms that are ready for release. Starting with the Closure Plan9Closure Form

Page 1Section IGeneral Information

Section IIPart A -Description of Landfill Units

Part B Description of Storage or Processing Units

Part C Maximum Waste Inventory

Part D Locations of Unit Drawings

The Closure Plan Form is made up 17 pages divided into VII Sections. Section I, General Information, asks for information that identifies the facility and the site operator.

Section II asks for information on the units that would require closure at the facility, including the size and waste inventory within each unit. Section II.A is for landfills, while section II.B is for processing facilities associated with the permit.10

Closure FormPage 3Section III Final CoverPart A - Types and Description

Part B Design Features (top and side slopes)

Part C Drainage Features

Part D Vegetation or other ground cover material

Part E Final Contour Map

Section III asks for information that describe the type and design of the final cover; which includes the cover system components, the top and sides slopes, 11

Closure FormPage 6Section IV Final Cover System InstillationPart A Mode of Instillation

Part B Drawings showing Sequence of Installation of Final Cover

Part C Final Cover Quality Control Plan (FCQCP)

Part D Final Cover System Evaluation Report (FCSERSection IV requests information that describes the final cover system installation procedure, the drawings that show details, cross-sections, and installation sequence drawings of the final cover. 12

Closure FormPage 8Section V - Closure Activities and Schedules

Part A Closure of Landfill Unit

Closure Notification

Submit Final Cover System Evaluation Report

Submit Engineers Certification of Closure

TCEQs Acknowledges Closure

Section V lists activities to be completed by the site operator for closure.

Section V.A lists the activities for closing a landfill unit within the facility. What this form has made clear is that for facilities that have more than one landfill unit, the site operator can close one unit while others are still receiving waste.For a landfill unit, the closure activities include notifying TCEQ of intent to close the unit, stoppage of waste receipt, construction of the approved final cover; 13

Closure FormPage 12Section V - Closure Activities and SchedulesPart C Final Facility Closure Criteria

Publish Final Closure Notice and Place Closure Plan in Public Place

Submit Written Notice to TCEQ Executive Director

Post Signs and Install Barriers

File Affidavit to the Public and Performance of the Final Deed Recording

Section V.C lists the activities and protocol for closure of entire facility. These include publication of notice of final closure in a local newspaper, notification of TCEQ, 14

Closure FormPage 14Section V: Part C Final Facility Closure Criteria (cont.)

Submit Copy of Affidavit to the Public and Modified Deed to the TCEQ Executive Director

Certification of Final Facility Closure by 3RD Party P.E.

Submittal of appropriate info to the TCEQ15

Closure FormSection V: Part C Final Facility Closure Criteria (cont.)

TCEQ Accepts Termination of Operation and Closure of a Landfill Facility

Closure Schedule

Section VI: Attachments Page 15Closure is not complete until TCEQ sends a written acceptance of termination of operation and acknowledgment of proper closure of the facility. 16

Closure FormPage 17Section VII - Engineers Seal and SignaturePE seal, signature, and date is needed on the form. There is a separate instruction part consisting of nine pages to assist in clarifying aspects of the form.17

Closure Cost EstimatePage 1Section I Engineers Statement Seal and SignatureThe form starts with identifying the facility and the site operator, and a statement of the total amount calculated for closure.Section I requests the responsible PEs seal, signature, date, and well as the engineering firms information.18

Section II

Site Operators Acknowledgment to Perform Annual Reviews and Updates Closure Cost EstimatePage 2Section II lists the site operators agreement to perform annual reviews of site conditions, revise the cost estimates, update the costs for inflation, provide and maintain FA, etc.19Closure Cost EstimateSection III Descriptions of Cost Estimate Worksheet Items

Engineering Costs

Construction Costs

Storage and Processing Units

Contingency

Contract Performance Bond

Page 3Section III provides descriptions of the minimum work or cost items utilized in determining unit costs or lump sum for each item. 20Closure Cost EstimateSection IV

Closure Cost Estimate Worksheet

Page 8Section IV is the closure cost worksheet made up of 7 columns. with itemized Work Items, units, and cells for entry of the cost data. The responsible engineer will provide the source of unit cost estimate to help in validating the data. 21Closure Cost EstimateSection IV Closure Cost Estimate Worksheet (contd)

Page 11Typical sources of the unit costs are provided in this page. The form will include appropriate attachments as indicated here.22Transportation Data

Page 1General InformationThis is an 8 page form made up of XI Sections.23Transportation Data

Page 2Section I Documentation of Coordination with TxDOT

Section IITxDOT Recommended Roadway or Intersection Improvements

Section IIIDocumentation of Coordination of Public Roadway Improvement with the Agency that has Jurisdiction

Section I requests information regarding coordination with TXDOT for traffic and location restrictions. We need to know that the site operator has coordinated with TXDOT and received TXDOTs response to the coordination correspondence. We also need that copies of the coordination documents are attached herein.

Section II requests information regarding TXDOTs recommended roadway or intersection improvements.

Section IV requests information used or assumed in obtaining transportation data, e.g. waste acceptance rates operating hours, site life, etc. These are mostly data validation information.

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Transportation DataSection V Facility Daily Traffic Volume DataPage 5Section V asks for daily traffic volume data to and from the facility; methods used in obtaining this data; and maps showing applicable roadways within 1 mile of the facility used to access the site.25Transportation DataSection VI Availability and Adequacy of Roads

Section VII Conclusion on availability and adequacy of roads

Section VIII Highway Beautification

Section IX Analysis of Impact upon Airports

Page 6Section VI requests data on the primary access roads used to access the site and other roads within 1 mile of the facility used by vehicles that access the site. The data required include: name of road, average daily traffic on roadway, roadway capacity, and so on.Section VII requests conclusion drawn from the roadway data on the availability and adequacy of roads to be used in access the site.

Section VIII request information relating to highway beautification act to establish whether the executive director would require screening of the waste activities from the major roadways.

Section IX requires cross-reference information regarding the location of the analysis of the impact of the facility upon airports.26

Transportation DataPage 8Section X Documentation of Coordination with Airport Location Restrictions

Section XI FAA Recommended Changes (as applicable)Section X requests information regarding documentation of coordination with the Federal Aviation Administration for compliance with Airport location restrictions. Any recommended actions by FAA will be described herein.

Section XI list attachments expected with the Transportation form.27

Post-Closure Care PlanPage 1Section IGeneral Information

Section II Party Responsible for Overseeing and Conducting Post-Closure Care Activities

Section IIIPost Closure Care Status of Landfill Units

The site operator will provide information on the person or office within his organization that will oversee post-closure28

Post-Closure Care PlanPage 3Section IV Post Closure Care Maintenance Requirements and Activities

Section IV: Part B Post Closure Care Maintenance Requirements and Activities for Facilities that Stopped Receiving Waste Prior to October 9, 1993

Section IV.B provides protocol and requirements for conducting post-closure care for units that stopped accepting waste prior to October 9, 1993 and that for

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Post-Closure Care PlanSection IV: Part C- Post Closure Care Requirements and Activities for Landfill Units that Received Waste on or After October 9, 1993Commencement of post-closure care

Period of post-closure care

Inspection Activities

Documentations of Corrective Actions

Page 7Section IV.C provides requirements and protocol for conducting post-closure care for units that accepted waste after October 9, 1993, including new units.30Post-Closure Care Plan

Page 9Section IVTable 5 Inspection Activities Schedule Final CoverThe engineer will provide information on what to inspect for during post-closure care for different components of the landfill subject to inspection.31

Post-Closure Care PlanPage 14Section IV9. Continuation of Monitoring Systems Operation and Maintenance

Must indicate continuation of monitoring system operation and maintenance GW, lfg, lcs32

Post-Closure Care PlanPage 15Section IV

Table 8 Landfill Gas Management System Inspection33Post-Closure Care Plan

Page 18Section V - Recordkeeping

Section VI Planned Use of the Land during and after the Post-Closure Period

Section VII Post-Closure Care and Corrective Action Cost Estimates34

Post-Closure Care PlanSection VIII Certification of Completion of Post Closure CarePage 1935

Post-Closure Care PlanSection IX Voluntary Revocation Request

Section X Attachments

Section XI Engineers Seal and SignaturePage 2036

Post-Closure Care CostsPage 1Section I Professional Engineers Statement, Seal, and Signature37Post-Closure Care Costs

Section II Annual ReviewPage 238Post-Closure Care Costs

Page 3Section III Description of Worksheet Items of the Post-Closure Care Cost Estimates

Engineering Costs

Construction Costs

Leachate Management Costs

Contingency

39Post-Closure Care Costs

Page 6Section IV Post-Closure Cost Estimates Worksheet40Post-Closure Care CostsSection IV - Post-Closure Cost Estimates Worksheet

Page 741Whats Next?Release the Forms for Use

Continue Work on the other Pending Forms

Finalize the TRAC Documents for Internal Use

42Q & AThe TCEQ appreciates the organizations and individuals that provided comments on these draft forms.

How to Contact UsTCEQ - MSW Permits SectionP.O. Box 13087 MC-124Austin, TX 78711-3087

Phone: (512) 239-2335 Fax: (512) 239-2007Email: MSWPER@tceq.texas.gov43