Ohio EPA approves permit for Envirosafe to expand landfill

Kelly J. Kaczala

        The Ohio Environmental Protection Agency has issued a Class 3 modification of the hazardous waste permit for Envirosafe Services of Ohio (ESOI), which allows continued operation of the treatment of hazardous waste in the company’s landfill located at 876 Otter Creek Rd.
        The agency held a public meeting in Oregon on January 8 in Oregon City Council chambers. Envirosafe had requested a vertical expansion of Cell M, its only active hazardous waste disposal cell.
        ESOI had submitted a permit modification to expand a portion of Cell M on May 11 last year. The Ohio EPA issued a draft approval for the modification November 9. The agency was required to act on the permit modification request on or before May 14 this year.
        ESOI has approximately three years of remaining capacity. With Ohio EPA’s modification approval, the new expansion will increase capacity by about five additional years.
Center of landfill
        The modification application had requested the following changes to the permit:
        • Vertical expansion of Cell M to increase the final height of the landfill by 14 feet and increase the remaining capacity by 144,670 cubic yards. The existing total capacity of Cell M is 3,194,300 cubic yards. The approval of the expansion will increase the total to 3,338,970 cubic yards. This amounts to a less than 5 percent proposed increase in the total capacity of Cell M. The remaining capacity of Cell M is calculated to be less than 100,000 cubic yards.
        •Update the surface water management retention analysis for the surface water retention ponds located adjacent to landfill cells G and H as a result of completed corrective measures at solid waste management units 6 and 7.
        The Cell M expansion is on the portion where soil and waste are exposed on the west side and center of the landfill. Plans include a new haul road to be constructed for additional waste placement on the top of the cell. The proposed primary fill area is in the center of the landfill.
        Based on the last topographical survey, the landfill is currently at approximately 96 feet above ground surface. The cell is currently permitted to go up another 10 feet. Upon completion of the expansion, the height will be 120 feet above ground surface or 24 feet higher than the current peak within the cell.
        Based on biennial reports submitted to Ohio EPA by Envirosafe since 2011, the hazardous waste facility disposes of approximately 50,000 tons of waste into Cell M each year. This correlates to approximately 30,000 cubic yards per year.
        The modification also updates the surface water retention analysis for the surface water retention ponds located adjacent to cells G and H - the closed older waste cells - due to completed corrective measures on the North and Central Sanitary landfills. The analysis indicated that the existing retention ponds are adequately sized. Therefore, the modification does not include any modifications to the closed portions of the facility.
        The Ohio EPA reviewed the permit modification request for compliance with the Ohio Administrative Code. The modified landfill request was reviewed for slope stability with the increased slope and increased final height. The slope stability analysis of the landfill indicates that the landfill would remain stable with the factor of safety remaining above 1.5, with 1.0 being stable. Because the expansion would expose the side slope of Cell M, Ohio EPA also reviewed water retention on the exposed waste. Ohio EPA also reviewed the constructability of the proposed expansion to minimize exposed waste during construction.
Future monitoring
        Ohio EPA will monitor the expansion activities, including leachate management after rain events. ESOI will be required to update the facility’s financial assurance now that the modification has been approved. The expansion of Cell M is not expected to significantly alter the closure cost estimate for Cell M.
        Issuance of the permit can be appealed to the Ohio Environmental Review Appeals Commission (ERAC), at erac.ohio.gov. Appeals generally must be filed within 30 days of issuing a final action. Anyone considering filing an appeal should contact ERAC at 614-466-8950.
        The Ohio EPA received and responded to public comments from the January meeting and those received throughout a public comment period. A sample of comments and responses include the following:
        •Comment: Officials from Arcadis, a consulting engineering firm, told Oregon officials that the slope stability design of Cell M falls below the Ohio EPA prescribed factors for safety.”
        •Response: Ohio EPA engineers reviewed the updated slope stability analysis that ESOI provided as part of the proposed expansion and determined that ESOI had satisfactorily demonstrated that the slope stability remained above 1.5. Any number above 1.0 is considered to be stable.
        •Comment: The site is impacting Lake Erie. Toledo’s raw water intake and supply lines [that go through the Envirosafe site] are not being protected.
        •Response: The vertical expansion of Cell M does not increase the footprint of the cell and therefore should have no impact on the City of Toledo raw water lines. Ohio EPA has no evidence of leaks from Cell M. Cell M is surrounded on all four sides by nested ground water monitoring wells to detect any leaks from Cell M. ESOI is required to submit ground water monitoring reports to Ohio EPA semi-annually.
        •Comment: I would like an update for the three trust funds and how much has been removed from the interest in the perpetual fund.
        •Response: The current permit has similar conditions regarding financial assurance for closure care. The current mechanism for funding each is a trust fund. As of February 28, the closure trust fund had a value of $13,285,973.72 to cover the estimated closure cost of $7,912,275.78. The post closure trust fund had a value of $38,439,658.01 to cover the estimated post closure cost of $10,749,848.04 and perpetual care cost of $19,410,646.37. The total excess remaining between the two funds after these costs are deducted is $13,652,861.54. That excess is used to fund the corrective measures estimate of $10,502,000. There is also $689,807.73 pending reimbursement for eligible completed work. After deducting the corrective measures and pending reimbursements from the excess, the trust funds are overfunded with an excess of $2,461,053.81.


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