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Kentucky Resources Council, PO Box 1070, Frankfort, KY 40602 Phone [502] 875-2428

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PO Box 1070, Frankfort, KY 40602  Phone 502.875.2428, Fax 502.875.2845

Comments on Glasgow Landfill Water Discharge Permit  Posted: November 20, 2006
November 20, 2006

David W. Morgan, Director
Division of Water
14 Reilly Road
Frankfort, Kentucky 40601

Re: Public Notice 2006-35
KPDES Permit KY 0095681, Agency Interest 74
City of Glasgow Landfill

Dear Mr. Morgan:

These comment are submitted on behalf of the Kentucky Resources Council, Inc., (Council), a non-profit environmental advocacy organization incorporated under the laws of the Commonwealth of Kentucky and dedicated to prudent use and conservation of the natural resources of the Commonwealth. KRC has reviewed the proposed terms and conditions and fact sheet for the proposed KPDES Permit authorizing discharges from the Glasgow Regional Landfill into South Fork Beaver Creek and Huggins Branch, and offers these comments.

1. Given the complexity and variability of the composition of landfill leachate from MSW landfills, the Council believes that a broader spectrum of monitoring requirements should be included in the final permit. At a minimum:

a. All indicator parameters contained in the 401 KAR 47:030 Environmental Performance Standards should be sampled in order to allow for prompt detection of any leachate contamination in stormwater runoff, and to allow for appropriate corrective action from the contaminated seep;

b. In this and all MSW KPDES permits, the Division should coordinate issuance of the water permit with the Division of Waste Management and assure that appropriate indicator parameters are included for each significant industrial of commercial waste stream in order to allow for detection of any leachate contamination from the facility and to impose appropriate conditions to protect stream health.

At a minimum, for both the active and closed areas of landfills accepting commercial or industrial solid waste, including UST soils, or sewage sludge from facilities with industrial dischargers in addition to residential waste should be required to monitor for all RCRA metals, expressed as total recoverable metals, as well as a broad spectrum analysis that will detect a wide range of the mobile volatiles associated with the disposal of industrial and commercial wastes.

The Council believes that with any facility accepting mixed waste (industrial, commercial, institutional or special in addition to residential), the imposition of all ten RCRA metals, total base/neutrals and acids using Test Method 625, and purgeables using Test Method 624 should be required at a minimum. RCRA metals testing and use of test methods 624 and 625 should be standard for all solid waste landfills, since a wide range of organics and inorganics of concern may be present at concentrations below RCRA - hazardous, but well above background or MCLs.

A requirement to run a GCMS analysis on water samples on a quarterly basis using Test Method 624, which will test for some 60+ compounds and degradation byproducts, including the degradation metabolites of trichloroethylene, as well as other chlorinateds and aromatics, is supported, and should be imposed on any facility has accepted commercial, institutional or industrial solid waste or special wastes, or ash from any incineration process. Such a requirement would be particularly useful since it also is capable of detecting BTEX.

2. Numerical and biological standards for protection of in-stream water quality for chlorides and all other constituents should be addressed, and specific values added as necessary to assure that at all times the acute and chronic standards will be met.

3. In order to determine whether the runoff from covered areas at the facility has become commingled or contaminated with leachate from the facility, it is necessary for the cabinet to have the background values in upland areas unaffected by the landfill. Without background water quality data, it will be impossible to determine whether elevated metals and other constituents in the runoff from the landfill, through contact with either the cover or landfilled material, is contributing to an increase in the downstream concentration of the constituents of concern. This can be of particular importance in establishing background where the constituent is “naturally-occurring” but is believed to be present at elevated levels due to leachate. In order to allow for a meaningful determination of whether leachate has been commingled with stormwater runoff for covered areas, it is necessary to know the background values for those constituents. For this reason, background samples should be collected and reported from upgradient areas not associated with the landfill, for each constituent for which a monitoring or limitation requirement is imposed.

4. To the extent that it has not already occurred, the Division of Waste Management should be consulted concerning the presence of leachate contamination in the spring seep (Outfall 002), since such detection triggers an obligation to begin corrective action in order to eliminate the release, to the extent that it originates at the landfill.

Thank you for your attention to these comments.

Cordially,

Tom FitzGerald
Director
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