BUOHART-MORrsl, I NIC. JOHN • JUNG.P.i .P«SO€HT …

36
BUOHART-MORrsl,I NIC. CONSULTING ENGINEERS and PLANNERS xam. ^t 55 South Richland Avenue / P.O. Box M-55 / York, Pennsylvania 17405 *«n »»•«,. Telephone (717) 843-5561 °000""- •"""• Telex No. 820403 "UMUi"°""' April 9, 1987 — — - -- '*• -^ -• v JOHN JUNG.P.i .P«SO€HT Mr. Timothy F. Travers CERCLA Remedial Enforcement _ _ ^A J b Section (3HW12) US Environmental Protect Agency £PA Region III ^ 841 Chestnut Building *-•• Philadelphia, "PA "19107" " ' •" Reference: Responses to Phase I Landfill permit Application (PA) Reviews. by_ .Ecology and Environment, Inc. (for C.U.R.E.) and BCM Eastern, Inc. (for Adams County Commissioners) Keystone Sanitation Co., Inc. BH No. 62209 _._.. Dear Mr. Travers: As we discussed earlier, we have enclosed for your use copies of the review reports by Ecology and Environment, Inc. and BCM Eastern, Inc. concerning Keystone's Phase I Landfill Application and copies of our rebuttals. If you have any questions, please call. Very truly yours, BUCHARTfHORN, INC. Timothy E. Saylor Director Chemistry and Earth Sciences Division TES/llb Enclosures Offices: Subsidiary °t MCE Rtiourcftl*:. to Tl,t*ni»fai& Company H IV 1 U I »•> u J Baltimore, Maryland _ Cherry Hill, New Jersey Memphis, Tennessee Williamsburg, Virginia Charleston, West Virginia ~ ~ Lewisburg, Pennsylvania New Orleans, Louisiana York, Pennsylvania

Transcript of BUOHART-MORrsl, I NIC. JOHN • JUNG.P.i .P«SO€HT …

BUOHART-MORrsl, I NIC.CONSULTING ENGINEERS and PLANNERS xam. t

55 South Richland Avenue / P.O. Box M-55 / York, Pennsylvania 17405 *«n »»•«,.Telephone (717) 843-5561 °000""- •"""•

Telex No. 820403 "UMUi"°""'

April 9, 1987— — - -- '*• -^ -• v

JOHN • JUNG.P.i .P«SO€HT

Mr. Timothy F. TraversCERCLA Remedial Enforcement _ _ ^A J bSection (3HW12)US Environmental Protect Agency £PARegion III ^841 Chestnut Building *-••Philadelphia, "PA "19107" " ' •"

Reference: Responses to Phase I Landfill permit Application (PA)Reviews. by_ .Ecology and Environment, Inc. (for C.U.R.E.) andBCM Eastern, Inc. (for Adams County Commissioners)Keystone Sanitation Co., Inc.BH No. 62209 _ . _ . .

Dear Mr. Travers:

As we discussed earlier, we have enclosed for your use copies of thereview reports by Ecology and Environment, Inc. and BCM Eastern, Inc.concerning Keystone's Phase I Landfill Application and copies of ourrebuttals.

If you have any questions, please call.

Very truly yours,

BUCHARTfHORN, INC.

Timothy E. SaylorDirectorChemistry and Earth Sciences Division

TES/llb

Enclosures

Offices: Subsidiary °t MCE Rtiourcftl*:. to Tl,t*ni»fai& CompanyH IV 1 U I »•> u J

Baltimore, Maryland _ Cherry Hill, New Jersey Memphis, Tennessee Williamsburg, VirginiaCharleston, West Virginia ~ ~ Lewisburg, Pennsylvania New Orleans, Louisiana York, Pennsylvania

A RESPONSETO A

LETTER REPORT BY BCM EASTERN, INC.DATED FEBRUARY 13, 1987 v.

ADAMS COUNTY BOARD OF COMMISSIONERSREGARDING

REVIEW OF PERMIT APPLICATIONSUBMITTED BY KEYSTONE SANITATION CO., INC.

FOR A SOLID WASTE DISPOSAL FACILITY

INTRODUCTION

Buchart-Horn, Inc. filed a Phase I Permit Application for the Keystone

Sanitation Company's proposed solid waste disposal facility in September 1985.

In February 1987 Adams County Board of Commissioners employed BCM Eastern, Inc.

of Pittsburgh, Pennsylvania to conduct a review of that application and prepare

a report. This report has been prepared in response to the BCM report and the

questions it raised. The permit application for Keystone Sanitation Company's

proposed solid waste disposal facility has been completed in accordance with

the Pennsylvania Department of Environmental Resources, Chapter 75 Solid Waste

Management Rules and Regulations. The site characteristics were investigated

using several different methods which were used to verify and cross-check

interpretations and conclusions based upon each type of method employed. This

procedure of using several standard investigation techniques allows for a

better understanding of the site geology and hydrogeology.

OVERVIEV

BCK' s major concern was the interpretation of the hydrogeology at the site.

This included groundwater flow in the fractured bedrock. BCM did not develop

i A R 1 G 1 3 7 0

- "- ; - •.'"-• "= . - : -- - .7. - ," .. (1)the critical connection between the geology (Marburg Schist) and hydrogeology

at the site. Buchart-Horn, Inc. has been working with the Penrsylvania

Departner.t cf Envi ronrentsl "Resource? PAPER for several year? concerri-.g the

" f- ~ • r.,..Keystone site. "• '-- •• > f

Basic concepts stated in the Phase I application have been submitted over time

in report form, letters and other technical communications between Buchart-

Horn, Inc. and PADER. This lack of information on BCM's part has limited their

evaluation of a very complex hydrogeologic setting.

BACKGROUND :

Prior to the evaluation of a hydrogeologic study, a literature review of the

existing geology and hydrogeology is normally conducted. This promotes a clear

understanding of concepts and general site characteristics. The Comnonwealth

of Pennsylvania Department of Environmental Resources' Bureau of Topographic

and Geologic Survey has developed numerous Water Resource Reports concerning

groundwater resources of Southeastern Pennsylvania. Water Resources Report

Nos. 42 (1977) and 52 (1981) discuss the basic geology and hydrogeology that is

applicable to the Keystone site. These reports discuss the groundwater

characteristics such as source, recharge, movement and discharge.

The concept of groundwater flow in fractured bedrock environments can sometimes

be confusing for those who are not familiar with the physical constraints

imposed on the aquifer by the geologic structure. The geologic structure of

the Marburg Schist exhibit^ a strong influence over the groundwater flow as

noted in Water Resource Report 42 (1977), Page 45.

AD i i r' "7a I U i J /

"The direction of the strike of schistosity, bedding and majorjointing exerts considerable control on both the surface drainage andthe occurrence and movement of groundwater through the area."

PUMP TEST

A pump test conducted on the Marburg Schist illustrates this conclusion as

shown on Page A6 of the Pennsylvania Geological Survey Water Resource Report 42

(1977). The report illustrates that drawdown from the pump test in wells(2)

located along schistosity (fracturing) show considerably greater influence

then in wells located across (perpendicular) schistosity. It further describes

the presence of a northeast and southwest groundwater flow component.

Buchart-Horn, Inc. performed a pump test at the Keystone site in March 1985.

The information substantiates the background literature. The results clearly

show that a very strong northeast-southwest groundwater flow component exists

at the site. The pump test report was submitted to PADER prior to the

present Phase I application and submittal is considered established background

information for the site. The BCK report stated:

"We do not agree that the hydraulic conductivity tensor is in theNorth 60 East to South 60 West direction".

If BCM would have conducted an adequate literature review or discussed this

with Hydrogeo-logist form PADER, Maryland Department of Mental Health and

Hygiene or Buchart-Horn, Inc., they would have better analyzed the groundwater

flow direction.

A K I O I 3 7 2

(3)The BCM report failed to note the lack of a deep aquifer. The open fractures

in the bedrock are caused by the weathering process. As the fractures in the

bedrock close, the aquifer change? to a aquitard. BCM stated that:J'-' "" " '-'-'• - - . . . - " ' "\ - ^ x/v

"The data base does not support the premise that the fractures close~at shallow depths, and thus form the base of the water-tableaquifer."

GEOPHYSICS

The results of 60 vertical. electrical, sounding (VES) stations conducted over

the site clearly show the closing of the bedrock fractures. In addition to the

VES survey 20 exploratory wells were used to verify the change from a aquifer

to an aquitard. Detailed maps and cross-sections are provided in the

application and previous report.

The results of the geophysical survey indicate that the fractures close at a

shallow depth. Exploratory borings confirm this interpretation. This concept

fits into the ^geologic and hydrogeologic environment at the site.

Investigation of rock fracturing can be accomplished by several different

methods. In the Marburg Schist, electrical resistivity has been successfully

used to map the closure of fractures. BCM stated:

"The degree of rock fracturing can only be determined by evaluationof rock cores and borehole geophysics such as natural gamma ray,gamma - gamma density, spontaneous potential, single pointresistivity and neutron logs."

This is not true! The electrical resistivity method was used very effectively

to map the fracture closures. Furthermore, the report of investigation by the

State of Maryland concluded that no deep aquifer exists and the deeper rone is

extremely impermeable. These concepts are based on the actual subsurface

conditions &'. the site. The pump test performed on the Marburg Schist is an

onal method used to determine the "degree of rock fracturing".

,(

HYDROGEOLOGY

From our review of the BCM report it is apparent that BCM did not conduct a

literature review or develop a hydrogeologic and geologic conceptual model of

the Marburg Schist. Without such effort it is extremely difficult for anyone

to assess the hydrogeologic setting.

The bedrock fractures have been weathered and enlarged to permit the storage,

release and movement of groundwater. As stated in the referenced background

publication, groundwater is influenced by geologic structure and is further

explained in the Keystone permit application.

The actual hydrogeologic conditions at the site as quoted from the Phase I

permit application are as follows:

"The majority of groundwater movement is either in the North 60 Eastor South 60 West direction due to hydraulic conductivity flow tensorcreated by slaty cleavage."

"Due to fracturing, groundwater flow directions may be contrary to theprincipal direction of anisotrophy. This occurs in several locations nearthe site where fracture density in the bedrock allows the groundwater toflow in the directions of principle joint sets." (4)

A"* ! •"• } f ~1 tli i U i 0 7 k

"In an anisotropic environment, the groundwater flow direction may beparallel to a water-table contour line."

These are the actual site conditions, to ignore them is to ignore the facts of

the case. . .. . „ _ - _ - .. _ - . ._. ... ... ., . C n._ - IT-- - • "*- ^ ^.' - - ,- J J .-..- * , ^ --. - ^ . JT .._<>. :.*. l /'£••.

-" "~ " '"»", -, " _ • • _ - - - - - , . ' " _ ~__ - - ..... *•' ""^ "

The groundwater is flowing along the fracture planes associated with the

schistosity. The flow perpendicular to the fractur-ing (schistosity)

is extremely small. However, fracture openings caused by weathered joint sets

can increase the permeability in directions other than North 60 East South 60

West.

Another concept BCK apparently did not understand was that of the groundwater

flow divides. This is evident in their comment:

"In all cases groundwater flow is never parallel to & water-tablecontour line."

In extreme cases (anisotropic environments) groundwater flow may parallel the

water-table contours. This occurs when the water-table contours are parallel

to the plane of fracturing. Under these conditions where this occurs, a

groundwater flow divide is created. Such conditions exist at the site and are

illustrated in the report.

BCM stated they did not agree with groundwater flow directions shown in

Appendix B. This is understandable because BCM apparently does not understand

or appreciate the significance of fracture flow at the site.

r n 1 ••"> 1 "A n I u I

BCK was concerned that the watertable maps were not properly prepared. In

their report IvM stated:

"Also, the groundwater contours do not reflect the influences causedby topographic features and mounding effects caused by the existinglandfill." _. . .

The groundwater maps reflect the elevation of the water-table above sea level.

If topographic features or mounding conditions affect the water-table elevation

they are shovr. in the maps. Conversely if these conditions or features do not

influence the water-table then they are not illustrated in the map.

LANDFILL DESIGN

(5)BCM suggested the use of a Shelby Tube sampling for the potential for .use of

natural clay liner at the site. This is very disturbing because the site does

not have the necessary geology for a natural clay liner and the application was

not submitted for such a facility.

The transition between the soil and the bedrock is not often a clearly defined

interface, but is rather a gradual transition. The request for Shelby tube

sampling is not required either by Chapter 75 or in the design of the facility.

The soil at the site will be used for daily, intermediate and final cover. A

proper background review of the site geology and the test pit logs in the

permit application shows that the idea to design the site for a natural clay

liner is unfeasible. BCM was concerned that the exploratory test pits were

terminated at shallow depths. Test pits were terminated at shallow depths when

the soil conditions did not meet the requirements of Chapter 75 or bedrock was

7 A h l O I 3 7 6

encountered. BCM' s review did not relate the_pennit application to Chapter 75

regulations and the site geology^ When that relationship is made it will be

q u i t e .evident that the permit application meets all of the requi remersts of

Chapter 75 and the site is suitable as proposed.

WELL LOGS

BCM apparently did not analyze the exploratory well logs. BCM reported that:

"Exploratory well logs in Appendix F did not contain base linehydrogeologic data such as hydraulic conductivity, rate ofgroundwater discharge, degree of rock fracturing, rock hardness, androck brokenness. Exploratory boreholes were terminated at shallowdepth. As a result, hydrogeologic data was not available todetermine intermediate and regional groundwater flow conditions."

Exploratory well logs do not contain hydraulic conductivity date, rate of

groundwater discharge degree of rock fracturing, rock hardness or rock

brokenness. They contain basic information about the subsurface during the

boring of the well. The well logs are provided in Appendix F. The exploratory

well logs were terminated when the aquitard was encountered. The aquifer of

concern is limited to the zone above the aquitard not 200 to 300 feet below the

ground surface.

CONFIRMATION

BCM stated "Appendices K and L -_Additional data is required to confirm the

resistivity investigation."

A R I D 1377

Subsurface mapping was concluded using the earth resistivity survey. The

cross-sections in Appendix I were developed from maps developed in Appendices

J-l and K. The cross-section locations are displayed in Appendix H.

Additional data is not necessary to confirm the cross-section K and L.

Confirmation was conducted through the 20 exploratory borings. It is well

established that the deep zone is an aquitard. These concepts are also

supported by the hydrogeologic study conducted by the Maryland Department of

Mental Health snd Hygiene.

It is understandable that BCM did not properly assess the hydrogeologic setting

of the site. Their failure to conduct, because of an apparent lack of time, a

thorough background review of existing published literature has severely

limited their ability to analyze the technical information provided in the

Phase I permit application.

The request for additional work to determine site conditions shows that BCM did

not because of the time factor properly analyze the hydrogeology at the site.

Such a request is considered to be neither justified or needed to fulfill the

requirements of Chapter 75 for permitting a double-lined solid waste disposal

facility at this particular site.

A [ i! 0 1 3 7 8

FOOTNOTES

.. .(1) Marburg Schist - The only geologic bedrock formation which underlies the

site.

(2) Schistosity - Fabric or texture of the rock. In the Marburg Schist, theschistosity weathers open to form near vertical fracture planes near theground surface.

(3) Weathering Process - Physical and chemical breakdown of the bedrock. Inthe Marburg Schist, weathering is commonly limited to the upper 100 feetof the bedrock formation.

(4) Joint Set - A group of fractures in rock, generally more or less vertical.In the Marburg Schist, four separate joint sets were mapped.

(5) Shelby Tube - Technique used to collect undisturbed soil samples.

A R I U I 3 7 9

A REBUTTAL

TO

THE

ECOLOGY AND ENVIRONMENT, INC.

REPORT OK SITE SUITABILITY FINDINGS

AND RELATED HATTERS PERTAINING TO THE

SOLID WASTE PERMIT APPLICATION

OF KEYSTONE SANITATION COMPANY

UNION TOWNSHIP, PENNSYLVANIA

JANUARY 1987

PREPARED BY:

BUCHART-HORN, INC.CONSULTING ENGINEERS AND PLANNERS

55 SOUTH RICHLAND AVENUEP.O. BOX M-55

YORK, PENNSYLVANIA 17045

MARCH 1987

A R I O I 3 8 0

CONTENTS

INTRODUCTION

OVERVIEW

GEOPHYSICS

HYDR.Ar.TC5

USE OF LINER?

ADEQUACY OF SOILS

CONCLUSIONS

FOOTS;

EXHIBIT A - LIST OF LINET FACILITIES

EXHIBIT B - PADER CHAPTER Ib RULES AND REGULATIONS

flRlQ!38

Page No.

INTRODUCTION>

Buc'r.a- t-horr., In;. f i l e d a Phase 1 Perrit Application for the Keystone

Sa~ i t % t i or, f ?-pr • *• ' E proposes so*, i c waste disposal f a c i l i t y in Sep:erb-:r 1985.

In January 19i? CURL employed Ecology and Environment, Inc. (E & E) of Buffalo,

New York tc- prepare a report. The E & E report severely c r i t i c i z e d the

application. To prevent the spread of misconceptions concerning the Keystone

application this report has be^n prepared in response to the E & E Report.

The Phase I Perr.it Application has been completed in accordance with the

Pennsylvania Department of Environmental Resources (PADER), Chapter 75 Solid

Waste Manage-.ent, K-'.es and Regulations (Exhibit B). The site characteristics

were carefolly investigated using several different methods which were used to

verify and cross-check interpretations and conclusions based upon each type of

method employed. This procedure of using several standard investigation "v

techniques allows for a better understanding of the site geology and

hydrogeology.

OVERVIEW

The E & E Report has four (A) areas of concern:

1) Resistivity survey

2) Hydraulic testing

3) Use of liners

4) Soils

Geophysical techniques (electrical resistivity) were used to obtain

information to map subsurface geologic and hydrogeologic features such as

aquifers and aquitards. The geophysical interpretation has been confirmed as T

H R I O I 3 8 2

potential for wide-spread contamination under conditions of absolute failure is

very minimal fit the very worst. Even under the worst conditions, the potential

area that rojli be ixparttc is very limited.

The volume of soil required for the disposal of solid waste refuse is

approximately (1) one part of soil for (4) four parts of refuse. To understand

whether suitable soil volume is present, soil tests havj been performed in

conjunction with the various exploratory test pits. The soil tests (mechanical

separation) and test pits indicate that the soil has suitable characteristics

for its intended use. The soil at the site will be used for daily,

intermediate and final cover. To determine if adequate volumes of soil are

present at the site, a soil budget was performed. A soil budget and isopach

map have been included as part of the Phase II Application. This indicates

the quantity of soil at the site is quite sufficient.

The total environmental concept of the proposed facility clearly indicates

favorable conditions for the disposal of solid waste at the Keystone site.

GEOPHYSICS

Interpretation of the subsurface conditions at the site are based upon the

results of several different methods of investigations. Earth resistivity is a

geophysical method commonly used in hydrogeologic studies to assist in detailed

mapping of subsurface geologic and hydrogeologic units.

The interpretation of the resistivity data clearly shows that a low resistivity

zone overlies a high resistivity zone. The low resistivity zone is located in

the fractured crystalline bedrock, well below the zones of high clay content.

Beneath the aquifer is located an aquitard. This zone is high in resistivity,

A R I O I 3 8 U "

extremely icpertneable, and retards the flow of groundwater. Since the low

r e s i s t i v i t y zone readily contains and release water it is impractical to assume

t h i t jc a clcv-rich zone as suggested by E & E.

Tn<> geologv at the site is a metamorphosed crystalline bedrock and not a

sedimentary formation; one would not expect to encounter high concentrations of

clay at depf.. Exploratory borings, down-hole logging, and other background

information confirm this assumption.

Clays do occur at the site, specifically in the near-surface environment and

concentratec in low-lying drainage swales. These clay-rich zones were mapped

in d e t a i l c^-ing the geophysical survey, the test pit exploration phase as well

as in the background review of the soils mapping of the site by the U.S.

Department of Agricultural (USDA) - Soil Conservation Service (Adaos County

Soil Survey 19). The subsurface bedrock is not a clay-rich zone. This was

verified by exploratory drilling. The contrast between the aquifer (conductive

zone) and the aquitard (highly resistive zone) is the change in porosity and

permeability due to the closing of fracture apertures.

These concejis fit the geologic and hydrogeologic conditions at the site.

HYDRAULICS

Several studies clearly show that the site does not contain a deep aquifer!

This has been demonstrated by Buchart-Horn and by independent studies conducted

by the State of Maryland.

A R I O I 3 8 5

The Maryland report states that:

"There is no evidence of a deep groundvater aq u i f e r in the study

B Te B ,

The geophysical results indicate a zone that retards the flow of groundwater at

depth, i.e. ar aquitard. The State of Maryland conducted a detailed subsurface

investigatice into the "deep zone" and concluded:

"The deeper zone of bedrock is extremely impermeable and has poor

capability to transmit groundwater; therefore, since the deeper zone

is incapable of providing and/or transmitting groundwater, no deep

groundvster aquifer (a water bearing zone which produces water in

usable quantities) exists within the study area."

The geophysical interpretation of Buchart-Horn, Inc., has withstood both site \

verification through exploratory borings and an independent investigation

performed by the State of Maryland, which cost more than $222,000! The E & E

Report does not address the conditions at the site but rather creates

hypothetical situations that do not represent the site conditions.

The suggestion that there is a potential for wide-spread contamination is not

realistic. The geologic structure and the hydrogeologic units preclude the

potential for wide-spread contamination.

The potential of groundwater flow bypassing the local, surface-water streams

in the vicinity of the landfill cannot occur because of the aquitard which

limits the rertical flow of ground water. The detailed investigation by the

State of Maryland states that there is no deep aquifer. To date, no scientific

data exist which show the presence of a deep aquifer. E & E's suggestion is V

'NALonly speculation, which is unsupported by technical on-site or even off-site)

data. E & E's suggestion cannot be substantiated and is therefore considered

i n v a 1 id.

There are no requirements in the Regulations of the Commonwealth for conducting

a hydrologi: budget. Since there is no evidence to indicate a deep flow

systerr., additional testing is not recommended. Information developed

independently by the State of Maryland and Buchart-Horn, Inc., background

reviews by the Commonwealth of Pennsylvania and various other professional

corporation?, geophysical surveys, exploratory wells, down-hole logging and

hydrogeologic pump tests indicate that a deep, regional aquifer does not exist.

USE OF LINEEi

Contrary to the E & E Report, the primary synthetic liner for the site is a CPE

liner, not PVC. CPE has higher resistance to chemical penetration by volatile

organic compounds and petrochemicals than PVC. Synthetic liners have been used

successfully for many different applications including hazardous waste

facilities permitted by State and Federal regulatory agencies. (See Exhibit A

- Sites) The site is proposed for disposal of municipal solid waste only, not

hazardous waste.

By using two liners, two monitoring systems and an extensive leachate

collection system, the site will be a secure landfill. This design is

certainly sore than adequate for disposal of municipal solid waste,

incinerator ash and bypass of either Hanover or Adams County Incinerator and

the surrounding area.

ADEQUACY OF SOIL

E & E has suggested there is insufficient soil at the site. Soil requirements

at the site depend upon the needs dictated by the engineering design of the

proposed facility. To address this concern a soil budget has been calculated

and submitted in the Phase II application package. This includes an isopach

map of the soils suitable for use as cover material.

According to the laboratory tests and test pit logs from the site, the soil

appears to be more than adequate for cover material. Not all of the 200+ acres

of the site will be used for disposal of municipal waste. Consequently, there

is more than adequate soil available for the site. Only 65 acres of the 200+

acres of the site are proposed for disposal and much of the site will

effectively serve as a borrow area.

The average depth of soil is not important but rather the volume of soil

available at the site. The site has a sufficient volume of soil for the

proposed facility.

The "soil" used in the witness zone and in the leachate drainage blanket will

be of a high-quality sand rather than on-site soil. This will ensure proper

drainage of any leachate that may be generated at the site.

CONCLUSIONS

1. The use of electrical resistivity methods is a standard practice of the

industry. The technical interpretations of the data obtained from

electrical resistivity are quite sound, and represent the actual

hydrogeology at the site.

A R I O I 3 8 8

2. The Rules and Regulations of Chapter 75 do not require hydraulic testing

for the permit application. However, hydraulic characteristics of the

bedrock have been tested. The results of the testing have been confirmed

by the well installation and by ar. i n v e s t i g a t i o n conducted by the State of

Maryland.

3. The proposed liners have been tested both by the manufacturers and by-

actual use (see Exhibit A). They have been used and continue to be used in

both conventional solid waste and hazardous waste facilities permitted by

State and Federal agencies. As shown in the investigations and confirmed

in the many reviews and studies by other agencies and private consultants,

the area of negative impact under c i rcutrs tances of total failure with no

remedial response is very limited. The potential for such failure and no

remediation is nil. To impact a population of the size and extent

suggested by E & E is so remote a possibility as to border on the

impossible.

4. The soils available on site are quite adequate for the daily cover

requirements and final cover. Finely crushed weathered bedrock would also

be sufficient and could be utilized as a supplement for daily cover.

Having reviewed the E & E report it has little scientific basis and its

value it greatly reduced because it is permeated with distoration and

exaggerations. We stand by our work and its validity.

A R I O I 3 8 9

FOOTNOTES

(1) Phase I Permit A p p l i c a t i o n - P e r m i t t i n g of a srli: wastt disposal

facility in Pennsylvania occurs in two phases. Phase I is the

application to permit the site and address the technical data concerning

the geology, groundwater, soils and other physical conditions existing at

the site. Phase II is for permitting the Engineering design of the

facility including the construction schedule, leachate collection and

treatment, and the general overall plan.

(2) Electrical R e s i s t i v i t y - a standard method of investigation used to

measure the electrical resistance created by geologic layers in the

subsurface in response to an electrical current.

(3) Aquifer - a saturated geologic unit that stores and releases (allows to

flow) significant quantities of water.

(4) Aquitard - a hydrogeologic unit that retards the flow of groundwater and

does not allow significant quantities of water to flow (at this site it

allows virtually no flow).

(5) State of Maryland Waste Management Administration - Keystone Landfill

Maryland Monitoring System Investigation and Report (June 1986).

(6) Marburg Schist - a geologic bedrock unit which underlies the Keystone

Site and extends southwest into Maryland and northeast across York

County.

B R I O 1 390 -9- ,.,.lbl390

"s •*—•

(7) Aquitard - Aquifer Interface - the boundary between these two hydrogeo-

logic layers or units. Its constitutes the boundary when flows of

groundwster become restricted or nearly cease (see footnote U and 5).

(fe) Mechanical Separation - a analytical method to separate the soil

particles into specific categories of size.

(9) Soil budget - the balance of available soil cocpared to the soil required

(far daily, intermediate, and final cover at a landfill).

(10) Soil Isopach Map - a map shoving thickness of soil present at a site.

(11) Hydrologic Budget - the balance of water moving onto a specific area

(precipitation) and leaving the area (runoff, evaporation, transpiration,

groundwater recharge).

-Ah I Oi 59!

EXHIBIT A

SOLID WASTE DISPOSAL FACILITIES PRESENTLY UTILIZING SYNTHETIC LIFERS

1. Modern Landfill"- Waste Management, Inc.Double Liner - HDPE

2. Pottstovr, Landfill - Waste Management, Inc.Double Liner - HDPE ,.- ''. AL.

3. Lakeview Landfill - Waste Management, Inc. - Erie, PennsylvaniaSingle Liner - HDPE

A. G.R.O.W.S. Landfill - Waste Management, Inc. - Morrisville, PennsylvaniaHDPE, as well as, clay, asphalt

5. York County Landfill - Stewartstown, PennsylvaniaSingle Liner

6. Delaware County Landfill - Shanesville, PennsylvaniaSingle Liner - 30 mi 1 PVC

7. Creswell Landfill - Lancaster Area Refuse Authority - Lancaster andCreswell, PennsylvaniaSingle Liner

8. Lanchester Landfill - Lancaster - Chester County, PennsylvaniaSingle Liner

9. Pine Grove Landfill - Pine Grove, PennsylvaniaSingle Liner

10. Lycoming County Landfill - 20 mil PVC

11. Boyertown Landfill - Boyertown, PennsylvaniaSingle Liner - 30 mil PVC

EXHIBIT B

(e) Application for Variance Permit.Application for an official plan implementation Tirana permit thai] be made

to the Department on • form prescribed by the Departrrtcr.t and ihal] contair or beaccompanied try the foDowing information:

(I) Background data, including the foDowing.0) Location tnd permitting flatus of proposed facilities(B) Capacity tnd tbility to accept propoiti waste(ill) The time period during which the pro ostd facility1 wfl] be utilised(iv) Such further information as may be rtquirtd to insure that the

proposed transportation of waste complies with the provisions of this Chapter(0 Criteria for Variance Permit*. (

The issuance to • municipality, ooimty, or luthority of tn official planimplementation nriince permit thaD be confined to the following instances:

fl) When the facility which is part of the xnunicip&lity't P n is unable to acceptthe iDunJcipality'a waste because of pending imminent closure or other permanent inabilityto operate.

(3) For the time period specified by the municipality's approved plan requiredfor the development of the facility Which is part of the municipality's approved plan.

(g) Incomplete Applications.When the Department has found an application incomplete, the applicant shall

be notified, _., _.._(h) bsuance of Permits.

Wfcfin the Department has determined that the application is completed and theproposed transportation of municipal waste meet* the requirements of the pertinentregulations amd Acts, a permit shaH be issued.

10 Berdal, Suspension or Revocation of Permits.(1) Reasons for the denial of any permit shaD be in writing to the applicant.(2) Permits may be suspended or revoked by the Department in accordance

• with the provisions of the Act and all permits ahaD expire on that date as aet forth onthose permits,

* ' . C?) Appeals may be made in accordance with Chapter 21 , of the Administrative

Subcfcapter C. PERMITS AND STANDARDS

| 75.21. Processing and Disposal Area Permits.

(a) A permit shaH be required of any person, municipality, State Agency orauthority proposing to use or continue to use their land or any other land as a aolidwaste processing or disposal area.

fb) Permit requirements ahaD not apply to farmers for normal fanning operations,nor thai permit requirements apply to the storage of byproducts which are utilized inthe processing or manufacturing of other products unless such storage causes environmentalgradation.

(c) The Department may issue a solid waste permit which is otherwise approvableaf that permit is conditioned to exclude the disposal and/or processing of solid wastefrom fflamcipalities whose official solid waste management plan designates another facilityfor teceipt of their waste; provided, however, that disposal and/or processing of solid wasteVy a fecffity not designated for receipt of that waste by an official solid waste managementplan my be allowed to the extent and so long as the facilities designated in the officialaolid wasfie management plan for disposal and/or processing of solid waste are accordingto *ae Department's determination, unable to accept solid waste in a manner consistentwith tie roles and regulations of the Department.

(d) All facilities shaE comply with the general standards set forth in this Chapter.ft) Planning, design and operation of any solid waste processing or disposal facility

75.10-"-- : ; " " ' "" "~ A h i u i 3 9 3

or area tnchding but not limited to resources recovery syrtems, sanitary landfills, ~fa cine rat on, eomposl planU, transfer stations and solid waste salvage operations, shaH befa accordance with the standards of the Department. _

(f) Thr Department, upon its own recommendation or the rccommendatior. of the ~~Soh'd Waste Management Advisory Committee shall adopt and revise and conduct periodicreviews of soA standards as it deems necessary to prevent nuisances and pollution ofthe air, land or waters of the Commonwealth. Such standards and revisions shall ir,:lude,but not be bruited to, procedures to insure suitability of the site and the proper operationfor the tra.-.sfcr station, sanitary landfill, incinerator, corr.por! plant, solid waste savageoperation cr other solid waste processing or disposal ope re tj or..

(g) Kr person shall operate a solid waste processing or disposal lactbty area or system -^twhich is no! in compliance with the provisions of this Chapter.

(h) AT areas or solid waste management systems, including all processing and disposalfacilities, shiH be operated in such manner as to prevent health hazards and environmentaldegradation

(i) Access roads. Access roads suitable for use in aU types of weather b> loadedcollection vehicles shall be provided to the entrance of the site or facility.

(1) The minimum cartway width for two-way traffic shall be 22 feet or a singlecartway of 12 feet with pull-off intervals at no greater thar. 100 yard intervals or suchdistance what dear sight is available.

(2) For one way traffic, separate roads with a minimum cartway of 12 feetaMl be available.

(3) The maximum sustained grade shaD not exceed (12%) twelve percent.0) Weighing and measuring facilities. Provision shal be made for weighing or

measuring all solid waste delivered to the site.(k) Communications. Telephone or radio communications shall be located at the

site or readily available to the site.(1) firt protection.

(1) Necessary measures shall be taken to prevent and extinguish fires, suchmeasure shall be. at least equivalent to any local municipal fire control ordinance orregulation.

(2) Adequate equipment for minimizing fire hazards shall be available at thesite. '

(3) AH equipment and buildings shaD be equipped with functional fireextinguishers,

(m) Limited access.(1) Access to the site shaD be limited to those times when an attendant is

on duty.(2) Hours of operation and other limitations shal] be prominently displayed

on a sigr at the entrance. The sign fbafl be a minimum size of three feet by four feet.(3) A gate or barrier and fencing as approved by the Department shall be erected

to block access to the site during times when an attendant is not on duty.|4) Access by unauthorized vehicles or persons shall be prevented.

(n) Unloading.Unloading of solid wastes shall be controlled and restricted to the working face

in accordance with the approved plan.(o) Sahage.

(1) Salvaging or reclamation of materials shaD be permitted only when properlycontrolled to prevent interference with prompt sanitary disposal or processing of solidwaste, and ID such manner that no health hazard or nuisance shall be created. All salvagedmaterials shaD be removed from the site daily or stored on site in accordance with theprovisions of this Chapter.

(2) Scavenging shall be prohibited.

75.11 (»-77)

A l\ i u i 3 3 k

(p) Fertor controlVector control procedures shall be carried out when necessary to prevent health

or »uuances. The applicant thai] submit a control program for the approval ofthe Department, including, when applicable, the contractual arrangement for services withan extermhator.

(q) Accident prevention end safety.Firsl aid facilities shall, be available _ar, 3 job safety shall be practiced,

(r) Operational records and plan execution .(1) Daily operational records shaE be maintained ir. a_format approved by the

Department." "" ~~~~ '""" -—..-(2) A daDy written log which hru the types and quantities of solid waste

received abzB be maintained by the site operator.(3)" Operational plans and specifications and the daDy log entries shall be made

available to authorized Department employes during inspections of the operation todetermine compliance with pertinent rules, regulations and standards.

(4) An annual report ah all be submitted to the Department summarizing thetypes and quantities of solid waste received during the preceeding twelve month period.

(s) Setback tine.A twenty-five foot (25') rone shall be established upon which no solid waste

ghaD be deposited adjacent to perimeter property lines unless otherwise approved by theDepartment.

Q) Asphalt Material"Whenever asphaltic materials are utilized fa the construction of any solid waste

procesflif or disposal facility', those asphaltic designations shall be referenced toPennsybaaii Department_of Transportation Form 408 and Bulletin Number 25, as in effectJanuary 1, 1976, such references to be submitted by appropriate page number(s).

§ 75.21 Permit Application and Issuance.

(a) Application,Application for a permit to operate a solid waste processing or disposal facility'

or area'iball he made to the Department. The application shaH be made in two (2) stages,said stajes titkd "Phase I" and "Phase IT.

(1) Each phase shall be submitted with the necessary data and informationrequired by the Department. The data and information required shall be that data andinformation categorized on the module form which shaH be provided by the Departmentto the applicant for reporduction as required.

(b) Design.AE solid waste processing or disposal facilities and operations shall be designed

by a lejistered professional engineer bcensed as required by the Professional EngineersRegistrt&on Law, Act 367, P.L. 913 in accordance with the requirements of theDepartaent. The design plans shall bear the seal of the registered professional engineeron eact document. __

(c) Incomplete applications.When the Department has found an application incomplete, the applicant shall

be notified of the deficiencies in writing and the application shall be returned. The applicantmust supply the requested information within 90 days or such longer perird as theDepartment may specify or agree to. Failure to supply such information shaH constitute•official cause for denial of the application.

(d) Issuance of Permits.When the Department has determined that the application is completed and the

proposed design meets the requirements of the pertinent regulations and Acts, a permitaha! k issued.

75.12H i V i U i 0

(e) Persia!, suspension or revocation of permits.(1) Reasons for the denial of any permit shall be in writing to the applicant.(2) Permits may be suspended or revoked by the Department in accordance

with the proiisions of the Act.(3) In case any permit is denied, suspended or revoked, aggrieved parties may

appeal to tt: Environmental Hearing Board in accordance with the provision of Chapter21, Title 25, Rules and Regulations.

(f) fit~issuance of Permit!:(1) Permits art not transferable or assignable.(2j Change of ownership - When a changt of ownership occurs, the ne* owner

must submr. the following:(i) An application for a revised permit on a form to be provided

by the Department.GO A notarized statement attesting to the following items.

(A) Verification of possession of all approved plans, maps, documents,schedules, and commitments approved by the Department.

(B) Statement of agreement and intent to comply with aH therequirements, plans, stipulations, and commitments previously approved by theDepartmer.L

(iii) A clear and cogent narrative indicating the scheduling andprocedure to be utilized in the transfer of ownership and subsequent operational intent.

§ 75.23. Plans for Solid Waste Faculties,

(a) General requirements, Phase L(1) The applicant shall describe the general operational concept of disposal or

processini which will be submitted with the application. This concept shall include anarrative, explaining the daily operational methodology of the proposed facility, the natureof the waste by source and type of material, the expected life of the facility, the proposedultimate dispositon of the site, and the anticipated environmental effects of the facilityon the physical characteristics of the site and the adjacent properties.

(2) Adequate maps shall be submitted in the number prescribed by theDepartment and shall be drawn to the scale of one inch equals 200 feet or larger andshall contiri ten-foot contour intervals. Maps thaH be limited in physical size to no greaterthan 30" vertical height and 36" horizontal width.

(b) General requirements, Phase IL(1) Upon notification by the Department of approval of the Phase 1 portion

of the application, the applicant may proceed with Phase n, the preparation and submissionto the Department of design plans and specifications. The design plans shall include butnot be trnfted to the following data and information:

0) Design plans submitted shaH be fimited in physical size to thirtyinches (30") wrtical height and thirty-six inches (36") horizontal width; clear and kgiblereductions-*2! J>e acceptable.

(ii) Grid and/or Coordinate system for the entire site. The horizontalcontrol system shall consist of a rid not to exceed two hundred foot square sections.The grid shall be controlled and tied to a permanent physical marker or ooject locatedon site. Tfe vertical control shall be tied to an elevation established for the permanentmarker.

(iii) Such further information as may be required by the Departmentto insure that the proposed solid waste processing or disposal facility or area complieswith th: provisions of this Chapter.

75-13 r. . *«HI; 1 u

I 75.24. General Standards for Sanitary LandfUL

(i) Cr>fffp1ianfe.Sanitary landfill operations shall conform to the standards listed in this Chapter(relating to ftneraJ standards for solid waste management) and to the specific standardsfor sanitar> iuidfil} operations contained in thi Subchapter. Q

(b) Pf se I. Application Requirements (KQQ)(1) A descriptive narrative ihal be written and submitted with the apptation.(2) Information on topographic msps shaL indude as a minimum the following:

CO Borrow areas, on site or off-site . Borrow tVfl be the materialexcavated for the constructipnjDf fills, use as cover material, or other construction purposes.

(u) "_ Location of public and private water supplies, weUs, springs,Streams, iwrnps or >thcr bodies of water within one-fourth of one mDe of the proposedlandfill site property' bits.

., (3) Certain factors msy serve to limit normal sanitary UndCD operations andinformaticc pertaining to these factors on site and within one-quarter mfle of the bndfiflsite shall be included as foBows:

G) Location of underground and surface mines and maps showingthe extent of deep mine workings, elevation of the mine pool and location of mrrtr pooldischarges

(u) Location of gas and oD weUs.(Hi) Location of high-tension power line right-of-ways.(iy) Location of pipeline right-of-ways.(v) Location of geologic and hydrologk features.

(4) A soDs, geologic and groundwater report of the characteristics of the sitethsll be indnded as required by the Department This report shall be based cm a soils,geology and fcydrology investigation and on a published standard ton survey or equivalentdata and shall encompass the criteria below:

0) • A -sufficient number of excavations and borings or wells shall beprovided to determine the valid and conclusive soil, geology and groundwater conditions.Exploratory borings or wells shall be provided. These borings or wells shall be drilledten feet into the groundwater or bedrock; or in the absence of groundwater or bedrock,a distance equal to the planned depth of refuse to be deposited. A minimum of threeborings or wefts thai! be drilled ten feet into the groundwater to delineate groundwater

: flow system (j). Groundwater monitoring systems required: A minimum of onegroundwater quality monitoring point shall be established in each dominant direction ofgroundwatc movement and one monitoring point upgradient of the site. Location ofmonitoring wills shall be approved by the Department in advance of drilling. Monitoringpoints shtB not be located in excess of 500 feet of the permitted area. Monitoring points*haT1 be accessible to the applicant. Chemical analysis and hydrologic data shaft be submittedquarterly to the Department in a format provided to the applicant by the DepannentEach monitoring point shall be purged prior to obtaining the annual sample analysis.

(ii) Detailed soil descriptions shall be submitted from excavations formaterials proposed for use as,renovating soD or cover material.

^ (iii) When the Department has determined that the informationrequired under this section is rerified and complete, the applicant shall be notified inwriting that Phase I site approval is granted. This approval is granted to the applicantfor the purpose of developing the detailed design and operational plans required in Phase Dof this section.

(c) fkae H Application Design Requirements.(1) The design plans shall include details relative to:

75.14

:~ - " ' A R 1 0 1 3 9 7

0) compaction of solid waste(ii) application of daDy cover material(iiJ) elevation and grade of final cover(TV) management of lurfaot wattr ^-;r-iK'AJ(v) erosion control " /(vi) rcvtgetation procedures to be used(vii) schedule of filling(viii) aitc preparations(ix) monitoring devices(x) location and Emits of arras previously filled(xi) cross sections indicating the interface details between areas

previously fifed and areas to be filled, where applicable(xii) Emits of construction defined by grid controls(xiii) borrow areas on aite defined by frid controls(xiv) location, description, and purpose of aD easements existing on

site and a definition of all title, deed, or usage restrictions relative to the aite(XT) location of gas and oD wets on site(xvi) location of public and private water supplies on site(xvii) location of underground and surface mines on site(xviii) cross sections shown on the plans thaTI be referenced to the grid

system for korizontal location, whenever applicable(xix) grades required for proper drainage of lifts(xx) the design plans shall include a cross section of the access roads

and aE weather roads identifying construction materials, slopes, grades and distances(xxi) cross sections, grades and/or profiles of drversioE ditches,

capacities and calculations for ditch volumeixxfi) grades indicating the depth of soil available at the site for cover

material.-(xxlii) a construction schedule shall be submitted by the applicant to

the Department in a format established by the DepartmentC2) Design criteria

0) Provisions shall be made to manage surface water at the sanitarylandfill site. Calculations indicating water quantities shall be submitted to the Departmentbased oo the one-hour rainfall in inches, to be expected once in ten (10) years.

<if) The grading of the final surface of the fiD area shaH provide aslope of not less than 1.0% but not exceeding 15% except as approved by the Department.

(iii) Where final grades are approved exceeding 15%, but in no caseexceeding 33%, a horizontal terrace ten feet (10') minimum in width shall be constructedon the slope for every twenty feet (20') maximum rise in vertical elevation of the slope.The gradient of the terrace shaH be 1%.

Ov) Access roads to the entrance of the landfill shall be paved orsurfaced with such materials as asphalt, gravel or cinders and than be provided with abase capshk of withstanding anticipated load limits.

(v) An all-weather road negotiable by loaded collection vehicles shallbe provided from the entrance gate of the landfill to the unloading area, treatment facility,or lagcx>i: located on site, unless provisions are made for an alternate disposal area onsite with all-weather roads to the unloading area to be used during periods of inclementweather.

(vi) All weather roads to the unloading area shall meet thefequiremntj set forth in this Chapter relating to access roads.

(vii) AD solid waste shall be weighed on permanently installed orportable truck scales which are checked annually for accuracy or measured in a consistent -vmanner approved by the Department. M

75.15 4 /V j; (j /

(viii) Methods other than weighing for determining the quantity of solidwaste delivered to sanitary landfills or land Tills used by industrial, commercial, municipal,and agricultural establishments shall be reviewed by the Department on their merit*.

(lx) Final cover lhall be foils that faC within the United StatesDepartment ef Agriculture (USDA) Textural classes of sandy loam, loam, sandy clay loam,sDty clay tors, and silt loam. All other final cover materials must be approved by the _°(;Department The soD must compact well, not crack excessively when dry and support '-'a vegetative cover. The coarse fragment content (particles not passing the No. 10 meshsieve, 2mir..) thill not exceed 60^ by volume.

(x) Renovating toil suitable for natural rtnovation of leachates thai!be toils th£* feL within the USDA Textural classes of tandy loam, loam, fandy day loam,ailty day loan:, and ailt loam. All other renovating materials must be approved by theDepartment The coarse fragment content (fragments not passing a No. 10 mesh sieve,2in*m.) thai sot exceed 60% by volume. The combustible and/or coal content *>«TI notexceed 12* by volume-,

(xi) Soils to be used as daDy and intermediate cover material shallbe soils th£'. fall within the USDA textural classes of sandy loam, loam, sandy day loam,sflty dsy faun, loamy sand, and silt loam. AH other cover materials must be approvedby the Department. The coarse fragment content (fragments not passing the No. 10 meshsieve, 2mrr;.) shall not to exceed 75% by volume and the combustible and/or coal contentshaE not exceed 12% by volume.

(xii) Boulders and stones as classified by the USDA shall be separatedout or excluded from soils to be used for any type of cover material or renovating soils.

(xiii) Landfills constructed without linen shall have a minimum ofsix (6) feet or renovating soil between the refuse and any sidewall with a slope less thanHCf as measured from the horizontal bottom of the fill area. If sidewall slopes art 110*or greater refer to (xv) of this section. The renovating soD shall have the characteristicsas specified in this section.

(xiv) All landfills constructed without liners or leachate collectionsystems oust have a minimum of 8 feet of renovating son beneath the refuse and abovethe high gnjundwater table or bedrock for one eight foot hft If more than one liftis proposed, an additional ratio of one foot renovating aoD to each one foot of refusemust be provided. The renovating soil may be undisturbed soD or emplaced soD andmust have fbe characteristics for renovating SOD as specified in this section.

(xv) In order to maintain the one to one (1:1) ratio of renovatingsoil to refuse in sites without liners or collection systems and with ground surfaces withslopes less thar, 175* and/or sidewalls with slopes equal to or greater than 110" as measuredfrom the horizontal bottom of the fall area, the following criteria must be applied:

Tbe total depth of renovating soil at any point on the site will be measuredon a vertical plane passing through that point from the upper surface of the renovatingsoil _ _ _

For example, in a landfiH that is to be constructed in a ravine with a V-shapedcross-sectiOE the depth of renovating soil measured in a vertical plane at any point onthe site must be equal to or greater than the refuse immediately above it.

(xvi) Coal seams and coal outcrops shall be isolated from refuse depositsby eartten barriers. The arthen barriers shall be a minimum thickness of 25 feet ofnatural or compacted soils. All mine openings shall be sealed in accordance with themining laws of the Commonwealth.

(xvii) The site shall not have a flooding hazard of greater frequencythan once it 100 years and direct fill into water shall be prohibited.

(xviii) The site shaH be designed and operated in a maner which willprevent or soriimize surface water percolation into the solid waste material deposits.

75.16

A R 1 0 1 3 3 9

(xix) Sites not meeting the criteria listed herein for natural renovationfor the prevention of groundwater pollution may be utilized if kachate collection andtreatment faalities ire approved by the Department.

(xx) Individual cells of refuse thai] be placed in layers not exceedingeight feet ir, depth as measured from the working plane.

(xxi) A final layer of cover material, comparted to e minimum uniformdepth of twc feet and having the characteristics specified in (ix) of this *ection »hal]be placed om the entire surface of each portion of the final bft.

(xxii) The final cover layer shaD be completed within two weeks afterplacement of sohd waste in the final lift. Completion shaU include permanent stabilizationof all slopes,

(xxiii) Diversion ditches constructed shaU be fully dimensioned or. theplans indicating length, gradient, and cross-sectional configuration. Side slopes of distndonditches sha! not be greater than two horizontal to one vertical, 50%

(xxiv) Gas venting systems and gas monitoring systems shaE be installedat all sites. Gas venting may be accomplished by construction of either lateral and/orvertical venting. Pipe vents located within one-hundred feet (100') of any building,mechanical structure, or roadway shall be constructed so as to discharge above the rooftrie of said building or mechanical structure and a minimum of twelve feet above theroadway surface.

(xxv) The plans shaU include a schematic presentation indicating themethod(s) of filling to be utilized; Le. Trench Method, Area Method, or both incombinatior,

(xxvi) All utilities to be installed at a facility shall be shown in plan,section and profile, where applicable. The design shaD initiate at the point of serviceconnection, on-site or off-site and be shown complete to the point of usage.

(xjcvii) All fencing and barriers to be constructed at a facility shall beshown on thi plans in full elevation, fully dimensioned and type of construction materialsshaU be identified and specified.

(3) A detailed written operational plan shaU be submitted to address thestandards as specified in this Chapter.

§ 75.25. Standards for Sanitary Landffll Uners.

(a) fermeabUify.A manmade finer shaD be considered suitable for use as an impermeable barrier

when the value of permeability is 1 x ICr' cm/sec or less.(b) Resistance to leachote.

Manufactured membranes, such as Ethylene Propylene Diene Monomer (EPDM),Chlorosulfoaated Polyethylene, Polv-Ethylene (PE), PolyvinylChloride (PVC), ElasticizedPoryolefin, QOo naled-Polv-ethylene (CPE), Polychloroprene (Neoprene), Asphaltic Mesh,and Poly ko Butylene Isoprene (BotyT), shal have a manufacturer's warranty that themembrane B capable of preventing leachate'from reaching the soil under the membrane.The composition of raw leachate for finer evaluation is expected to be within the rangeof maximinc values shown in Table L

75.17 <« n i 6 I i* 0 0

Leachite CompontioDMaximum Value

pH 8.5 •Hi-*dness (carbonatt) 8120Alxilinity (carbonate) 9500Cilaum _ _ 2570Kiijnesium 410Sodjum _ _ 3800Pc:*ssium 1860Ira (tola]) 1640OJoride 2350S;2fate 1220Phosphate 130Organic Nitrogen 550Anmonia, Nitrogen . 845Conductivity 1200BOD 32400COD 50715Suspended Solids 26500Total Organic Carbon 30000

Note: Above values given in milligrams per liter except:pE (pH units)Cond activity (Micromhos per centimeter)

(c) Whenever a particular waste material, such is sludge, is proposed to be depositedin a lined anitary landfill, data shall be submitted to the Department by the applicantindicatinf the miscibflity of the membrane material relative to an undiluted exposure ofnot less than (100) one hundred hours to the particular waste.

(d) tkyricdl properties.fc order to provide the Department with a basis for evaluating the various

manufactured membranes, the applicant shall require the manufacturer to submit, at least,the foDowiag basic data, where applicable.t, Tens3; Strength m. Resistance to oxygenated solventsb. Bonption n. "Resistance to Aromatic and Halogenatec. Ter Resistance (Ibs/inch) Solvents0. OMK Resistance o. Resistance to Aliphatic (Petroleum)£. Uterjolet Resistance Solventst. Pemeability (cm/sec) p. Cold crack temperaturef. Operating temperature range q. Shrinkage (% in length and width)h. Tteacness (Inches & mils) r. Resistance to Methanej, Heai Resistance s. Any unique or limiting characteristicsj. Subfese preparation (minimum) t Weight per square feet in poundsk. Mefead of splicing & properties of u. Method of patching

spfe material t. Resistance to soil burialL Slope placement imitation in percent

All Aatta submitted as physical properties shall have the appropriate current ASTMTest Method designated.

(e) Subgrade Bearing Criteria.For aH Mner installations, the subgrade shall have a minimum bearing capacity

75.18AR i U

of one and cnc half tons per square foot (M/2 tons/sq.ft.) plus one-half of the toU3applied load in pounds per square foot. In areas where fill may be required to achievethe desired subgrade elevation, compaction shall be ninety percent (90%) of the standard ;, ,,.proctor density test. ' 3

(f) Asphalt Membranes - Field Constructed.AT asphaluc designations shall be referenced to PennDOT Forrr, 408,

fpedfications by section, .parajzraph, ind page, and further referenced to PennDOT BuDetinNumber 25 by page arid class of material The native ground, when in direct contactwith the crmbraruf iection shaB bt able to maintain a minimurn field capacity (moistureretention) cf fivt percent (5%) dry Weight of soD.

(g) Krmbnne Thickness.Ttr minimum allowable thickness for a manufactured membrane with properties

sunBar to approved Polwinyl Chloride (PVC) membranes shaB be twenty mB '(20mB)Membranes constructed of asphalt pavement material similar to PennDOT

Bituminous SurTace Course ID-2A, Wearing Course, as described in Section 420, PennDOTForm 405 Specifhaetions, shaB have a compacted thickness of not less than two inches(2"). The surface of «uch membranes shall be further sealed with an application of AC-20or PC-1 as specified ir PennDOT Bulletin Number (25) twenty-five. The seal coats shallbe applied at a quantity not less than (.6) six tenths of a gallon per square yard in twoappfc cations of approximately (.3) three tenths of a gallon per square yard each.

Asphalt membranes constructed to accomplish a stabilized base membrane shallbe constructed according to Section 330, SoQ-Bituminous Base Course, PennDOT Form408 Spedfistions. The thickness of stabilized base membranes utilizing central plantmixing aoJ placement through a paver or spreader box; or mixing and placement utilizinga motor paver shal be (3") three inches compacted. The thickness of stabilized basemembrane utihzin* mix in place methods such as windrowing shaB be (12") twelve inches.Stabilized base membranes shaB be sealed in the same manner as asphalt pavementmembranes.

Asphalt materials utilized to construct stabilized base membranes than be limitedto water-asphalt entuisions, PennDOT designations E-5 or E-6 as specified in PennDOT'BuBetin Hnnber 25

Asphalt membranes constructed by spraying asphaltic material shaB beconstructed according to the applicable provisions of PennDOT Form 408 Specifications.Prior to fc: placement of any asphaltic material the fubgrade shaB be constructedconformin to the grades and cross sections shown on the design plans. The fubgradeyfrafl be considered as that portion of the. work which has been prepared as specifiedherein and upon which a layer of specified asphaltic material is to be placed. The finishedsubgrade sLsJl be true to cross -section, hard, uniform, smooth, free of aB debris, weedsor other foreign material, ind whei, -tested shaD attain a relative density of at least ninetypercent (90) as measured by the standard proctor density test. The finished subgradeshaB be aibHized when an application of MC-30, or an application of MC-70 when theslope does not exceed fifteen percent (15%), as specified in PennDOT BuBetin Number(25); the application to be applied at a quantity not less than 030 gaBons per squareyard as |feced by an approved pressure distributor. The subgrade shaB be further sealedwith an application of AC-20, PC-1, or RC-800, RC-250 where the slope does not exceedfifteen percent (15%), at a quantity not less than 0.75 gaBons per tquare yard. Theseal cost shaB be placed in two applications utilizing a distributor truck equipped withan offset spray bar with an allowable variation not to exceed 0.05 gallons per squareyard fror the specified rate of application.

(h) Subgrade for Monitoring Liners.The subgrade for monitoring purposes shaB consist of a fine graded subbase

with a tetht inch (12") base course. The base course shaB be of sandy material notless the 70% by weight of sand between 2mm and .05mm in size and not more than

75.19 (•--77)

by weight of day less than jD02mm fa size to create • flow cone for monitoringpurposes. A tub-drain system consisting of four inch (4*) drainage pipe than be instilledin the bax course perpendicular to the direction of liquid flow at a spacing pattern ofnot snore than one-hundred and seventy-five feet (175*) on center. To protect the integrityof the Co* tone and to insure a permeability contrast between the twelve inch baseCOUTS? ani ttf fine graded native soD subbase, an application of MC-30, as specified byPtnnDOT Bulletin Number twenty-five, shaD be applied to the fine graded native soilfubbast i' tz application rtte of not less than one-quarter (.25) of a gallon per squareyard. Wbrt the native soil subbase has i permeability of lee than 1 X 10^ cm/re.,thr MC-3C AiL nol be rtquired.

CD fwective Cover.Tk protective cover for aH sanitary landfill membranes shall consist of six inches

(£*) of selected clean earth material and at least eight inches (8") of clean earth materialfor a tot*: earthen coyer of not less than fourteen inches (14"). The six inch (6") selecteddean eartt aaterial shaTJ be placed directly upon the membrane and wiD be selected sothat DO agrcptc, rocks or solid material which is larger than two inches (2*) in greatestdimension *iD be placed in this tone. The initial lift of refuse placed upon the fourteeninch (14") protective cover shall consist of two feet (21) of selected refuse; selected refusebeing that refuse which does not contain bulky- waste or items where the greatest dimension• larger then three feet (31),

(j) Slopes,7k minimum subgrade for aH sanitary landfill liners shaU be one percent (1%).

The KiixJEum slope for aH sanitary land ED liners shall be twenty percent (20%). Themaxim un. side slope for manufactured membranes shaU be thirty-three percent (33%) orthe manufacturers recommendation, whichever is the lesser. The maximum side slopefor isphaltic membranes ahaU be twenty-five percent (25%).

fk) Im&ale Collection for Man-made Liners.UK applicant shaU submit to the Department full and complete calculations

based oc Bftural precipitation indicating the amount of leachate generation anticipatedannually tier the operational Hfespan of the site and a period of ten yean followingclosure »f (he site. Natural precipitation shall be calculated on the basis of the past25 year image for the nearest recording station of record. The leachate collection systemabal be iartaSed and operable in order to collect and retain tke calculated volume ofkachate expected during the initial first year operational increment.

(1) A drainage system for the channelization and collection of leachate may beinstalled fc proximity to the protective cover. The drainage systsm, whether collectionpiping, freach drain, or other type's, shall not penetrate a distance in excess of ten inches(10") into the protective cover.

(E) Ceftection ditches installed at the extremities of the sanitary bndfiE finer shaUbe constructed with an impermeable wetted perimeter. The collection ditches shall besized to accommodate the maximum anticipated rolume of leachate flow with a factorof safety sot less than twenty-five percent (25%).

&) AE ditches and drainage facilities shall be shown on the design plans indicatinggradient, elevations, and fully dimensioned cross sections.

(c) Additional design criteria for leachate collection facilities shall be as follows:(1) The area designed for filling shaU not exceed 70% of the hydraulic loading

capacity cf the treatment facility.(2) After five years of operation, the applicant shaU revise and itsubmit the

plans tat design of the collection system as required by existing conditions and criteria.C3) A metering device to record the daily flow of leachate in gallons per minute

from a completed lined increment shaD be installed at the orifice of that increment. Anaccurate secord of the measured flow shall be maintained by the operator and submittedto the Department on a quarterly basis.

(Red)75.20 .

(4) Where t lined landfill is proposed, the aggregate amount of liquid storageto be provided thai! be 100% of the precipitation and induced liquid applied to theoperational lined increment in one year. An operational subsection of the lined area shallhave a minimum two lifts of refuse in place prior to proceeding to an additional subsection.The aggregate volume of required liquid storage shall provide an allowance not to exceed25 gallons pr cubic yard of liquid capacity.

(5) When a lined increment of a site is completed, final covered, properly gradedar.d vegetate-d. a total maximum allowance of seventy percent (70%) of natural precipitationshall be cornered runoff.

(6) Natural systems may be utilized to collect kachate from hndfUU. Themethods to utilize the natural systems may be the manipulation of the groundwater flowsystem(s) or wturaDy occurring impermeable rones.

(i) Where collection and treatment is proposed to manipulate orutilize natural troundwater flow system(s), the applicant shall submit design data, plans,tnd specifications for the approval of the Department

(ii) Detail analysis of the groundwater flow systems most besubmitted and include as a minimum, groundwater table maps, piezometrie surface maps,hydraulic gradients, nydrologic connections, flow directions, flow regimes analysis,transmissvit), and permeability data.

(iii) Where naturally occurring impermeable zones are to be utilized,the minirauz: site requirements that must be met are:

(A) Zones with a uniform thickness of greater than two feet (2*) musthave a permeability of less than 1x10*' on/sec.

(B) Zone with a uniform thickness of greater than four feet (4*) andan upward gnoundwater gradient into the zone may be approved with a maximumpermeability ef less than 1 x 10"' cm/sec.

(7) Documentation insuring the proper treatment and disposal of all kachateooDected wi §e provided to the Department by the applicant. Said documentation mayinclude a contractual agreement with the operators of a treatment facility off-she anda contractual arrangement for the transporting of kachate to said site.

(8) Water Tabk . •Whenever the distance between the high water table and the MC-30

monitoring Sow plane is less than four feet, a groundwater drainage system consistingof drain tik, piping, french drains, intercepts, or other conventional sub-drainagemechanisms stall be installed to maintain a four foot isolation distance between the MC-30and the groondwater table.

§ 75.26. Operating Standards for Sanitary Landfills,

(a) Eq^pment provided for operation of the sanitary landfill shaH be in operablecondition, adequate in size and performance capability to continuously conduct the landfillin accordant with these standards.

(b) AI solid waste shaD be spread and compacted in shallow layers, not exceedinga depth of t»o feet. Compacting of the solid waste shaD be accomplished by repeatedpassages of landfill equipment

(c) Stndby equipment shaD be on-site or readily available to provide for majorequipment ktakdown.

(d) Unlading areas shaD be specified and restricted to the proximity of the workingface and thai permit collection vehicles to unload promptly.

(e) At attendant shaD direct vehicles to the unloading area or clearly marked signsshall be located prominently to the unloading area.

(0 luaang of solid waste is prohibited at the aanitary landfffl.(g) fcowBons shaD be made to prevent dust from hampering landfill operations or

from causaf health or safety hazards and nuisances.

75.21 C.-7?)A r I i C i i, 0 k

(h) To control dust and mud problems, one or more of the foDowing measure*shall be implemented:

(1) Paving of access roads and roads leading to the unloading area.(2) Application of moisture absorbing chemicals such as calcium chloride to

roadways.(3) Application of oD to the roadways.(4) Spraying water, as needed, on roadways.

(j) The size of the working face shall be confined to ar, are* no greater thar, canbe easily compacted and covered daDy with available equipment.

0) Portable fencing constructed of wire mesh, snow-fencing or other suitablematerial shaD be used to control blowing litter.

(k) Litter control fences ihaD be located in the immediate operating area,approximately 50 to 75 feet downwind from the working face. The nature of the solidwaste or excessive winds may require additional litter control measures which shaU beprovided. The entire landfill shaD be adequately policed and litter shall be collectedroutinely at no greater than weekly intervals from fences, roadways and tree line barriersas incorporated into the solid waste cells.

(1) A uniform six inch compacted layer of daily cover material shaU be placed onaD exposed solid waste at the end of each working day.

(m) DaDy cover material shaU have the characteristics as specified in this Chapter(relating to daily cover materiaJ characteristics).

(n) A layer of intermediate cover material, compacted to s minimum uniform depthof one foot and having the characteristics specified in this Chapter (relating to covermaterial characteristics) shaU be placed on completed lifts in areas where there is clearintention to place _another Eft on top within one year. When additional waste is notdeposited within one year additional cover and revegetations shall be provided as requiredfor final cover. --

(o) Completed portions of the landfill shall be graded as specified in this Chapter(relating to drainage of surface water) within two weeks pf completion.

(p) Seed bed preparation and planting operations to promote stabilization of thefinal soil cover shaD be done as soon as weather permits and seasonal conditions are suitablefor the establishment of the type of vegetation to be used. Reseeding and maintenanceof cover material shall be mandatory until adequate vegetative cover is established toprevent erosion. Revegetation procedures as published in PennDOT Form 408 or the current"Agronomy Guide" of The College of Agriculture, Pennsylvania State University, maybe utilized.

(q) To assure mat proper construction of the landfill is carried out according tooperational plans and to provide for the most efficient utilization of the completed site,daily operational records shall be maintained.

-* (r) The disposal of solid waste shaD be prohibited in areas where continuous orintermittent contact occurs between solid waste and the ground water table.

(s) The disposal of sewage liquids and solids, liquids and hazardous waste in asanitary landfill shall be prohibited until the methods of disposal, suitability of the siteand plan of operation have been reviewed and approved by the Department.

• -- -••--*.-:--•- ------- ,--••••-.. '- - - ORIGINAL8 75.27. General Standards for Solid Waste Transfer Stations. (Red)

(a) Solid waste transfer stations shaD conform to the requirements listed in thisChapter (relating to general provision for solid waste management) and to the specificstandards for solid waste transfer stations contained in this Subchapter.

(b) Location of the transfer station site shaD be adjacent to access roads whichare paved or surfaced with such materials as asphalt, gravel or cinders and which areprovided with a base capable of withstanding anticipated load limits.

(c) An all-weather road negotiable by loaded collection vehicles shaD be provided

-•'- "* - 75.22 / («-77)