ettl engineers & consultants inc. - geotechnical, environmental

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ETTL Engineers & Consultants Inc. GEOTECHNICAL MATERIALS ENVIRONMENTAL DRILLING LANDFILLS 210 Beech Street 1717 East Erwin 707 West Cotton Street Texarkana, Arkansas 71854 Tyler, Texas 75702 Longview, Texas 75604-5505 870-772-0013 Phone 903-595-4421 Phone 903-758-0915 Phone 870-216-2413 Fax 903-595-6113 Fax 903-758-8245 Fax www.ettlinc.com May 3, 2012 Tyler, Texas Mrs. Christine M. Bergren Texas Commission on Environmental Quality Manager, Municipal Solid Waste Permits Section Waste Permits Division, MC-124 P.O. Box 13087 Austin, Texas 78711-3087 Re: IESI East Texas Regional Landfill – Rusk County Municipal Solid Waste (MSW) – Permit No. 1249B RN 102379815/ CN 601668486 Landfill Gas Management Plan Modification Application Incident Specific Remediation Plan Dear Mrs. Bergren: ETTL Engineers & Consultants Inc. (ETTL) is providing the following Incident Specific Remediation Plan as a permit modification to the designated facilities Landfill Gas Management Plan (LGMP) on behalf of IESI TX Landfill LP. The modification is required due to a verified methane exceedance detected within landfill gas probe M2. The initial exceedance was detected during scheduled quarterly landfill gas monitoring on December 14, 2011. In accordance with the LGMP, the facility conducted a limited subsurface investigation on January 23, 2012. Landfill gas extraction trenches were scheduled for installation during the week of February 7, 2012; however, during construction solid waste was encountered between three (3) and ten (10) feet below ground surface in the area. A request for an alternate schedule to demonstrate compliance was granted by the TCEQ on March 7, 2012, allowing an additional 60 days to provide an Incident Specific Remediation Plan as a permit modification with public notice. This permit modification application is prepared to provide an Incident Specific Remediation Plan as described within the facilities’ Landfill Gas Management Plan and TCEQ correspondence. The Incident Specific Remediation Plan is identified as Appendix G3 within the facilities approved Landfill Gas Management Plan.

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Page 1: ETTL Engineers & Consultants Inc. - Geotechnical, Environmental

ETTL Engineers & Consultants Inc.

GEOTECHNICAL MATERIALS ENVIRONMENTAL DRILLING LANDFILLS

210 Beech Street 1717 East Erwin 707 West Cotton Street Texarkana, Arkansas 71854 Tyler, Texas 75702 Longview, Texas 75604-5505 870-772-0013 Phone 903-595-4421 Phone 903-758-0915 Phone 870-216-2413 Fax 903-595-6113 Fax 903-758-8245 Fax w w w . e t t l i n c . c o m

May 3, 2012 Tyler, Texas

Mrs. Christine M. Bergren Texas Commission on Environmental Quality Manager, Municipal Solid Waste Permits Section Waste Permits Division, MC-124 P.O. Box 13087 Austin, Texas 78711-3087 Re: IESI East Texas Regional Landfill – Rusk County Municipal Solid Waste (MSW) – Permit No. 1249B RN 102379815/ CN 601668486 Landfill Gas Management Plan Modification Application Incident Specific Remediation Plan Dear Mrs. Bergren: ETTL Engineers & Consultants Inc. (ETTL) is providing the following Incident Specific Remediation Plan as a permit modification to the designated facilities Landfill Gas Management Plan (LGMP) on behalf of IESI TX Landfill LP. The modification is required due to a verified methane exceedance detected within landfill gas probe M2. The initial exceedance was detected during scheduled quarterly landfill gas monitoring on December 14, 2011. In accordance with the LGMP, the facility conducted a limited subsurface investigation on January 23, 2012. Landfill gas extraction trenches were scheduled for installation during the week of February 7, 2012; however, during construction solid waste was encountered between three (3) and ten (10) feet below ground surface in the area. A request for an alternate schedule to demonstrate compliance was granted by the TCEQ on March 7, 2012, allowing an additional 60 days to provide an Incident Specific Remediation Plan as a permit modification with public notice. This permit modification application is prepared to provide an Incident Specific Remediation Plan as described within the facilities’ Landfill Gas Management Plan and TCEQ correspondence. The Incident Specific Remediation Plan is identified as Appendix G3 within the facilities approved Landfill Gas Management Plan.

Page 2: ETTL Engineers & Consultants Inc. - Geotechnical, Environmental

ETTL Engineers & Consultants Inc. 1717 E. Erwin Tyler, Texas 75702 903-595-4421 Phone

Page 2 of 2

Specific changes to the Landfill Gas Management Plan include the following:

(1) Incident Specific Remediation Plan integrated into the original Landfill Gas Management Plan as Appendix G3.

(2) A description of investigation and remediation activities;

(3) Removal of an existing passive landfill gas trench system in order to remove solid

waste materials from the area;

(4) Removal of solid waste within the vicinity of landfill gas probe M2 and groundwater monitoring well MW-12;

(5) Backfill of compacted clayey soils within the excavation area; and,

(6) Monthly monitoring of landfill gas probe M2 for six (6) months unless two (2)

consecutive monthly monitoring events show methane levels below five (5) percent. In which case monitoring will revert to the normal quarterly schedule.

One (1) original and two (2) copies of the application, including the Part 1 (TCEQ-0650) Form, a redline version showing changes to the original LGMP, and a final version of the LGMP are included in this submittal. A property landownership map depicted landowners within 0.25 miles of the facility, a cross-referenced list of landowners, an electronic (CD) copy of the landowner list, as well as application fee documentation are also attached. Sincerely, ETTL ENGINEERS & CONSULTANTS INC. C. Brandon Quinn, P.E., P.G. Vice President Manager of Engineering Services

Page 3: ETTL Engineers & Consultants Inc. - Geotechnical, Environmental

Permit Modification Application Form 0650-Part 1

Page 4: ETTL Engineers & Consultants Inc. - Geotechnical, Environmental
Page 5: ETTL Engineers & Consultants Inc. - Geotechnical, Environmental

IESI East Texas Regional Landfill Affected Land Owners List

Page 6: ETTL Engineers & Consultants Inc. - Geotechnical, Environmental

IESI East Texas Regional Landfill-Landfill Gas Management Plan Modification May 3, 2012

Affected Land Owners List (See attached ¼ mile radius map)

(From current Rusk County Appraisal District records) 1. James Kangerga 2009 Trust 7. Donnie Anthony & James Michael Kangerga, Trustee 611 Florey St. 2. 704 Pine Street Kilgore, TX 75662 Henderson, TX 75654 8. Bill King Estate Rade Russell Kangerga c/o Jessie Hill, et al. 102 E. Main Street 117 Lewis St. Henderson, TX 75652-3184 Henderson, TX 75652-6803 John Kangerga 102 E. Main Street 9. Wilkerson Family Trust Henderson, TX 75652-3184 & Melba Jo Wilkerson,Trustee 10. Melba Wilkerson Spikes Kangerga 11 Woodhaven Circle 102 E. Main Street Henderson, TX 75654 Henderson, TX 75652-3184 3. Will Sanders Estate 11. IESI TX Landfill, LP c/o Armestella Anthony Attention: Thomas J. Fowler, 5063 FM 2867 E General Counsel Henderson, TX 75654-2333 2301 Eagle Parkway, Ste. 200 Fort Worth, TX 76177-2326 4. Clifford G. Starcher Estate and Linda 11A. IESI TX Corp. 4953 FM 2867 E 2301 Eagle Parkway, Ste. 200 Henderson, TX 75654-2331 Fort Worth, TX 76177-2326 5. Will Sanders Estate 12. Barbara Simmons c/o Arma Burnett 5469 FM 2867 E 5057 FM 2867 E Henderson, TX 75654-2419 Henderson, TX 75654-2333 13. Gary N. & Janie C. Pointer 6. Shiloh Reese CME Church 5497 FM 2867 E c/o Estell Reese Henderson, TX 75654-2419 422 E. Ragley St. Henderson, Tx 75654-3235

Page 7: ETTL Engineers & Consultants Inc. - Geotechnical, Environmental

IESI East Texas Regional Landfill

Land Owners List (continued)

(From current Rusk County Appraisal District records) 14. Michael Wilhite 22. Joshua Lee P.O. Box 1810 5652 FM 2867 E Henderson, TX 75653-1810 Henderson, TX 75652 15. Patsy Earline Jones 23. Mason William Schmidt, Jr. & 1302 CR 342 S 5539 FM 2867 E 16. Henderson, TX 75654 Henderson, TX 75654-2421

17. Cecil R. & Clara V. West 24. Haskell E. Gossett 2167 CR 304 S 150 Hillside Dr. Henderson, TX 75654-2348 Liberty, TX 77575-3306 18. Christopher Lynn Hale 25. Brenda Kay Harrison P.O. Box 26 6607 Taylor Way Henderson, TX 75653-0026 Spring, TX 77389-2924 19. Doris Artelia Reese Life Estate 26. FM 2867 Right of Way 20341 CR 482 TxDOT Tyler District Lindale, TX 75771-3711 2709 W. Front St. Tyler, TX 75702 20. Donald & Ettie Copeland 27. CR 355 Right of Way 5788 FM 2867 E Rusk County Henderson, TX 75652 P.O. Box 758 Henderson, TX 75652-0758 21. Chris Alan Roberts 5580 FM 2867 E Henderson, TX 75654-2420 Rusk County Appraisal District records do not include mineral interest ownership or facility easement information.

Page 8: ETTL Engineers & Consultants Inc. - Geotechnical, Environmental

Affected Landowner Map

Page 9: ETTL Engineers & Consultants Inc. - Geotechnical, Environmental
Page 10: ETTL Engineers & Consultants Inc. - Geotechnical, Environmental

Redline Version

Page 11: ETTL Engineers & Consultants Inc. - Geotechnical, Environmental

IESI EAST TEXAS REGIONAL LANDFILL RUSK COUNTY, TEXAS

TCEQ PERMIT NO. MSW 1249B

PERMIT AMENDMENT APPLICATION

PART III - FACILITY INVESTIGATION AND DESIGN ATTACHMENT G

LANDFILL GAS MANAGEMENT PLAN

Prepared for

IESI TX Landfill LP

Technically Complete October 22, 2009

Prepared by

BIGGS & MATHEWS ENVIRONMENTAL 1700 Robert Road, Suite 100 Mansfield, Texas 76063 817-563-1144

TEXAS BOARD OF PROFESSIONAL ENGINEERS FIRM REGISTRATION NO. F-256

TEXAS BOARD OF PROFESSIONAL GEOSCIENTISTS FIRM REGISTRATION NO. 50222

May 3, 2012

Revisions Prepared by

ETTL Engineers and Consultants Inc. 1717 East Erwin

Tyler, Texas 75702 903-595-4421 Phone

903-595-6113 Fax

Page 12: ETTL Engineers & Consultants Inc. - Geotechnical, Environmental
Page 13: ETTL Engineers & Consultants Inc. - Geotechnical, Environmental
Page 14: ETTL Engineers & Consultants Inc. - Geotechnical, Environmental

ETTL Engineers and Consultants Inc. Revised 5/3/2012

G3 INCIDENT SPECIFIC REMEDIATION PLAN 30 TAC §330.371(c)3

G3.1 Purpose and Background

This incident specific remediation plan is prepared in response to verified methane concentrations exceeding five (5) percent within landfill gas probe M2. The initial methane exceedance was detected during quarterly landfill gas monitoring in December 2011. Landfill gas probe M2 is located approximately 65 feet south of a closed (Pre-Subtitle D) landfill and approximately 50 feet north of Cell #1 within the active Subtitle D landfill. G3.2 Assessment and Remediation Activities In response to the verified methane exceedance, the facility has implemented the following assessment and remediation activities:

• Increased monitoring activities within landfill gas probe M2 and nearby passive gas vent system to a bi-monthly frequency;

• Installation of two (2) turbines to the existing passive gas vent system

risers in order to increase vacuum within the vent system;

• A single pumping event of the passive gas vent system to remove accumulated water within the trench; and,

• A limited shallow subsurface investigation in the vicinity of landfill gas

probe M2 in order to attempt to determine the potential source of the landfill gas. The investigation included advancing ten (10) boreholes via hand auger to various depths in the vicinity of landfill gas probe M2,

Based upon the results of the shallow subsurface investigation, installation of additional landfill gas extraction trenches was scheduled. However, solid waste was encountered between 3 to 10 feet below ground surface in the vicinity of landfill gas probe M2. Waste encountered appears to be municipal waste from the closed (Pre-Subtitle D) landfill located north of landfill gas probe M2. This waste is expected to be the source of methane within landfill gas probe M2.

Page 15: ETTL Engineers & Consultants Inc. - Geotechnical, Environmental

ETTL Engineers and Consultants Inc. Revised 5/3/2012

G3.3 Additional Remediation Activities The facility will remove any waste encountered within approximately 15 feet of landfill gas probe M2 and a groundwater monitoring well (MW-12) located in close proximity to M2. The excavation of waste will also require the removal of the passive landfill gas extraction system currently located in the vicinity of landfill gas probe M2. Landfill gas probe M2 and groundwater monitoring well (MW-12), will not be removed during excavation activities. Caution will be utilized during excavation and backfill activities to prevent damage to the landfill gas probe and groundwater monitoring well. During excavation activities, several test pits may be utilized to verify the deepest layer of waste within the area has been removed. Excavated waste will be disposed within the active working face of the Subtitle D landfill in accordance with the facility Site Operating Plan. Stockpiling of waste is not anticipated; however, if necessary, excavated waste will only be stockpiled within lined areas of the active landfill. The excavation area will be covered overnight and during periods of inactivity due to inclement weather. Upon completion of excavation activities, clayey soils (CL, CH or SC) will be placed within the excavation area and compacted. Clayey soils will be backfilled in thin lifts and compacted. An approximate five (5) foot wide portion of the backfill, located along the northern extent of the excavated area, will be compacted according to constructed soil liner standards in order to form a poorly permeable wall between the closed Pre-Subtitle D fill area and the landfill gas probe. The remediation activities are scheduled to begin on May 7, 2012 with an expected completion date of May 21, 2012 dependent on weather conditions. G3.4 Post Completion Activities Following completion of the remediation activities, monitoring of landfill gas probe M2 will be conducted on a monthly basis for at least six (6) months. However, if methane levels below five (5) percent are recorded during two (2) consecutive monthly monitoring events, monitoring frequency will return to the normal quarterly schedule. In addition, a report detailing remediation activities will be provided to the TCEQ upon completion of remediation activities. If after six (6) months of monitoring are conducted and methane levels remain above five (5) percent; additional remediation activities will be implemented which may include installation of addition passive landfill gas vent systems, additional compacted clay wall structures or removing additional waste.

Page 16: ETTL Engineers & Consultants Inc. - Geotechnical, Environmental
Page 17: ETTL Engineers & Consultants Inc. - Geotechnical, Environmental

Submittal Version

Page 18: ETTL Engineers & Consultants Inc. - Geotechnical, Environmental

IESI EAST TEXAS REGIONAL LANDFILL RUSK COUNTY, TEXAS

TCEQ PERMIT NO. MSW 1249B

PERMIT AMENDMENT APPLICATION

PART III - FACILITY INVESTIGATION AND DESIGN ATTACHMENT G

LANDFILL GAS MANAGEMENT PLAN

Prepared for

IESI TX Landfill LP

Technically Complete October 22, 2009

Prepared by

BIGGS & MATHEWS ENVIRONMENTAL 1700 Robert Road, Suite 100 Mansfield, Texas 76063 817-563-1144

TEXAS BOARD OF PROFESSIONAL ENGINEERS FIRM REGISTRATION NO. F-256

TEXAS BOARD OF PROFESSIONAL GEOSCIENTISTS FIRM REGISTRATION NO. 50222

May 3, 2012

Revisions Prepared by

ETTL Engineers and Consultants Inc. 1717 East Erwin

Tyler, Texas 75702 903-595-4421 Phone

903-595-6113 Fax

Page 19: ETTL Engineers & Consultants Inc. - Geotechnical, Environmental
Page 20: ETTL Engineers & Consultants Inc. - Geotechnical, Environmental
Page 21: ETTL Engineers & Consultants Inc. - Geotechnical, Environmental

ETTL Engineers and Consultants Inc. Revised 5/3/2012

G3 INCIDENT SPECIFIC REMEDIATION PLAN 30 TAC §330.371(c)3

G3.1 Purpose and Background

This incident specific remediation plan is prepared in response to verified methane concentrations exceeding five (5) percent within landfill gas probe M2. The initial methane exceedance was detected during quarterly landfill gas monitoring in December 2011. Landfill gas probe M2 is located approximately 65 feet south of a closed (Pre-Subtitle D) landfill and approximately 50 feet north of Cell #1 within the active Subtitle D landfill. G3.2 Assessment and Remediation Activities In response to the verified methane exceedance, the facility has implemented the following assessment and remediation activities:

• Increased monitoring activities within landfill gas probe M2 and nearby passive gas vent system to a bi-monthly frequency;

• Installation of two (2) turbines to the existing passive gas vent system

risers in order to increase vacuum within the vent system;

• A single pumping event of the passive gas vent system to remove accumulated water within the trench; and,

• A limited shallow subsurface investigation in the vicinity of landfill gas

probe M2 in order to attempt to determine the potential source of the landfill gas. The investigation included advancing ten (10) boreholes via hand auger to various depths in the vicinity of landfill gas probe M2,

Based upon the results of the shallow subsurface investigation, installation of additional landfill gas extraction trenches was scheduled. However, solid waste was encountered between 3 to 10 feet below ground surface in the vicinity of landfill gas probe M2. Waste encountered appears to be municipal waste from the closed (Pre-Subtitle D) landfill located north of landfill gas probe M2. This waste is expected to be the source of methane within landfill gas probe M2.

Page 22: ETTL Engineers & Consultants Inc. - Geotechnical, Environmental

ETTL Engineers and Consultants Inc. Revised 5/3/2012

G3.3 Additional Remediation Activities The facility will remove any waste encountered within approximately 15 feet of landfill gas probe M2 and a groundwater monitoring well (MW-12) located in close proximity to M2. The excavation of waste will also require the removal of the passive landfill gas extraction system currently located in the vicinity of landfill gas probe M2. Landfill gas probe M2 and groundwater monitoring well (MW-12), will not be removed during excavation activities. Caution will be utilized during excavation and backfill activities to prevent damage to the landfill gas probe and groundwater monitoring well. During excavation activities, several test pits may be utilized to verify the deepest layer of waste within the area has been removed. Excavated waste will be disposed within the active working face of the Subtitle D landfill in accordance with the facility Site Operating Plan. Stockpiling of waste is not anticipated; however, if necessary, excavated waste will only be stockpiled within lined areas of the active landfill. The excavation area will be covered overnight and during periods of inactivity due to inclement weather. Upon completion of excavation activities, clayey soils (CL, CH or SC) will be placed within the excavation area and compacted. Clayey soils will be backfilled in thin lifts and compacted. An approximate five (5) foot wide portion of the backfill, located along the northern extent of the excavated area, will be compacted according to constructed soil liner standards in order to form a poorly permeable wall between the closed Pre-Subtitle D fill area and the landfill gas probe. The remediation activities are scheduled to begin on May 7, 2012 with an expected completion date of May 21, 2012 dependent on weather conditions. G3.4 Post Completion Activities Following completion of the remediation activities, monitoring of landfill gas probe M2 will be conducted on a monthly basis for at least six (6) months. However, if methane levels below five (5) percent are recorded during two (2) consecutive monthly monitoring events, monitoring frequency will return to the normal quarterly schedule. In addition, a report detailing remediation activities will be provided to the TCEQ upon completion of remediation activities. If after six (6) months of monitoring are conducted and methane levels remain above five (5) percent; additional remediation activities will be implemented which may include installation of addition passive landfill gas vent systems, additional compacted clay wall structures or removing additional waste.

Page 23: ETTL Engineers & Consultants Inc. - Geotechnical, Environmental
Page 24: ETTL Engineers & Consultants Inc. - Geotechnical, Environmental

Application Fee Documentation

Page 25: ETTL Engineers & Consultants Inc. - Geotechnical, Environmental

ETTL Engineers & Consultants Inc.

GEOTECHNICAL MATERIALS ENVIRONMENTAL DRILLING LANDFILLS

210 Beech Street 1717 East Erwin 707 West Cotton Street Texarkana, Arkansas 71854 Tyler, Texas 75702 Longview, Texas 75604-5505 870-772-0013 Phone 903-595-4421 Phone 903-758-0915 Phone 870-216-2413 Fax 903-595-6113 Fax 903-758-8245 Fax w w w . e t t l i n c . c o m

May 3, 2012 Tyler, Texas

Texas Commission on Environmental Quality Financial Administration Division, MC 214 P.O. Box 13087 Austin, Texas 78711-3087 Re: IESI East Texas Regional Landfill – Rusk County Municipal Solid Waste (MSW) – Permit No. 1249B RN 102379815/ CN 601668486 Landfill Gas Management Plan Modification Application Fee Incident Specific Remediation Plan To Whom It May Concern: Please find the attached Permit Modification Application Fee for the above referenced facility. Please feel free to contact me if you have any questions. Sincerely, ETTL Engineers and Consultants Inc.

Daniel Richbourg Project Manager

Page 26: ETTL Engineers & Consultants Inc. - Geotechnical, Environmental