Custodial care beyond the minimum 30-year post-closure period – Are you taking steps now?
At this year’s WasteCon, I was looking for the latest information on exposed geomembrane covers (EGCs) because we are considering EGCs for several of our clients. At one session, I was interested to learn that predictions for performance life for some exposed geomembranes are now 70 years or more, based on information from the Geosynthetics Institute and others. At more than twice the 30-year post-closure period, it seems like EGCs are more viable than ever for use in final cover.
The conversation turned, however, to the concept of custodial care; monitoring and maintenance activities that would extend beyond the minimum 30-year post-closure period. This would certainly have an impact on how we evaluate alternative covers and I wanted to find out what owners/operators were thinking.
Darrell O’Neal, Director of the New River Solid Waste Authority in Raiford, Florida, had this to say. “If there is leachate and gas generation still occurring after the 30 year post closure period, DEP feels they have the authority to institute “custodial care” for post, post closure care. I’m not surprised with DEP’s position, but since we have 75+ years of capacity, we have ample time to figure out what “custodial care” looks like and budget accordingly.”
However, not every site has that amount of time (or indeed, any time) to prepare – if the site is already in post-closure, funds are being expended – with no revenue to cover costs beyond 30 years.
Darrell went on to say that the “DEP will have a hard time forcing custodial care for facilities [that have no gas, leachate, or contamination issues] and the goal should be to look like that kind of facility.” He was referring to an analysis that many states require before being “released” from post-closure care. While they vary, these “stability” requirements typically include minimal gas production, minimal anticipated further settlement, significant reduction in leachate quantity, relatively benign leachate characteristics, adequate vegetation/erosion control and no recent impacts to groundwater.
Are you taking steps now to have a “stable” landfill at the end of the 30-year period or are you budgeting for care beyond 30 years?
Donald Hullings, PE, is a senior project manager with 24 years of experience in the solid waste industry. He specializes in geosynthetic and geotechnical engineering and has presented on exposed geomembrane covers and sustainable landfill concepts.
Categories: Environmental Planning & Compliance, Landfill Engineering and Design, Solid Waste
Posted By Donald Hullings, PE at 11:30 AM | No Comments on Custodial care beyond the minimum 30-year post-closure period – Are you taking steps now?
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