Proposed Landfill Leachate Evaporator: 45,000 gallons per day

Pa. DEP held 2 public hearings last week about a plan by a Westmoreland County landfill to build a gas-fired leachate evaporator (data sheet PDF).

Environmentalists and nearby residents testified about their concerns, pointing out that the landfill accepts solid fracking waste that can contain radioactive materials.

“The leachate evaporator system will exacerbate the air pollution in Allegheny County, which is already a non-attainment area for multiple pollutants. We do not believe that WSL will adhere to the requirements necessary for the evaporator.”

Jenna Rindy, environmental scientist with the citizens advocacy group Protect PT

Reporter Julie Grant covered the September 3, 2022 story, DEP hears concerns over evaporator at Rostraver landfill that processes frack waste, on WESA 90.5 – Pittsburgh’s NPR News Station.

“Research has shown that this waste is known to contain radioactive materials, which in turn could produce leachate that is also radioactive. These particles, when ingested or inhaled, have been linked to causing various types of cancer, such as lymphomas, leukemia, and bone cancer. A fact EHP (Environmental Health Project) finds especially concerning [is that] no health impact assessment was conducted to understand what this could mean for the surrounding community.”

Mackenzie White with the Environmental Health Project

“The landfill has continued to have extreme disregard for the rights of the people. The people of the Mon Valley deserve, and should demand, clean air, clean water and an environmentally safe place to live and thrive.”

Lisa Fordanich, who has family members who live close to the landfill

DEP is accepting comments until September 19, 2022:

“All comments, whether provided orally at a hearing or in writing, carry equal weight and consideration before DEP. All presenters should provide at least one copy of their written comments and exhibits for submission to the DEP either at the in-person hearing or via email to RA-EPSWROAIRPERMNOTE@pa.gov following the virtual hearing.”

TESTING REQUIREMENTS (excerpts)
“(a) The permittee shall conduct monthly sampling of the leachate prior to the hydrocarbon recovery unit (prior to the pretreatment unit) and post hydrocarbon recovery unit (post pre-treatment unit) for VOC, Total Suspended Solids (TSS), Total Dissolved Solids (TDS), Gross Alpha, Gross Beta, Radium-226, Radium-228, Sulfur Compounds, and HAP Metals (Antimony (Sb), Arsenic (As), Beryllium (Be), Cadmium (Cd), Chromium (Cr), Cobalt (Co), Lead (Pb), Manganese (Mn). Mercury (Hg), Nickel (Ni), and Selenium (Se) concentration.
(d) Within 180 days after initial startup, or on an alternative schedule as approved by the Department in writing, and at a minimum of once every quarter calendar year thereafter, the permittee shall conduct EPA reference method stack testing for PM10 (filterable and condensable), PM2.5 (filterable and condensable), Gross Alpha, Gross Beta, Radium-226, and Radium-228, or alternative test methods as approved by the Department in writing, in accordance with 25 Pa Code Chapter 139 and applicable EPA reference methods.”

Page 16 – DEP Auth ID: 1291604 – DEP PF ID: 514148 – PROPOSED 7-13-22

“(The landfill) can’t fix their truck wash bay, but you want to sell it to us that they’re going to put in this new system and they’re going to maintain it when they can’t maintain a truck wash bay to keep the trucks from dumping dirt and garbage on Tyrol Boulevard.”

Resident John Lunt

“They’re primarily concerned with the lack of environmental control and protection, which has previously caused violation to various permits and the Solid Waste Act. The township is concerned the evaporation and violation of this permit, this air quality plan, will further degrade the air quality of the township.”

Joseph Dalfonso, Rostraver Township solicitor, spoke on behalf of the township commissioners

PENNSYLVANIA BULLETIN, VOL. 52, NO. 30, JULY 23, 2022 – Pages 4166-67

Intent to Issue Plan Approvals and Intent to Issue or Amend Operating Permits under the Air Pollution Control Act (35 P.S. §§ 4001—4015) and 25 Pa. Code Chapter 127, Subchapter B. These actions may include the administrative amendments of an associated operating permit.

Southwest Region: Air Quality Program, 400 Waterfront Drive, Pittsburgh, PA 15222-4745.
Contact: Edward Orris, P.E., New Source Review Chief, (412) 442-4168.

65-00767C: Westmoreland Sanitary Landfill, LLC, 111 Conner Lane, Bell Vernon, PA 15012. Notice is hereby given in accordance with 25 Pa. Code §§ 127.44—127.46 that the Department of Environmental Protection (Department) intends to issue Air Quality Plan Approval 65-00767C to allow the construction and initial temporary operation of a Leachate Evaporation System consisting of one (1) Pentair Hydrocarbon Recovery Unit; one (1) Cleaver Brooks, ProFire MYHG 25.2, 25.2 MMBtu/hr natural gas-fired burner; and one (1) 45,000 gallons per day (gpd) Heartland Water Technology, LM-HT Concentrator, Evaporator and Entrainment Separator at the Westmoreland Sanitary Landfill located in Rostraver Township, Westmoreland County. The Westmoreland Sanitary Landfill currently operates under Title V permit 65-00767.

Potential to emit from the project is estimated to be 2.0 tons of nitrogen oxides (NOx), 1.5 tons of carbon monoxide (CO), 8.0 tons of particulate matter less than 10 microns in diameter (PM10), 8.0 tons of particulate matter less than 2.5 microns in diameter (PM2.5), 0.2 ton of sulfur dioxide (SO2), 1.0 ton of volatile organic compounds (VOC), and 0.5 ton of total hazardous air pollutants (HAPs).

The authorization is subject to State regulations including 25 Pa. Code §§ 123.1, 123.2, 123.13, 123.21, and 123.31. This Plan Approval has been conditioned to ensure compliance with all applicable rules. This includes emissions restrictions, operational restrictions, testing, monitoring, recordkeeping, reporting, and work practice requirements. Notice of Intent to issue the plan approval (NOI) was previously published in the Pennsylvania Bulletin on May 9, 2020. A substantial amount of comments were received from the public. The Department has considered those comments and produced an addendum to the previous review memo. The addendum to the memo summarizes the Department’s review after May 9, 2020, and any subsequent updates to the draft plan approval. The updated Plan Approval conditions include emission limitations for Radium-226 and Radium-228 from the leachate evaporation system to not equal or exceed the Nuclear Regulatory Commission’s (NRC) air discharge limits of 10 CFR Part 20, Appendix B, Table 2.

The updated plan approval also includes conditions requiring leachate sampling and conditions for testing, monitoring, recordkeeping, reporting, and work practice requirements for radionuclide emissions. The Department has determined that the proposed facility satisfies the Department’s Best Available Technology (BAT) requirements. Once compliance with the Plan Approval is demonstrated, the applicant will be required to revise or submit a Title V Operating Permit in accordance with 25 Pa. Code Subchapter G.

The Plan Approval application, the Department’s Air Quality Review Memorandum, Review Memorandum Addendum, and the proposed Air Quality Plan Approval for this project are available for review by any interested party at the Department’s Southwest Regional Office, 400 Waterfront Drive, Pittsburgh, PA 15222. Documents are available for review at the Department’s Southwest Regional webpage at http://www.dep.pa.gov/southwest and navigating to the Westmoreland Sanitary Landfill LLC project tab. Additionally, to request a review of the Plan Approval Application, to receive an electronic copy of the Department’s Air Quality Review Memorandum and Air Quality Review Memorandum Addendum, or to receive an electronic copy of the Department’s proposed Air Quality Plan Approval for this project, a person may contact the Southwest Regional Office File Review Coordinator at 412-442-4000.

A person may oppose the proposed plan approval by filing a written protest with the Department through Melissa Jativa via the U.S. Postal Service to Pennsylvania Department of Environmental Protection, 400 Waterfront Drive, Pittsburgh, PA 15222; or email to RA-EPSWROAIRPERMNOTE@pa.gov. Each protest or set of written comments must contain the name, address, email, and telephone number of the person submitting the comments, identification of the proposed Plan Approval (PA-65-00767C) and a concise statement of the objections to the plan approval issuance and the relevant facts upon which the objections are based. Public hearing. DEP will hold one in-person hearing and one virtual hearing to collect testimony from the public on the draft air quality plan approval. Each hearing will begin at 6:00 PM. The dates and locations are as follows:
• Wednesday, August 31, 2022—Rostraver Central Fire Department, 1100 Fells Church Road, Rostraver Township, PA 15012
• Thursday, September 1, 2022—virtual hearing via Webex.

Testimony will be limited to 3 minutes in order for DEP to receive as many comments as possible. Time may not be relinquished or shared, and organizations are asked to designate one speaker on its behalf. Video demonstrations and screen sharing by testifiers will not be permitted during the virtual hearing. All comments, whether provided orally at a hearing or in writing, carry equal weight and consideration before DEP. In order to accommodate all interested parties, the virtual hearing will be accessible both by internet and phone. Individuals who wish to observe or present testimony at either hearing are asked to register in advance by contacting Lauren Fraley at lfraley@pa.gov or 412-442-4203. Those wishing to participate in the virtual hearing will receive the link and instructions for how to join via e-mail. Registration for the hearing will be taken through 4:00 p.m. the day before each hearing.

All presenters should provide at least one copy of their written comments and exhibits for submission to the DEP either at the in-person hearing or via email to the email account following the virtual hearing. DEP will accept written comments on the draft air quality plan approval through close of business on September 12, 2022 (extended to September 19, 2022). Comments on the applications can be e-mailed or sent via postal mail to the Department of Environmental Protection, Southwest Regional Office, Air Quality Program, 400 Waterfront Drive, Pittsburgh, PA 15222, RA-EPSWROAIRPERMNOTE@pa.gov.

The draft air quality plan approval and more information on this site is available on the designated DEP Community Information webpage for Westmoreland Sanitary Landfill, LLC, found at www.dep.pa.gov/southwest.

If you are a person with a disability wishing to attend either hearing and require an auxiliary aid, service or other accommodation to participate in the proceedings, please contact Lauren Fraley to discuss how DEP may accommodate your needs. If necessary, you may use the Pennsylvania Hamilton Relay Service by calling (800) 654-5984 (TDD Users) or (800) 654-5988 (Voice users) and request that your call be relayed to Lauren Fraley at 412-442-4203.

Source: Pennsylvania Department of Environmental Protection
AIR QUALITY PLAN APPROVAL APPLICATION FOR A PROPOSED LEACHATE EVAPORATION SYSTEM

Air quality plan approval is required for the applicant to commence construction of an air contamination source and may allow for temporary operation. A plan approval is not the same as an operating permit, which is required for long-term operation. Publication of a draft air quality plan approval and notice of intent signals that DEP has performed its evaluation of the application and begins the regulatory public participation process.

On October 9, 2019, DEP received an air quality plan approval application on behalf of Westmoreland Sanitary Landfill for a proposed leachate evaporation system at the facility. On November 5, 2019, DEP accepted this application as administratively complete.

On May 9, 2020, DEP issued a draft air quality plan approval.

In response to public comments received, DEP has requested additional information from Westmoreland Sanitary Landfill. On July 2, 2020, DEP sent a letter to Westmoreland Sanitary Landfill requesting additional information. If Westmoreland Sanitary Landfill’s responses satisfied all deficiencies, DEP committed to develop a revised draft plan approval and review memo, republish public notice, provide for an additional public comment period, and hold a public hearing. Westmoreland Sanitary Landfill responded on August 31, 2020 and with additional information on September 23, 2020.

On November 13, 2020, DEP sent Westmoreland Sanitary Landfill a second letter requesting additional information. Westmoreland Sanitary Landfill responded on February 4, 2021.

On May 7, 2021, DEP sent Westmoreland Sanitary Landfill a third letter requesting additional information. On July 2, 2021, Westmoreland Sanitary Landfill requested an extension to respond to DEP’s deficiency letter. On July 20, 2021, DEP granted the extension to respond until September 2, 2021

On June 25, 2021, Westmoreland Sanitary Landfill submitted air dispersion modeling protocol to DEP.

On July 15, 2021, DEP provided comments on the submitted air dispersion modeling protocol for the proposed installation of the leachate evaporator at Westmoreland Sanitary Landfill.

On August 11, 2021, Westmoreland Sanitary Landfill submitted revised air dispersion modeling protocol to DEP. In coordination with DEP’s Southwest Regional Office and Bureau of Radiation Protection, DEP’s Air Quality Modeling Section reviewed the revised air dispersion modeling protocol for estimating ambient air concentrations of radionuclides due to the installation of the proposed leachate evaporator at Westmoreland Sanitary Landfill. DEP concurs with the proposed data, methods, and calculations to be used with the air dispersion modeling, as described in the protocol and will review the analysis when it is submitted.

On October 1, 2021, Westmoreland Sanitary Landfill submitted additional information. On October 29, 2021, DEP’s air quality modeling section provided comments on Westmoreland Sanitary Landfill’s air dispersion modeling. On November 30, 2021, Westmoreland Sanitary Landfill responded to DEP’s letter.

On July 23, 2022, DEP noticed draft air quality plan approval [65-00767C] to allow the construction and initial temporary operation of a leachate evaporation system.

Public Participation

Public Notice on DEP’s proposed air quality plan approval was published in the July 23, 2020 edition of the Pennsylvania Bulletin, which began a public comment period.

More infoOpens In A New Window (begins on page 4166).

Due to a publishing error in the Mon Valley Independent, DEP has extended the comment period until through Friday, September 19, 2022.

Newspaper notices (PDF)

Comments on the applications can be e-mailed to RA-EPSWROAIRPERMNOTE@pa.gov or mailed to the DEP’s Southwest Regional Office, Air Quality Program, 400 Waterfront Drive, Pittsburgh, PA 15222 and should contain the name, address, email, and telephone number of the person submitting the comments, identification of the proposed Plan Approval (PA-65-00767C), and a concise statement and the relevant facts upon which the comments are based.

DEP will hold two public hearings, one in-person hearing and one virtual, to collect testimony from the public on the draft air quality plan approval. Each hearing will begin at 6:00 PM.

  • Wednesday, August 31, 2022 at Rostraver Central Fire Department, 1100 Fells Church Road, Rostraver Township, PA 15012
  • Thursday, September 1, 2022 held virtually via the Webex platform

Individuals who wish to observe or present testimony at either hearing are asked to register in advance by contacting Lauren Fraley at lfraley@pa.gov or 412-442-4203. Registration for the hearing will be taken through 4:00 PM the day before each hearing. Testimony will be limited to three minutes for DEP to receive as many comments as possible. Time may not be relinquished or shared, and organizations are asked to designate one speaker on its behalf.

To accommodate all interested parties, the virtual hearing will be accessible both by internet and phone. Those wishing to participate in the virtual hearing will receive the link and instructions for how to join via e-mail. Video demonstrations and screen sharing by testifiers will not be permitted during the virtual hearing.

DEP provided an information sheet at the public hearings to provide background on the proposal and DEP’s review.

All comments, whether provided orally at a hearing or in writing, carry equal weight and consideration before DEP. All presenters should provide at least one copy of their written comments and exhibits for submission to the DEP either at the in-person hearing or via email to RA-EPSWROAIRPERMNOTE@pa.gov following the virtual hearing.

If you are a person with a disability wishing to attend either hearing and require an auxiliary aid, service or other accommodation to participate in the proceedings, please contact Lauren Fraley to discuss how DEP may accommodate your needs. If necessary, you may use the Pennsylvania Hamilton Relay Service by calling (800) 654-5984 (TDD Users) or (800) 654-5988 (Voice users) and request that your call be relayed to Lauren Fraley at 412-442-4203.

MORE: Opposition to Westmoreland Sanitary Landfill plan expressed at public hearing

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