Waller Times Open Letter – The Unsuitability of the Proposed Pintail Landfill Site

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Just what makes a site suitable for a privately owned Municipal Solid Waste Landfill? Or perhaps more importantly, what makes a site unsuitable? The answer to those questions may very well depend on who it is that you ask.

If you ask a landfill company, their answers to those questions will probably differ greatly from the answers that you may get from the general population, local government officials, engineers and scientists, and even the regulatory agencies that regulate them.

Certainly, a privately owned landfill company will be looking at profitability first and foremost. Things like closeness to major highways to provide access from all surrounding areas and closeness to major large sources of waste are of primary importance to ensure that the landfill is utilized. And, certainly for them, finding a location which doesn’t violate the regulatory agency’s “fatal flaws” with regards to locations near airports, fault lines, and other such restrictions, is vital to getting the landfill permitted. Other than that, there is not much that limits them.

For most people in the general population, however, you may get a pause while they think about the question for a moment before they would no doubt give a variety of answers. It is very likely that the profitability of the landfill company would not be something that they would even consider.

Municipal Solid Waste Landfills have a stigma attached to them, and for good reason. In all probability, most people would say that landfills need to be far away from residential areas, small towns, schools, hospitals, etc. Some may include that they need to be away from areas that would pose a threat to sensitive surface and ground water resources, but the general population does not really have an adequate understanding of such water resources in their area.

The residents in the area around Hempstead, Texas, however, may have a greater sense than most of the general population about the importance of groundwater and surface water and their interaction. Most have lived here a long time and have an understanding of the sandy nature of the soils. Most have seen vast areas where the soil is incredibly similar to beach sand. Most have seen indications of the interaction between surface water and ground water first hand, either through the continuous flow of clean cold water in Clear Creek during the worst of drought conditions or, in times of more normal rainfall, areas where side-hill seeps occur where the water just flows out of the ground, or even in some areas where flowing water seems to disappear into the ground. Most are very aware that you don’t have to dig very deep before the hole fills with water.

All of the above indications of surface and ground water interaction are really only possible in areas where water can flow through the soil at a relatively rapid rate. The soil property that defines how quickly water can flow through soil is called the hydraulic conductivity. High hydraulic conductivities are associated with sandy soils and low hydraulic conductivities are associated with soils that contain a great deal of clay in them.

For a Municipal Solid Waste Landfill, as well as other types of waste disposal landfills, it is important that areas of very low hydraulic conductivity be chosen in order to minimize the spread of groundwater contamination when leaks occur in the liner. The area around Hempstead has very sandy soils with very high hydraulic conductivities that would allow groundwater contamination to spread very quickly into the aquifer that is recharged by rainwater infiltration into the outcropping of the aquifer’s sands. Since the sole source of potable water for the entire area is groundwater, this creates an unnecessary and dangerous risk.

The types of materials that are contained in municipal solid waste include all types of dangerous chemicals and cancer causing substances that are found in the products that we buy and use on a daily basis. All types of chemical cleaners, paints, detergents, benzene containing products, caustic materials, pesticides, herbicides, etc. Just think of all of the types of products that you have under your kitchen sink, or in your garage. Do you read those safety and hazard warnings?

The TCEQ does restrict the types of materials that can be disposed of in municipal solid waste landfills, but because of the mix of materials normally contained in household garbage there is no way to separate household quantities of restricted materials. In addition, TCEQ rules allow for the disposal of otherwise prohibited Class I Industrial Waste in Municipal Solid Waste landfills upon special request and permission of the TCEQ, up to 20% of the current or previous year’s total volume or weight of waste received. (30 TAC §330.173) Also, Special Wastes including coal ash, oil and gas wastes, and crude oil, petroleum product, or chemical contaminated soils may be disposed of by special permission from the TCEQ.

For Industrial Solid Waste Landfills, the TCEQ has written guidelines as to locations that are not appropriate with respect to hydraulic conductivity, depth to water table, groundwater flow velocity, as well as other factors. Those are contained in Technical Guideline No 2, titled “Industrial Solid Waste Landfill Site Selection”.

The guidelines state that areas where hydraulic conductivities are in the range of the Hempstead location are “Not Recommended”. Secondly, they also state that “Landfill locations that would require the placement of liners to cover appreciable thicknesses of moderately to highly permeable soils that are Below the Water Table Must Be Avoided”. Pintail now wants to place their liner up to 23 feet below the water table. And, thirdly, they state that groundwater flow velocities of greater than 100 feet per year are “Not Recommended”. The first application submitted by Pintail showed that the groundwater flow velocities at the Hempstead site exceed 400 feet per year.

So, should the same guidelines that apply to Industrial Solid Waste Landfills apply to Municipal Solid Waste Landfills? Is the proposed Pintail Landfill site in Hempstead a suitable location for a Municipal Solid Waste Landfill? You be the judge.

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