Alternative Daily Cover Evaluation ADEQ Permit No. 0198-S1-R2 AFIN 01-00117 PREPARED FOR: EMS 1784 Highway One North Wynne, AR 72396 PREPARED BY: Fields & Associates, LLC 75 Norfork Drive Maumelle, Arkansas 72113 (501) 912-6381 August, 2009
EMS ADC Evaluation TABLE OF CONTENTS 1.0 INTRODUCTION... 1 1.1 REGULATORY REQUIREMENTS... 1 2.0 ALTERNATIVE DAILY COVER EVALUATION... 2 2.1 DISEASE VECTORS... 2 2.2 FIRES...2 2.3 ODORS... 2 2.4 BLOWING LITTER... 2 2.5 SCAVENGING... 2 2.6 CONCLUSIONS... 5 LIST OF APPENDICES APPENDIX A Alternative Daily Cover Request Fields & Associates, LLC No 109050 ii August, 2009
EMS ADC Evaluation 1.0 INTRODUCTION EMS (EMS) contracted with Fields & Associates, LLC to provide engineering services for the (Facility) located in Arkansas County, Arkansas. A request was made to the Arkansas Department of Environmental Quality (ADEQ) on August 04, 2008 to utilize a synthetic tarp in lieu of the prescribed six inches of daily cover as required by Regulation 22. The ADEQ authorized a trial period of a minimum of sixty days to evaluate the effectiveness of the tarp. EMS began uses the tarps in November of 2008. The Alternative Daily Cover (ADC) request and ADEQ authorization is included in APPENDIX A. The purpose of this report is to provide an evaluation of the tarp in meeting the requirements of Regulation 22. 1.1 REGULATORY REQUIREMENTS Reg.22.413(b) sets forth the requirements of any alternative daily cover material that is utilized in lieu of the prescribed six inches of earthen daily cover. More specifically Reg.22.413(b) states: Alternative Cover Materials - Alternative cover materials of an alternative thickness (other than at least six inches of earthen material) may be approved by the Director either through an individual request or through generalized Department approval upon demonstration that the alternative material and thickness controls disease vectors, fires, odors, blowing litter, and scavenging without presenting a threat to human health and environment. EMS selected a synthetic tarp manufactured by Enstar to evaluate as an ADC material. The tarps purchased for the landfill are 8.5 ounce per yard, forty eight foot by fifty foot in size and manufactured of polypropylene plastic. APPENDIX A contains additional information and specifications for the tarp. Fields & Associates, LLC No 109050 1 August, 2009
EMS ADC Evaluation 2.0 ALTERNATIVE DAILY COVER EVALUATION This section details the evaluation of the ADC material as required by Reg.22.413(b). 2.1 DISEASE VECTORS Disease vectors are defined by Regulation 22 as any rodents, flies, mosquitoes, or other animals, including insects that are capable of transmitting disease to humans. The ADC is a thick, tightly woven polypropylene material that will not allow the entry of insects into waste mass. The weight of the ADC, amount of overlap and the placement of sand bags inhibits animals from gaining access to the waste mass beneath ADC. The ADC utilized at the Facility is an effective means of controlling disease vectors. 2.2 FIRES The landfill operators have been trained in inspecting and identifying waste loads that have the potential to cause fire. This does not totally eliminate the possibility of fire but does greatly diminish the chances for a fire within the active face of the Facility. The ADC utilized at the Facility is not fire retardant, but in the event of a fire the remote location of the Facility minimizes the threat to human health and environment. 2.3 ODORS The operational procedures for placement of the ADC minimizes the generation of odors. The Landfill incrementally covers the waste with the ADC. There is no more than a two day period that waste is not covered by six inches of earthen cover. 2.4 BLOWING LITTER The ADC is an effective measure in eliminating blowing litter. The ADC is paced over the waste in a manner that all waste is covered and the edges of the ADC are placed over waste that has received earthen cover and secured by sandbags. 2.5 SCAVENGING Scavenging is defined as the manual sorting and/or materials from the waste stream, either in the trucks, at the face of the fill, or in unconfined truck discharge areas by individuals not employed or associated with the landfill operation. The ADC is placed at the end of the working day by an landfill personnel. The edges of the ADC are secured by sandbags. The level of effort required to remove the ADC would deter individual from scavenging. In addition the access to the landfill is control through gates and berms which further increases the effort required to scavenge items from the active face of the Facility. Fields & Associates, LLC No 109050 2 August, 2009
EMS ADC Evaluation 2.6 CONCLUSIONS The ADC as utilized at the Facility meets the requirements of Reg.22.413(b) in demonstrating a synthetic tarp can be used in lieu of the prescribed six inches of earthen daily cover. The ADC provides an efficient and cost effective means of covering the waste. EMS would like to request a permanent authorization in utilizing the ADC. Fields & Associates, LLC No 109050 5 August, 2009
EMS ADC Evaluation APPENDIX A Alternative Daily Cover Request Fields & Associates, LLC No 109050 6 August, 2009
Fields & Associates, LLC 75 Norfork Drive Maumelle, AR 72113 Office: (501) 912-6381 Fax: (501) 325-4110 Providing Innovative Solutions to the Solid Waste Industry July 30 th, 2008 Mr. Bryan Leamons Engineer Supervisor Arkansas Department of Environmental Quality 5301 Northshore Drive North Little Rock, AR 72118-5317 RE: Alternative Daily Cover Request for the DeWitt Arkansas, ADEQ Solid Waste Permit, 0198-S1-R2, AFIN 01-00117 Dear Mr. Leamons: Fields & Associates, LLC, on behalf of Eaton-Moery, would like to request authorization to evaluate the use of an alternative daily cover (ADC) material for the EMS Class 1 Landfill located in DeWitt Arkansas. This ADC will replace the six inch thickness of soil cover material required pursuant to Reg.22.413 with a tarp constructed of synthetic materials. The ADC will be placed at the end of each working and adequately overlapped to assure all waste is covered. The ADC will be anchored with sand bags to assure that the tarp remains in place. The exposed waste will be covered at the end of the week with adequate soil cover material. A daily inspection log will be kept to document any damage that may occur to the ADC. Repairs will be made to the ADC with materials supplied by the manufacturer. The ADC will be replaced when the damage to the tarp exceeds fifty percent of the area of the tarp. A replacement tarp will be kept at the landfill. Fields & Associates believes that the requirements set forth in Reg.22.413 are met with this alternative daily cover material. The proposed ADC will reduce the cost for the placement of daily cover and has the added benefit of saving landfill waste volume. The ADC system will be evaluated by random inspection by Fields & Associates representatives and ADEQ inspection reports. A request will be made at the end of the trial period to permanently utilize the ADC if the system is proven effective. If you have any questions or need further information, please feel free to contact me at (501)-912-6381.
Fields & Associates, LLC 75 Norfork Drive Maumelle, AR 72113 Office: (501) 912-6381 Fax: (501) 325-4110 Providing Innovative Solutions to the Solid Waste Industry Fields & Associates, LLC Phillip Fields, P.E. F&A President Attachments: Tarp Material Specifications and Information Cc: Tim Phillips, EMS Compliance Officer
EMS OM Manual ADC Operation and Maintenance Manual for the Alternative Daily Cover ADEQ Permit No. 0198-S1-R2 AFIN 01-00117 PREPARED FOR: EMS 1784 Highway One North Wynne, AR 72396 PREPARED BY: Fields & Associates, LLC 75 Norfork Drive Maumelle, Arkansas 72113 (501) 912-6381 August, 2009
EMS OM Manual ADC TABLE OF CONTENTS 1.0 INTRODUCTION... 1 1.1 GENERAL PROCEDURES... 1 1.2 PREDEPLOYMENT PROCEDURES... 1 1.3 DEPLOYMENT PROCEDURES... 2 1.4 MAINTENANCE... 2 1.5 CONCLUSION... 2 Fields & Associates, LLC Project No.15008 ii September, 2008
EMS OM Manual ADC 1.0 INTRODUCTION Eaton-Moery Environmental Services (EMS) contracted with Fields & Associates, LLC to apply to the Arkansas Department of Environmental Quality (ADEQ) for an authorization to evaluate using an alternative daily cover at their located 5 miles north of DeWitt, Arkansas. A request for the use of an alternative daily cover (ADC) was submitted to the ADEQ on August 4, 2008 (ADEQ Document Identifier 53443). The ADEQ granted a minimum sixty day demonstration period (ADEQ Document Identifier 53552) to evaluate the effectiveness of the ADC at meeting the requirements of Regulation 22.413. EMS began using the tarps for an ADC beginning in November 2008. EMS evaluated during this time period a synthetic tarp produced by Enstar. Through random inspections by Fields & Associates, LLC, the tarps proved to be effective at meeting the requirements of Regulation 22.413. The purpose of this report is to provide an operations and maintenance manual for the use of tarps as an ADC. This will be used by EMS and the ADEQ as guidance on how to properly use and maintain the tarps as an ADC at the. 1.1 GENERAL PROCEDURES The tarps in general will be utilized Monday thru Friday of the work week. During this period cover soil will be stockpiled adjacent to the working face. Covering of the waste with a minimum of six inches of soil cover will be performed each Saturday. During periods of inclement weather, such as high winds, the tarps will not be utilized. The cover soil stockpiled adjacent to the working face or soil from the borrow area will be used to cover the waste for the day. Other conditions may warrant the use of covering the waste with six inches of soil. These will be addressed on a case by case basis. 1.2 PREDEPLOYMENT PROCEDURES In order to minimize damage to the tarps and lessen the potential for a fire starting at the working face, the landfill personnel should perform the following steps before deployment of the tarps: 1. At the end of the working day the active area will be reduced to a size that will allow the tarps to overlap onto the adjacent soil a minimum of 4feet 2. The working face will be visually inspected for any signs of fire such as charred debris or smoke. Fields & Associates, LC Project No.109050 1 August, 2009
EMS OM Manual ADC 3. The working will be visually inspected for debris that could snag or tear the tarps. If any debris is found it will be recompacted into the working face. These steps should minimize the potential fire and the intrusion of vectors into the active working face and minimize damage to the tarps. 1.3 DEPLOYMENT PROCEDURES The tarps will be deployed either by hand or by available landfill equipment. When the tarp is being deployed by equipment the tarps will be tethered to the equipment and slowly pulled across the active face. The operators of the equipment will continually observe the progress of the tarp deployment. In the event the tarp snags, the deployment will be stopped immediately. The operator will inspect the active face and remove or any obstruction. The tarp will be inspected for damage. If damage occurs it will be reported and documented. After deployment and fully covering the active face, the tarps will be secured around the edges of tarp with sand bags or waste tires. The sand bags or tires will be placed every twenty feet to minimize the potential for the tarp to be wind blown and minimize infiltration of vectors in the active face. 1.4 MAINTENANCE The tarps have a very finite life due to the rough service nature of using them as an ADC. EMS will replace the tarps annually or if the tarp becomes severely damage during the year service period. The old tarps will be kept as spare tarps and will be used as additional cover over damaged tarps. When the tarps have reached the end of the usable life, they will be disposed of in the landfill. 1.5 CONCLUSION Tarps have proven to be a reliable and effective means of serving as an ADC. The tarps when deployed properly fully meet the requirements of Reg.22.413The tarps will provide a considerable cost savings to EMS and has improved the overall operational efficiency of the landfill. Fields & Associates, LC Project No.109050 2 August, 2009