The application asks for a permit to allow the C&D waste to be piled to a height of 65 feet and to allow 100 trucks of waste to be brought to the landfill every day.
The north boundary of the property is formed by Community Canal which flows into Bayou Braud. The south boundary is formed by Bayou Braud which flows into Spanish Lake and Alligator Bayou. The potential for toxic materials to leach from the debris into the Spanish Lake Basin is a concern.
Construction and Demolition Landfill Wastewater
St. Gabriel Redevelopment submitted a LPDES Permit Notice of Intent for a C and D Debris Landfill general permit to DEQ on August 8, 2007 (EDMS Document 36183018). St. Gabriel Redevelopment plans to collect cell dewatering wastewater from the construction and demolition landfill cell and discharge the wastewater via a ditch to the Commercial Canal, Bayou Braud, Spanish Lake and the Alligator Bayou Control Structure to Bayou Manchac. The additional wastewater loading to Alligator Bayou is unacceptable. The Bayou is already stressed and is the location of chemical loading that is causing large quantities of foam to be generated. The location of a Construction and Demolition debris landfill at the proposed location is unacceptable based on the necessity to discharge the wastewater through Alligator Bayou.
Description of Need Versus Service Area
St. Gabriel Redevelopment attempted to demonstrate the need for the C & D landfill near St. Gabriel based on the fact that the only D & J Landfill in the area is under a DEQ closure order and will soon cease operation. In the Introduction section of the Solid Waste permit application (EDMS Document No. 36712948 page 7 of 546), the applicant states that the proposed St. Gabriel landfill will be the only C & D landfill available to serve the disposal needs in the south Baton Rouge area (parishes of southern E. Baton Rouge, Iberville, Ascension, St. John the Baptist, St. James and Livingston). Upon further examination of the permit application, the applicant designated the service area as state wide (EDMS Document No. 36712948 page 25 of 546). In addition on page 25 of 546 (EDMS Document No. 36712948) the applicant further describes the waste to be received by the site as consisting of C & D debris from the service area. The service area is state wide. Thus the applicant in the Introduction is attempting to paint a picture of the waste to be disposed of at the site as coming from the south Baton Rouge area while the remainder of the application describes the waste to be received as being generated across the state.
Transportation of Waste
In the solid waste permit application (EDMS Document No. 36712948 page 111 of 546), the applicant states there would be 100 trucks per day entering the landfill through each to the two entrances (Hwy. 75 – ICI Road and through Bear Industries from Hwy. 75 ) carrying C & D waste into the facility. This equals 200 trucks per day. In the IT response, the applicant states that there will be up to 22 trucks a day utilizing the facility (EDMS Document No. 36712948 page 48 of 546). On page 49 of 546 under the response to the IT questions (EDMS Document No. 36712948), the applicant utilized the 22 trucks per day estimate to calculate savings in transportation costs when comparing various other C & D landfills to the St. Gabriel landfill. Up to 22 trucks a day versus 200 trucks a day is a very large difference in truck traffic and quantity of waste being transported to the proposed landfill. The applicant must be required to rectify the differences in truck traffic count.
On page 49 of 546 of EDMS Document No. 36712948 the applicant indicated that the landfill will be near dock facilities. No where else in the application is there any indication that C & D waste will be transported to the area of the landfill site via water. The applicant must be required to clarify the issues of transportation of waste.
Air Pollution
In the response to the IT questions, the applicant list dust and wind-blown materials as potential air pollution issues. The applicant indicated that cover soils will prevent releases of odors and wind-blown debris. The applicant failed to state that the C & D regulation only require C & D landfills to be covered with interim cover once per month. The applicant also failed to identify emissions of hydrogen sulfide as a large problem from C & D landfills. The hydrogen sulfide is generated as a result of degradation of wallboard which will be disposed of in the St. Gabriel landfill.
Air Pollution issues associated with C & D landfills are a substantial problem which are not adequately addressed by application of interim cover once per month.
Conclusion
The proposed location that would result in waste water discharges into Alligator Bayou make the proposed site unacceptable. The inconsistencies in the application also raise areas of grave concern. The proposed C & D landfill is designed to consist of a 90 acre disposal cell which will operate for 20 to 40 years. The application for the landfill by St. Gabriel Redevelopment is unacceptable and DEQ should deny the permit.
LDEQ will accept written comments from the public on this proposed permit until 12:30 p.m. on Monday June 9, 2008.
