SENECA — The engineering firm hired by the town of Seneca has added its criticism to the Final Environmental Impact Statement for the proposed 43.5-acre expansion of the Ontario County Landfill.
The town of Seneca hosts the 389-acre landfill, operated for the county by Casella Waste Services, on Routes 5&20.
Clough Harbour Associates (CHA) of Rochester filed eight pages of comments by the Oct. 4 deadline.
A law firm hired by the town has also filed critical comments, as has town resident Katherine Bennett Roll of Number Nine Road and the Finger Lakes Zero Waste Coalition.
CHA engineer Kenneth Gallagher made these comments on the FEIS:
• VISUAL IMPACTS: In response to the Draft Environmental Impact Statement (DEIS), the town asked for more tree plantings on the berms to provide more of a visual barrier to the landfill.
Gallagher said the county’s response “is inadequate because it does not agree to remove and replace existing dead or dying trees.’’
“In addition, the details of the proposed vegetation mitigation should be presented now, in advance of the permit application. This response does not provide enough detail for the town to be assured that the required mitigation will be provided.’’
• BORROW AREA: The plan is for Casella to purchase a 40-acre parcel of farmland south of the landfill to use as a soil borrow area for landfill operations. Casella would then transfer the property to the county or town.
The FEIS states that the 40 acres may not be used for waste disposal activities and it would be immune from local zoning regulations.
“The DEIS and FEIS erroneously note that because the project will have no significant adverse impacts on land use, zoning, agricultural resources and open space and recreation, there is no need to propose mitigation,’’ Gallagher wrote.
He said the town believes the project, as presently proposed, will have a significant adverse impact.
He added that the town’s suggested mitigations were initially accepted by the county but later rescinded.
• OFF-SITE SOIL: The town has asked what the impact on existing traffic patterns would be if soil had to be delivered from an off-site area by truck in lieu of using the 40-acre borrow area.
The county’s response is that it would estimate five to eight more trucks per hour, or 43 to 64 truckloads a day, hauling soil to the new landfilled area.
“In the absence of any contrary discussion presented in the FEIS, we would conclude that it is highly unlikely that the addition of five to eight trucks more per hour associated with soil importation from an alternative off-site soil mine would result in a deterioration of roads,’’ Gallagher said. “This substantiates the town’s position that an off-site soil mine is a reasonable alternative that should have been examined.’’
• MORE SEQRA: The town said because of the deficiencies in addressing issues in the DEIS and FEIS and because the county and Casella have not yet applied for the expansion permit, “certain details about the proposed project are not presented or discussed in the environmental reports.’’
CHA asked whether the details of the permit application and air permit application will be subject to supplemental SEQRA review.
The FEIS response said the permit applications will be submitted after completion of the SEQRA process the project.
“Additional SEQRA review is not expected to be necessary,’’ it states.
Gallagher disagreed, noting that the county has said it will detail its mitigation measures as part of its expansion permit applications.
“It remains to be seen whether the measures that are proposed will reasonably mitigate the impacts that have been identified,’’ Gallagher said.
• SOIL AMOUNT: The amount of soil needed for the landfill expansion has decreased by 510,000 cubic yards from the DEIS to the FEIS.
Gallagher wants an explanation of how this decrease was calculated.
• BUD MATERIALS: Beneficial Use Determined (BUD) materials brought to the landfill as waste can be used as cover for the trash, in conjunction with soil. Gallagher said the FEIS calculation of how much BUD material can be used as cover needs to be explained.
• DUST EMISSIONS: Dust emissions are not estimated for the new landfill cell construction or the soil borrow area.
Gallagher said the county’s logic is that such emissions are not expected to change because the daily waste acceptance rate and annual construction is not anticipated to increase.
But Gallagher said documents show that dust emissions are expected to be 80.1 tons per year, exceeding the 15 tons per year threshold set by the state to require more analysis of health risk.
• LANDFILL GAS: The county plans to recirculate some of the leachate it collects from the landfill expansion.
Gallagher said the county promises to design and implement a gas collection and control system to handle an increase in methane from recirculated leachate.
Gallagher again said those plans should be detailed now, not in the permit application process.
• LEACHATE GAS ODORS: Leachate storage lagoons will be re-located to the northern boundary of the landfill site, possibly causing odor problems that should be mitigated.
The county replies that leachate will be pumped daily from storage lagoons and transferred off-site for treatment. They also said an odor management plan will be prepared for the expansion permit application.
Gallagher said that the covering of the leachate lagoons and collection of gas for treatment or an alternative leachate management option of a dedicated sewer line to the Canandaigua wastewater treatment plant should be explored fully.
• SOIL BORROW BERMS: Gallagher said the FEIS only provided one simulation of visual impact renderings regarding screening berms. He said an additional simulation should be provided from others residences on Rilands Road west of County Road 5.
• NOISE: Gallagher took issue with the Noise Impact Assessment provided for the county.
He said noise easements obtained by the county should be shown. He also said estimated noise from landfill construction and operation “does not adequately consider the cumulative noise impact associated with landfill cell construction, landfill closure contraction and landfill operations all occurring simultaneously.’’