SENECA FALLS — Before the state Department of Environmental Conservation considers Seneca Meadows’ landfill expansion application for review, the company must respond to 36 questions or requests for more information.
DEC officials in the Region 8 office in Avon listed the three dozen items in a 10-page Nov. 23 letter to SMI District Manager Kyle Black. SMI submitted the application July 20, seeking permits to deposit solid waste in a 50-acre “valley infill” area of the original Tantalo portion of the 400-acre landfill. SMI officials say that using that area would extend the life of the landfill by 15 years.
The application was submitted despite the town of Seneca Falls’ approval of Local Law 3 of 2016, which requires the landfill to close by Dec. 31, 2025, with no new solid waste disposal facilities allowed after that.
“As discussed with you, this is the Department’s first review of the very extensive application package and does not likely detail all DEC comments,” wrote Kimberly Merchant, deputy regional permit administrator.
No specific timeline was given as to when the questions and issues need to be addressed, but here are some of the DEC comments:
• The application cannot be deemed complete until receipt of the requested full Environmental Assessment Form (EAF) and completion of all procedural parts pertaining to Type I actions leading up to and including lead agency coordination, public scoping and the acceptance of the draft Environmental Impact Statement has been accomplished.
• The pre-draft submitted cannot be used in lieu of a full EAF due to the changes in the State Environmental Quality Review Act.
• DEC officials wants SMI to show compliance with the State Historic Preservation Act and show contact, cooperation and consultation with Indian nations.
• The DEC said SMI’s odor control plan should consider four stations outside the perimeter of the landfill to monitor for hydrogen disulfide, automation of the well field and if not possible, more monitoring wells in key areas, alternative material for daily cover such as thin polyethylene sheeting, spray foam or other technologies.
• The DEC listed 14 other requests for more information and data. One is for SMI’s plan to consider methane gas flares, which the DEC wants explained in more detail.
The DEC also noted that the Climate Leadership and Community Protection Act that went into effect Jan. 1, 2020, directs state agencies to determine if the decisions they make are consistent with the state greenhouse gas emission limits established by the new law. SMI is asked to identify each greenhouse gas and and how emissions from the landfill would be reduced or mitigated.
SMI also was told that questions about modeling protocols and the review of the potential for odors will come in a future correspondence.
Under comments for the Part 360 permit, the DEC listed four questions or inquiries. The first is a request that SMI provide a justification of the proposed design for the cell floor. It was noted that the current design required removing the existing final Tantalo cap. Alternate designs should be considered.
The DEC also has raised several questions about plans to remove the cap on the Tantalo portion of the landfill, including concerns about infiltration of ground water, bedrock removal and monitoring well abandonment and replacement in that area.
There also are 11 questions or comments about storm water pollution prevention plans in terms of hyrology data, swale design, storm water diversion, erosion protection, slope design, sediment ponds and berm design.