certification of compliance by evita lagard louisiana department of environmental quality

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Certification of ComplianceBy Evita Lagard

Louisiana Department of Environmental Quality http://deq.louisiana.gov/

SOLID WASTE REGULATIONS• Promulgated on November 20, 2011 • Citation: LAC 33:VII.525• Minor permit modification to current permits• Due annually on October 1 of each year for the preceding July 1 to June 30• First submittal is due on October 1, 2013


FACILITIES REQUIRED TO SUBMIT

• All permitted solid waste facilities: Landfills (Type I, II, III) Landfarms

Surface Impoundments Incinerators

Separation Facilities Resource Recovery Processing Transfer Stations Compost Facilities Air Curtain Destructors Shredder/Compactor


WHO IS NOT REQUIRED TO SUBMIT?

• Solid waste generators• Waste tire processors• Beneficial use facilities (Ch. 11)•Non-processing transfer stations


CHANGES TO REPORTING REQUIREMENTS

• Facilities that submit the Certification of Compliance are no longer required to submit the following solid waste annual reports: -Generator -Disposer -Processor -Separation & composting• Due date changes from August 1 to October 1


REPORTING REQUIREMENTS

• Facilities that do not submit the Certification of Compliance are still required to submit solid waste annual reports: -Generator -Beneficial use (Ch. 11)

-Non-processing transfer stations• Due date is still August 1


TWO FORMS

• Operating facilities which includes the Part I & II Certification of Compliance• Facilities in post-closure (LDEQ has approved closure)


SUBMITTALS

•Each permit must be completed on a separate form - P-0000 for landfill and surface impoundment, complete one form - P-0000 for landfill and P-1111 for surface impoundment, complete two forms


CERTIFICATION OF COMPLIANCE-PAGE 1

• Instructions -Reporting Period: July 1 – June 30 - Mail 2 copies to LDEQ: Enforcement & Financial Services• Facility information• Certification of responsible official



•Type of Operation -Type I, Type I-A, Type II, Type II-A, Type III -Landfill, landfarm, surface impoundment processing transfer station, incinerator - Check all units covered by the permit



• Provide calculations, including conversion factors -State device or describe method used to determine quantities of waste (scale, recordkeeping)• Same requirement from annual solid waste reports • Attach as Attachment 1



• Deviations from Permit Conditions• Identify each• Provide steps taken to return to permit conditions• Provide steps taken to insure deviations of similar type are prevented in the future• Examples: change in operating hours, not having required number of certified solid waste workers, not performing groundwater monitoring according to permit schedule• Attach as Attachment 2


DEVIATION ≠ VIOLATION

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• Type and Quantities of Waste

- Waste generated (Attachment 3) If more than one permit, only complete generator information once - Waste processed (Attachment 4) - Waste disposed (Attachment 5)



• Capacity for Disposal Units Only

- permitted (cubic yards & wt-wet tons) - remaining (cubic yards & wt-wet tons) - remaining capacity (months & years) - capacity used during reporting period • Provide for each unit covered by the permit



•Off-Site Reuse and/or Recycling - Provide type & quantity sent off-site for reuse or recycling (Attachment 4) - Provide end use• Replaced the separation & composting annual report



•Incinerator, shredders, balers, compactors & transfer stations - Provide types and quantities of waste transported for disposal



• Solid Waste Worker Certification - Provide number of certified operators for each unit covered by the permit



• Fees - Have all fees due to LDEQ been paid? - Applies to all media, not just solid waste fees - Any invoice in dispute? Explain & attach as Attachment 6



• Annual Certifications Required - Provide a list of certifications - Proof certification completed - Attach as Attachment 7



• Landfill Requirements - Permitted elevation - Current elevation, method to calculate & date of measurement (Attachment 8) - Last date landfill elevation certified by professional land surveyor or registered professional engineer in the state of Louisiana (required at least every 5 years)



• Landfill Requirements - Maximum area requiring final cover at any time during the active life of the landfill (required for financial assurance estimates) - Waste disposal area without cover in acres



• Air Curtain Destructors - Provide location of the site used - Provide quantity of waste processed at each site - Attach as Attachment 9



• Ultimate Off-Site Disposal Site - Facility name - Facility agency interest number - City and state• Applies to permitted disposal facilities that send unacceptable waste off-site



• Financial Assurance - Updated cost estimates - Updated mechanisms - Local government financial test & local government guarantee have additional questions on updating information and recordkeeping



• Part II Certification of Compliance, Item 15 - Facilities with TEMPO permits or modifications complete Item 15.B - If TEMPO permit requires specific conditions, address each one - Attach as attachment 13



• Part II Certification of Compliance, Item 15 - Facilities without TEMPO permits or modifications complete Item 15.C & D - Have all required reports been submitted as required? - Have all monitoring requirements been met? - If “no” is the answer to either question, must provide an explanation and attach as Attachment 13


CERTIFICATION OF COMPLIANCE-PAGE 7-16

• Attachments


CERTIFICATION OF COMPLIANCE-Post-Closure

• Same as form for operating facilities: - Reporting period, mailing instructions, certification of responsible official - Type of operation - Financial assurance - Fees



• Different from form for operating facilities: - Final cover information - Leachate - Gas collection/treatment - Groundwater monitoring



• Final cover information - Significant erosion? - Depressed areas holding water? - Cover well vegetated? - Has final cover been maintained? - Has LDEQ been notified of any problems or corrective action taken? - Have annual reports on integrity of the cap been submitted to LDEQ?



• Leachate - Has leachate collection and removal system been maintained? - Any leachate outbreaks? - Are pumps adequate & maintained?



• Gas collection/treatment - Gas collection/treatment or removal system maintained & operated? - Gas monitoring system maintained & operated? - Has the methane concentration exceed the lower explosive limit? - Is an air permit required?



• Groundwater monitoring - Has a groundwater monitoring system been maintained. - Provide date of last groundwater monitoring report submitted to LDEQ - Site in assessment or corrective action? - Have any statistically significant increases been detected?


LDEQ Web Site

Home page: http://deq.louisiana.gov/

Divisions Waste Permits Solid Waste PermitsAnnual Report FormsCertification of Compliance (Due October 1)Certification of Compliance for Facilities in Postclosure (Due October 1)


http://deq.louisiana.gov/

Key Points:

- Required for all permitted facilities, except waste tire processors

- Certification of Compliance replaces solid waste annual reports

& due on October 1

- Generator only, beneficial use facilities or non-processing

transfer stations continue submitting solid waste annual reports

& due on August 1

- Deviation ≠ Violation

Louisiana Department of Environmental Quality

http://deq.louisiana.gov/

QUESTIONS

Evita Lagard Environmental Scientist Senior Office of Environmental Services Waste Permits Division (225)219-3388 [email protected]


mailto:[email protected]

certification of compliance by evita lagard louisiana department of environmental quality

Documents

solid waste fees

solid waste regulations

annual solid waste reports

waste processed attachment

waste generated attachment

quantities of waste

permit conditions

type quantity