1. Closure and Post-Closure
Armando Barrera – Environmental Permit Specialist
Municipal Solid Waste (MSW) Permit Section

2. Agenda What is closure and post-closure care
What occurs at waste processors, recyclers & disposal sites
What to include in closure and post-closure care plan
Where to find forms

3. General Timeline of a Disposal or Processing Facility
Remove Waste
Final Cover
Continued Monitoring
Permit Revocation
Closure and Post-Closure
Construction
Waste Transfer
Waste Disposal
Site Monitoring
Operation of Facility
Development Plan
Operating Plan Review
Public Notice
Application and Authorization

4. General Definitions Closure Post-Closure Care Stop taking waste
Remove all waste, residues, and recovered materials from storage and processing units
Cover disposal sites with a final cover system
Maintain right of entry
Maintain final cover from erosion, lack of vegetation, or ponding water
Continued Gas and Groundwater Monitoring
Maintain Leachate Collection

5. Applicability Processing Facilities Disposal Facilities Closure
Certification
Voluntary Revocation
Final Cover
Closure Plan
Post-Closure Care Plan
Monitoring
Certification
Voluntary Revocation

6. Processors Recycling Facilities Transfer Stations
Composting Facilities
Liquid Waste Processing Facilities
Medical Waste Processing Facilities

7. Closure Processes
Remove all waste, waste residues, and any recovered materials
Dismantle and remove all facility units or decontaminate
Evacuate all on-site material and feedstock to an authorized facility
Disinfect all waste management units/areas
If there is evidence of a release, an investigation may be required

8. Notice of Final Facility Closure
Publish a public notice in the newspaper of largest circulation in the area
Notice to the Executive Director
Post a sign at the entrance to the facility
Information in the notice
Name
Address
Physical Location
Authorization Number
Last date of received waste

9. Certification of Final Facility Closure
Submit a certification verifying that final facility closure has been completed within 10 days.
Signed by an independent licensed professional engineer.
Request for voluntary revocation.

10. Disposal Facilities Type I Landfills Type IV Landfills
Type I & IV Landfills
Type I AE Landfills
Type IV AE Landfills
Type I & IV AE Landfills

11. Final Cover System
Designed & constructed to minimize infiltration and erosion.
2 feet of soil
18 inches of clay-rich soil
6 inches of earthen material
Quality tested every acre

12. Liner System Properties for MSW Units
If there is a Synthetic Bottom Liner
Synthetic membrane equal or less permeable than the bottom liner
Minimum 20 mils
60 mils for HDPE
Clay-Rich Soil Layer
18 inches
Coefficient of permeability <1 x 10-5 cm/sec
Erosion Layer
6 inches
Sustaining Native Plant growth
Seeded or sodded immediately

13. Final Cover Properties-Class 1 Cells
Clay-Rich Soil Layer
4 feet
Coefficient of permeability <1 x 10-7 cm/sec
Membrane Layer
Synthetic membrane equal or less permeable than the bottom liner
Min. thickness of 20 mils
60 mils for high-density polyethylene to ensure seaming
Top Soil Layer
18 inches
Coefficient of permeability <1 x 10-5 cm/sec
Erosion Layer
6 inches
Sustaining Native Plant growth
Seeded or sodded immediately to minimize erosion

14. Alternative Final Cover Designs
Must achieve an equal reduction in infiltration as the clay-rich soil cover layer
Must provide equivalent protection from wind and water erosion

15. Alternative Final Cover – Water Balance
Limits percolation by use of silty and clayey soils until the water is removed by evapotranspiration
No less than two feet of thickness
Requires modeling unless Statewide Design Table is used
Financial Assurance must cover most expensive final cover option in the facility permit
Guidance (RG-494) is available

16. Closure Plan
Lays out the steps necessary to close all MSW landfill units at any point during the active life of the unit.
Includes:
Final Cover Design
Installation Methods and Procedures
Estimate of Largest Area requiring a final cover
Estimate of maximum inventory of wastes ever on-site
Schedule for completing closure activities
Final contour map with final contours, top slope, side slopes, surface drainage features, & protection of any 100-year flood plain

17. Closure Implementation
Place copy of closure plan in operating record
45 days before initiating closure, write notification to ED. Place notice in record.
Before 30 days after unit receives last receipt of waste, begin closure activities.
Within 180 days, complete closure activities.
Certification signed by an independent licensed professional engineer
Inspection report from regional office
Affidavit to the public and record in the deed
Begin Post-Closure Care

18. Post-Closure Activities
Maintain:
integrity and effectiveness of the final cover
the leachate collection system
the groundwater monitoring system
the gas monitoring system

19. Length of Post-Closure
30 Years for Type I and Type I AE
5 Years for Type IV and Type IV AE
Can be decreased based on documentation and certification.
Can be increased if it is necessary to protect human health and the environment

20. Post-Closure Care Plan
Describes the monitoring & maintenance activities required, and the frequency
Information for person responsible for overseeing the post-closure care activities
Description of the planned uses of any portion of the closed unit
Detailed written estimate, in current dollars

21. Completion of Post-Closure Care
Submit a certification, signed by an independent licensed professional engineer, verifying that post- closure care has been completed in accordance with the post-closure plan.
Submit a request for voluntary revocation of the facility permit.

22. Cost Estimates Included in the application and applies to Landfills
Storage and Processing Facilities
Recycling Facilities that store combustible materials.
Financial Assurance

23. Closure Cost Estimates For Processors
In current dollars
Cost of hiring a third party
Disposition of all processed and unprocessed materials
Maximum inventory of all wastes
Based on a per cubic yard and/or short ton measure
If conditions change, cost estimates should be adjusted accordingly. Decrease in costs would not be acceptable unless strongly justified with data.

24. Estimates for Combustible Materials
Estimate Maximum amount of combustible materials stored outdoors.
Calculate the disposal cost for each type of material.
Estimate loading costs
Loading Cost = Max Amount of Material in cubic yards x $0.80 per cubic yard
Loading Cost = Max Amount of Material in tons x $1.00 per ton
Estimate the cost of hiring a third party to transport
Number of Truckloads to transport max amount of material (weight limit, load capacity)
Transportation Cost = # of truckloads x mileage to disposal facility x $2.50 per mile
Total Estimated Cost = Loading Cost + Transportation Cost + Disposal Cost

25. Closure Cost Estimates for Landfills
In current dollars
Cost of hiring a third party
Closing the largest waste fill area that could potentially be open
Areas that have not received final cover
Review permit conditions on an annual basis and verify active areas match closure cost estimate areas.
If conditions change, cost estimates should be adjusted accordingly. Decrease in costs would not be acceptable unless strongly justified with data.

26. Post-Closure Cost Estimates for Landfills
In current dollars
Cost of hiring a third party to conduct post-closure care activities.
Annual and periodic costs for gas and groundwater monitoring.
If correction action must be taken, a cost estimate for hiring a third party to perform the activities is required.

27. Example Items in the Cost Estimate
Engineering Costs – Surveys, Closure Inspection, Testing, Contract Administration
Construction Costs – Mobilization of Personnel and Equipment, Final Cover Clay, Geosynthetic Clay Liner, Membrane Cover, Drainage Aggregate, Vegetation, Site Fencing
Storage Unit Closure Costs – Waste Disposal, Material Removal
Well Monitoring – Landfill Gas, Groundwater
Leachate Management – Operation, Maintenance and Disposal
Contingency – 10% of Sum of Engineering Costs, Construction Costs, Maintenance Costs, and Management Costs
Third Party Administration and Project Management Costs – 2.5% of Sum of Costs

28. Sources of Estimates Published Cost Estimator Manuals (e.g. RS Means)
Written quotes from an independent contractor not affiliated with the facility.
Verifiable Data based on Actual Operations

29. Financial Assurance – 30 TAC Chapter 37
Trust Agreement
Payment and Performance Bonds
Letter of Credit
Certificate of Insurance
Financial Test
Government Guarantee

30. Voluntary Revocation
Certification of Closure and Post-Closure from independent licensed engineer
Inspection report from agency regional office
Affidavit to Public
Deed Recordation
Submit Form TCEQ-10359

31. Website – www.tceq.texas.gov

32. Available Forms

33. Texas Administrative Code References
Closure and Post-Closure Procedures for Landfills and Processors
Title 30 Chapter 330 Subchapter K
Cost Estimates for Closure and Post-Closure
Title 30 Chapter 330 Subchapter L
Closure Procedures for Recycling Facilities
Title 30 Chapter 328 Subchapter A
Closure Procedures for Composting Facilities
Title 30 Chapter 332 Subchapter C
Closure Procedures for Medical Waste Facilities
Title 30 Chapter 326 Subchapter F

34. Thank you for coming
Armando Barrera Environmental Permit Specialist Waste Permits Division