By Thomas P. Caldwell, InDepthNH.org
BETHLEHEM — The N.H. Department of Environmental Services has issued a letter of deficiency against North Country Environmental Services, Inc., the Casella-owned company that operates the landfill in Bethlehem where leachate overflowed its containment units last May.
The incident occurred when a pump failed to receive a wireless signal indicating that the leachate tank was filled, and it kept pumping material in, leading to an overflow that ultimately flooded the detention pond as well. Because it occurred on the weekend when there was no attendant, the problem was not discovered until Monday morning.
In the deficiency letter addressed July 21, Sarah Yuhas Kim, assistant director of the Waste Management Division, listed several problems with the company, beginning with its failure to provide leak-tight leachate storage units. The department asked the company to review both its as-built plans and the field condition of the storage system “for the entire facility” and ordered that, by Sept. 1, the company must complete the decommissioning of any units that are no longer in use.
By Oct. 1, North Country Environmental Services must send DES a description of all of the conduit decommissioning that has taken place.
The second deficiency cited was “failure to operate and maintain the facility in a manner that controls to the greatest extent practicable spills, and assures compliance with the facility permit.” The letter noted that North Country Environmental Services reported having problems with the wireless communications system for several weeks.
A June audit found that “multiple interlocks and other controls that would prevent spills are not present.” DES asked the company to provide monthly updates on its progress in addressing the problems found in the audit.
The department also found that the incident report lacked necessary details. Reporting that about 154,000 gallons of leachate was pumped after the tank was full “is an incomplete response because it lacks information” on the quantity of liquids and sediments removed from the stormwater pond and the quantity of soils excavated.
Furthermore, “the report states that the leachate was contained onsite and therefore posed ‘no risk to human health or safety or impact off property.’ This is an incomplete response and does not include an assessment of ‘actual or potential hazards to the environment, safety and human health.’”
The DES asks for such an assessment that would include “possible exposure routes (e.g., inhalation, ingestion, dermal contact) for humans and the environment.”
The company also failed to outline short- and long-term measures to eliminate a recurrence of the problem, the DES letter states.
The department is asking for an amended incident report that contains the missing information and monthly updates.
Kim noted that the DES may still seek monetary penalties for the noted deficiencies, and that failure to respond as requested could lead to enforcement action against the company.