ECDC defends its record and plans
Since announcing plans in November 2011 to apply for permitting to allow polychlorinated biphenyl contaminated material into the ECDC landfill, company administrators have been at odds with a group of East Carbon residents bent on stopping the the material from reaching their community.
While it is the Environmental Protection Agency and the State Office of Solid and Hazardous Waste who have the final say concerning the storage of this material at ECDC, public perception remains important for a company which has operated in the area for more than 20 years.
Following the printing of several critical letters to the editor from members of the East Carbon community, ECDC officials are speaking in the company's defense.
Allegations 'completely untrue'
"There are so many comments which have been made about our company which are completely untrue," said ECDC General Manager Jeff Green. "We understand that these citizens are concerned and we only wish to have the opportunity to present the facts about our protocols and our records."
Green and ECDC top administrator Kirk Treece explained the company's inspection and waste acceptance protocols.
"Our inspection process is two-fold," explained Treece. "We are subject to random inspections by the state of Utah at any given time. That entails a regulator showing up and filling out a full-blown inspection report at anytime. We also have our own internal inspection process which is quite extensive."
The area administrator addressed repeated accusations by East Carbon resident Robert L. Warren that improper and possibly hazardous material was being trucked into the facility from Colorado in the early morning hours to avoid inspection.
According to Treece, any new customer wishing to use the landfill must fill out a generator profile sheet, detailing what name of the substance, what the substance is and where it is coming from. The customer then must detail its sampling process showing exactly how they determine what a given material is composed of. That information is then sent to the company's corporate special waste approval group for review.
This is only the first step in the inspection process. Once the material's manifest is taken at ECDC's gates, those working in the cell inspect the dumped material to make sure that it visibly matches what is listed on the manifest. If it does not, the operator is forced to leave with the material.
"We go through a very vigorous training process with our employees, most of whom are long term hires," said Green. "Our people are highly educated when it comes to inspecting the material which is dumped at our site. We have a union site, so that should tell you that our employees always have to opportunity to speak about what they see and how they feel."
This leads to another area of contention among those at ECDC, several in the local area and Robert Warren specifically, have stated that the landfill's employees have made several mistakes which could lead to future problems. From ECDC's perspective, any mistake made at their facility has always been addressed by the book, working to prove their competence rather than diminish it.
According to ECDC officials, the issue brought up most often speaks to the return of hazardous waste to a generator after it was disposed of. A large and well known generator reported to the landfill that they had accidentally sent them waste which was not permissible in this area. The company reported this to ECDC.
"Four to six months had gone by and we were able to locate that material on the same day and it was approximately 30 feet from where we thought it was going to be," said Green. "That situation showed that our grid systems works well. With more than 60,000 tons of waste on top of that material, we were able to locate one barrel and send it away."
The liner which coats the cells at ECDC has also been made a matter of contention by those who oppose the landfill's new venture, stating that the equipment which is used in the cell could easily puncture the bottom of the landfill leading to leaks.
ECDC reports that a minimum of two feet of screened one-inch minus material is placed over the top of their liner before any waste transported into the cell. And while the bottom of the cell never has that material obstructed, the area officials were clear about erosion on the sides of the cell.
"The reality is that we have had compactors get too far into the garbage and the protective cover on the side walls of the cell wall," explained Treece. "However, once an operator sees that protective soil, we stop everything, dig it out and if the liner is damaged we repair it and document the incident with the state."
Another major point ECDC raised focused on their financial obligation to this area. Concerning bonding, every year ECDC officials conduct a flyover of their property and distinguish the acreage which they would have to reclaim if their facility was to shut down. After that, the company bonds annually to insure that if they were to walk away for any reason, including bankruptcy, the finances which would pay for the reclamation of their property are available.
While the majority of the points raised by ECDC's leadership focused around their record and attention to safety, a common thread repeatedly came back to their intentions concerning both the landfill's and the community's future.
"Why would we want to dispose of something improperly at ECDC?" asked Green. "First thing, it's my job if that happens. Also, I am a resident of Carbon County. I was born and raised here. If I do something improper and it's against the law and I could be thrown in jail for something like that. I could also lose my job. Why would I jeopardize my career by letting someone dump improper substances at ECDC?"
PCB levels deemed acceptable
Concerning the PCB material specifically, the city's environmental expert has contended that the material to be dumped is 1,000 times below the daily acceptable intake of PCB contaminated material. Beyond that, Treese spoke to the company's motivation for moving in this direction.
"The state is telling us we can dump this substance. The EPA is telling us we can do it. We would have never gone to either of those organizations if our corporate people who have experience with TSCA (Toxic Safety Control Act) materials were not saying we could do this," said Treece. "We get our confidence from the fact that we aren't in business to get into trouble, cause harm, or go way out on a limb and do something that isn't safe. We have confidence in the fact that our corporation, which runs over 260 landfills is saying, this is doable."