2014 WQM Report

Updated: April 17, 2015 Total Pages following cover: 10

NEW YORK STATE DEPARTMENT OF ENVIRONMENTAL CONSERVATION

REGION 3 OFFICE/SOLID WASTE PROGRAM

2014 Groundwater Quality

Monitoring Audit Report

for Region 3 Inactive

Landfills A Summary of Compliance Rates

Nicole Smith

4/15/2015

2014 Groundwater Quality Monitoring Audit Report for Region 3 Inactive Landfills

Updated: April 17, 2015 Page 1 of 17

Table of Contents

Introduction ………………………………………………………………………………………2

Methods ………………………………………………………………………………………......2

Results and Discussion …………………………………………………………………………...3

Conclusions and Recommendations………….…………………………………………….……..4

Tables

Table 1. Inventory of water quality monitoring reports received 2010-2014 ……………5

Table 2. Compliance rates for landfill WQM data submittals 2010-2014 ……………….7

Table 3. Landfills missing data for the years 2010-2014 ………………………………...8

Table 4. Landfills missing data for the years 2011-2014 ………………………………...8

Table 5: Landfills missing data for the years 2012-2014 ………………………………...8

Table 6: Landfills missing data for the years 2013-2014 ………………………………...8

Table 7: Landfills missing data for the year 2014 ………………………………………..9

Figures

Figure 1. Graph illustrating compliance rates for landfill WQM data submittals

2010-2014 ……………………………………………………………………..7

Appendices

Appendix A………………………………………………………………………………10

Appendix B………………………………………………………………………………13

Appendix C………………………………………………………………………………17



Introduction

After closure of a landfill, the operator of the facility is required to submit groundwater

quality monitoring data each year. When the Solid Waste program receives this data, the

sampling results are reviewed and compared to applicable standards or guidance values (SGVs)

in order to identify potential environmental concerns. Analysis of this data allows the

department to evaluate the effectiveness of the landfill cap in mitigating landfill derived

groundwater contamination.

The rate at which a landfill is required to submit groundwater quality monitoring data is

based on a number of legally binding documents. First, the operator is provided with a consent

order that sets forth a number provisions, terms, and conditions. If the respondent (operator of

the landfill) agrees to the provisions outlined in the order on consent, then he/she is required to

submit a closure plan including post-closure maintenance and monitoring procedures to the

department for approval. Once approved, the post-closure monitoring and maintenance plan

calls for annual, semi-annual, or quarterly groundwater sampling for NYSDEC Part 360 Routine

and/or Baseline parameters. After five years of post-closure monitoring, the landfill can request

a variance reducing the monitoring frequency. If approved by the department, the variance then

modified the requirements of the post-closure monitoring and maintenance report.

The author has performed an audit of all inactive, monitored landfills to determine

compliance rates for submission of data during the past five years. This report summarizes the

data submission rate for the past five years (2014-2010), collected until April 1, 2015. It also

provides a summary of which landfills are not in compliance.

Methods

To begin, an inventory of groundwater quality monitoring data submissions to the

department from 2010 to 2014 was performed. A previous intern completed the most recent

audit in August 2014 (appendix A) which included an inventory of data from January 2010 to

August 2014. This audit builds off the previous report and includes updated information

subsequent to August 2014 through April 1, 2015.

A total of 66 monitored landfills from all seven counties under Region 3 jurisdiction

(Dutchess, Orange, Putnam, Rockland, Sullivan, Ulster, and Westchester) were evaluated in this

inventory. Either digital or hard copies of reports were considered sufficient submissions as long

the report included the relevant water quality monitoring data. In a table, the number of reports

submitted by each landfill were recorded for each of the five years included in the audit and

years with no data submissions were highlighted. Landfills missing data for an entire year were

flagged. The most recent date for data submissions for each landfill was also recorded in this

table.

Next author reviewed files to better understand the submission requirements and

circumstances of each landfill. In order to reconstruct the history of the landfill, excerpts of the



consent order, post-closure monitoring and maintenance plan, and approval letter reducing the

variance were pulled from the file and assembled as packages for each landfill that was flagged

in the table. The author then made phone calls to a number of the consultants for the flagged

landfills in order to see if the required water quality testing had been done, but failed to be

submitted to the department. A call log (appendix B) was kept in order to record all

correspondence regarding the landfills.

After organization of all the submitted data into a tabular format, review of files, and

completion of phone calls, overall compliance rates were determined as a percentage of the total

number of monitored landfills based on the inventory. Landfills that were missing required data

were then organized based on degree of non-compliance. Five individual tables were created to

outline degree of non-compliance. A table was created for each of the following categories:

Those that were missing data for all the past five years (2010-2014),

Those that were missing data for the past four years (2011-2014,

Those that were missing data for the past three years (2012-2014),

Those that were missing data for the past two years (2013-2014),

And those that were only missing data for the year 2014.

Most landfills are required to submit reports annually. Landfills that had only a one-year gap in

the submission of data, but had submitted data for the 2014 monitoring year were considered to

be in compliance.

Results and Discussion

The inventory of the monitoring reports (Table 1) received by the department over the

course of the last five years indicated that not all landfills have been submitting water quality

monitoring data regularly. In fact, the rate of compliance over the past five years is steadily

decreasing. In 2010, 82% of the monitored landfills were submitting data, but in 2014, that

percentage was down to only 70% of the total landfills required to submit data. Looking at the

past 5 years as a whole, only half (50%) of the landfills submitted data consistently every year

from 2010 to 2014 (Table 2, Figure 1).

After the audit was complete, 12 landfills were considered to be non-compliant with the

monitoring regulations set forth in the applicable post-closure monitoring report. Four landfills

(Table 3) were the worst offenders and had not submitted any data at all in the past five years

(2010-2014). Three landfills (Table 4) had not submitted any data for 2011-2014, three (Table

5) were missing 2012-2014 data, and two (Table 6) were missing 2013-2014 data. The landfills

listed in Tables 3-6 make up 12 landfills that are considered “non-compliant”.

Throughout the audit process, there were a few special cases that merit mention:

Gedney Way



Gedney Way was unique because it was found that the department never received

the closure report that was due in March 2012. Steve Parisio advised Bryan Zieroff

(consultant) that we would allow until March 13, 2015 for submission of the Post-Closure

Monitoring Plan. On March 11, 2015 the Closure Plan as well as all the data collected to

date was submitted by email to the department.

Plattekill

Steven Parisio, Solid Waste Geologist has been dealing with this landfill and

advised not to pursue this case because the town has already been notified that they are

not in compliance with regulations.

After careful review of all the landfills and their unique circumstances, 11 landfills that were not

in compliance remained:

Milan, Dutchess County

Middletown Psychiatric Center, Orange County

Phillipstown, Putnam County

Marlborough, Ulster County

Olive, Ulster County

Railroad One, Westchester County

Cragston (USMA), Orange County

St. Columba, Orange County

Hurley, Ulster County

East Fishkill Joint, Dutchess County

Kent, Putnam County

Conclusions and Recommendations

The overall goal of this audit was to determine the compliance rates among landfills that

were required to submit water quality monitoring data to the department each year. The study

found that only half of landfills inventoried had actually submitted their data consistently for the

last five years.

In response, I recommend reaching out to the operators of these landfills in hopes of

bringing them back into regulatory compliance. For each of the above 11 landfills I have drafted

letters (appendix C) that I recommend be sent to the operators informing them of their non-

compliance. These letters reference the order on consent, post-closure monitoring and

maintenance plan, and the letter reducing the variance (if applicable). These documents have all

been assembled as a package and I would advise that they be sent to operators as an attachment

to the letter. These letters will give the operators an opportunity to correct their deficiencies by

working with the department. All components of these letters can be found on the S drive using

this path: Computer\SHARED (\\NEWP-NW-GEN2\APPS1) (S:)\WQM Audit\(Landfill Name).



Tables and Figures

Table 1: Inventory of water quality monitoring reports received by DEC-Region 3, 2010-2015

Region 3 Inactive Landfills - Water Quality Monitoring - Number of Reports Received

Facility Name County Municipality Most

Recent Report

20

14

20

13

20

12

20

11

20

10

Beacon Dutchess Beacon Aug. 2014 1 1 1 1 1

Beekman Dutchess Beekman Sept. 2014 1 3 1

Castle Point Dutchess Wappinger Aug. 2014 1 1 1 1 1

Clayton Dutchess Hyde Park Jan. 2015 4 4

Dover Dutchess Dover Feb. 2014 1 1 1 1

DC Airport Joint Dutchess Wappinger Jul. 2014 2 1 1 2

Dutchess County Balefill Dutchess Wappinger Jan. 2015 1 4 4

East Fishkill Joint Dutchess Fishkill Sept. 2014 1 1 2

Harlem Valley Dutchess Ameinia Jul. 2014 1 4 4 4 4

Hudson River Psychiatric Center Dutchess Poughkeepsie Nov. 2014 2 3 4 3

Hyde Park Dutchess Hyde Park Aug. 2014 1 1 1 1 1

James Baird State Park Dutchess La Grange Nov. 2014 1 1 1 1 1

Milan Dutchess Milan Nov. 2001

Pine Plains Dutchess Pine Plains Sept. 2014 1 1 1

Rhinebeck Dutchess Rhinebeck Jan. 2014 1 1 1 1

Stanford Dutchess Stanford Feb. 2015 1 1 4 4 3

Tivoli Dutchess Tivoli May. 2014 1 2 1 2

Union Vale Dutchess Union Vale Dec. 2014 1 1 1 1 1

Washington Dutchess Washington Jan. 2015 1 2 2 3 2

West Hook Sand & Gravel Dutchess Fishkill Feb. 2014 2 2 4 3

Al Turi Orange Goshen Mar. 2015 1 2 2 2 2

Cragston (USMA) Orange Highland Feb. 2007

Danskammer Orange Newburgh Feb. 2015 4 3 1 1 1

Middletown Psychiatric Center Orange Middletown Dec. 2009

Monroe Orange Monroe May. 2013 1 1 1 4

Montgomery Orange Montgomery Nov. 2014 1 1 1 1 1

Spring Brook Road Orange Greenville Feb. 2015 1 1 1 1 1

St. Columba Orange Chester Aug. 2011 1

Stewart Air National Guard Orange Newburgh Jul. 2014 1 1 1 1 1

Youmans Flats Orange Youmans Flats Mar. 2015 1 1 1 1 1

Carmel Putnam Carmel Feb. 2015 1 2 4 4

Kent Putnam Kent Jan. 2013 1 1

Patterson Putnam Patterson Nov. 2013 1 1 1 1

Phillipstown Putnam Phillipstown Mar. 2004



Putnam County Putnam Carmel Jun. 2014 1 3 1

Southeast Putnam Southeast Nov. 2014 1 1 1 1 3

Haverstraw Rockland Haverstraw Feb. 2015 1 1 1 1 1

Lovett Coal Rockland Tomkins Cove Feb. 2015 3 1 4 3 2

Pfizer Rockland Orangetown Feb. 2015 1 1 4 4 1

Rockland County Psychiatric Center Rockland Orangeburg Dec. 2014 1 4 4 3 3

Bethel Sullivan Bethel Dec. 2014 1 1 1 1 4

Fallsburg Sullivan Fallsburg Jan. 2015 4 4 4 1 1

Lumberland Sullivan Lumberland Sept. 2014 2 1 1 1 1

Mamakating Sullivan Mamakating Jun. 2014 1 1 2 2

Sullivan Co Landfill Phase 1 Exp Sullivan Thompson Aug. 2013 1 4 4

Esopus Ulster Esopus Nov. 2014 1 1 1 1 1

Gardiner Ulster Gardiner Nov. 2014 1 1 1 1 1

Hurley Ulster Hurley Sept. 2011 1 1

Jockey Hill Ulster Kingston Jul. 2014 1 1 1 1 1

Lloyd Ulster Lloyd Nov. 2014 1 1 1 1 1

Marlborough Ulster Marlborough Mar. 2009

Minnewaska State Park Ulster Rochester Feb. 2015 2

New Paltz Ulster New Paltz Nov. 2014 1 1 1 1 1

Olive Ulster Olive May. 2011 1

Plattekill Ulster Plattekill Aug. 2010 1

Rosendale Ulster Rosendale Mar. 2015 1 1 1 1 1

Rochester Ulster Rochester Jan. 2015 1 1 1

Saugerties Ulster Saugerties Dec. 2014 1 1 1 1 1

Shawangunk Ulster Shawangunk Aug. 2013 1 1 1 1

Ulster Ulster Ulster Nov. 2014 1 1 1 1

Wawarsing Ulster Wawarsing Jan. 2015 1 1 1 1 1

Woodstock Ulster Woodstock Nov. 2014 1 1 1 1 1

Gedney Way Westchester White Plains Mar. 2015 1 1 1 1 1

Mt. Kisco Westchester Mt. Kisco Feb. 2015 1 2 1 1 1

Railroad One Westchester Croton-on-Hudson Apr. 2011 2

Sprout Brook Westchester Cortlandt Aug. 2014 1 2 1 1

Notes:

1. The following reports were received but did not include groundwater monitoring lab data: Al Turi - 2013, Carmel - 2012, Pfizer - 2014.

2. Highlighted cells indicate zero reports.



Table 2: Compliance rates as percentages based on the number of reports submitted each year

from 2010-2014

2010-2014 COMPLIANCE STATS

# of Landfills required to submit data 66

# of landfills that have submitted data for all years 33

2010-2014 Compliance Rate (%) 50.00

# of landfills that have submitted 2014 data 46

2014 Compliance Rate (%) 69.70









Figure 1: Bar graph demonstrating the decreasing compliance rate from 2010-2014

81.81

78.79

77.27

75.76

69.70

62.00

64.00

66.00

68.00

70.00

72.00

74.00

76.00

78.00

80.00

82.00

84.00

2010 2011 2012 2013 2014

Co

mp

lian

ce R

ate

(%)

Monitoring Year



Table 3: Landfills missing data for the years 2010-2014

Region 3 Inactive Landfills - Water Quality Monitoring - Missing 2014-2010 Data

Facility Name County Municipality

Milan Dutchess Milan

Middletown Psychiatric Center Orange Middletown

Phillipstown Putnam Phillipstown

Marlborough Ulster Marlborough




Olive Ulster Olive

Plattekill Ulster Plattekill

Railroad One Westchester Croton-on-Hudson




Cragston (USMA) Orange Highland

St. Columba Orange Chester

Hurley Ulster Hurley




East Fishkill Joint Dutchess Fishkill

Kent Putnam Kent



Table 7: Landfills missing data for the year 2014

Region 3 Inactive Landfills - Water Quality Monitoring - Missing Only 2014 Data


Dover Dutchess Dover

Rhinebeck Dutchess Rhinebeck

Tivoli Dutchess Tivoli

West Hook Sand & Gravel Dutchess Fishkill

Monroe Orange Monroe

Patterson Putnam Patterson

Shawangunk Ulster Shawangunk



Appendix A



Region 3 Inactive Landfills - Water Quality Monitoring - Number of Reports Received

Facility Name County Municipality 20

14

20

13

20

12

20

11

20

10

Beacon Dutchess Beacon 1 1 1 1 1

Beekman Dutchess Beekman 1 3 1

Castle Point Dutchess Wappinger 1 1 1 1 1

Clayton Dutchess Hyde Park 4 4

Dover Dutchess Dover 1 1 1 1

DC Airpoint Joint Dutchess Wappinger 1 1 1 2

Dutchess County Balefill Dutchess Wappinger 1 4 4

East Fishkill Joint Dutchess Fishkill 1 2

Harlem Valley Dutchess Ameinia 1 4 4 4 4

Hudson River Psychiatric Center Dutchess Poughkeepsie 2 3 4 3

Hyde Park Dutchess Hyde Park 1 1 1 1 1

James Baird State Park Dutchess La Grange 1 1 1 1

Milan Dutchess Milan

Pine Plains Dutchess Pine Plains 1 1 1

Rhinebeck Dutchess Rhinebeck 1 1 1 1

Stanford Dutchess Stanford 1 1 4 4 3

Tivoli Dutchess Tivoli 1 2 1 2

Union Vale Dutchess Union Vale 1 1 1 1 1

Washington Dutchess Washington 1 2 2 3 2

West Hook Sand & Gravel Dutchess Fishkill 2 2 4 3

Al Turi Orange Goshen 1 1 1 1

Cragston (USMA) Orange Highland 1 1

Crawford Orange Crawford 1

Danskammer Orange Newburgh 3 3 1 1 1

Howell Septage Lagoons Orange Goshen 2 1 2

Middletown Psychiatric Center Orange Middletown

Monroe Orange Monroe 1 1 1 4

Montgomery Orange Montgomery 1 1 1 1 1

Spring Brook Road Orange Greenville 1 1 1 1 1

St. Columba Orange Chester 1

Stewart Air National Guard Orange Newburgh 1 1 1 1 1

Youmans Flats Orange Youmans Flats 1 1 1 1

Carmel Putnam Carmel 1 2 4 4

Kent Putnam Kent 1 1

Patterson Putnam Patterson 1 1 1 1

Phillipstown Putnam Phillipstown

Putnam County Putnam Carmel 1 3 1

Southeast Putnam Southeast 1 1 1 1 3



Haverstraw Rockland Haverstraw 1 1 1 1

Lovett Coal Rockland Tomkins Cove 2 1 4 3 2

Pfizer Rockland Orangetown 1 1 4 4 1

Rockland County Psychiatric Center Rockland Orangeburg 1 1 4 3 3

Rockland State Park Rockland Clarkstown

Bethel Sullivan Bethel 1 1 1 1 4

Fallsburg Sullivan Fallsburg 4 4 4 1 1

Lumberland Sullivan Lumberland 2 1 1 1 1

Mamakating Sullivan Mamakating 1 1 2 2

Old Sullivan County Sullivan Thompson 1 4 4

Old V-Monticello Sullivan Monticello

Esopus Ulster Esopus 1 1 1 1 1

Gardiner Ulster Gardiner 1 1 1 1 1

Hurley Ulster Hurley 1 1

Jockey Hill Ulster Kingston 1 1 1 1 1

Lloyd Ulster Lloyd 1 1 1 1 1

Marlborough Ulster Marlborough

Minnewaska State Park Ulster Rochester 1

New Paltz Ulster New Paltz 1 1 1 1 1

Olive Ulster Olive 1

Plattekill Ulster Plattekill 1

Rochester Ulster Rochester 1 1 1

Rosendale Ulster Rosendale 1 1

Saugerties Ulster Saugerties 1 1 1 1 1

Shawangunk Ulster Shawangunk 1 1 1 1

Ulster Ulster Ulster 1 1 1 1

Wawarsing Ulster Wawarsing 1 1 1 1 1

Woodstock Ulster Woodstock 1 1 1 1 1

Croton Point Westchester Croton-on-Hudson

Gedney Way Westchester White Plains

Mt. Kisco Westchester Mt. Kisco 1 2 1 1 1

Railroad One Westchester Croton-on-Hudson 2

Sprout Brook Westchester Cortlandt 1 2 1 1

Notes:

1. The following reports were received but did not include groundwater monitoring lab data: Al Turi - 2013, Carmel - 2012, Pfizer - 2014.

2. Highlighted cells indicate zero reports.



Appendix B



PHONE LOG

Landfill: Marlborough

Date: March 25, 2015

Consultant: Tectonic, Jim Upright

Phone Number: (800) 829-6531

Spoke with:

Nature of Conversation: was unable to get ahold of anyone, left message.

Landfill: East Fishkill

Consultant: Rennia Engineering Design, Richard Rennia

Date: March 25, 2015

Phone Number: (845) 877-0555

Spoke with: Ryan

Nature of Conversation: Said that the firm does not represent East Fishkill, only Fishkill.

Offered to contact the town if they were having problems with the sampling. I said we would be

in touch with the town and did not request any further information.

Landfill: Railroad One

Consultant:

Date:

Phone Number:

Spoke with:

Nature of Conversation:

***Could not find any reports in SW digital filing cabinet or in the basement so I could not

determine who the consultant was.



Landfill: Middletown

Consultant: EA Engineering, Judith Graham

Date: April 1, 2015

Phone Number: (315) 431-4610

Spoke with: recording, left message

Nature of Conversation: No way to connect with an actual person. Tried to look up Judith

Graham in the directory and the recording said that the name did not match any results. Left a

message with the general mailbox.

Landfill: Kent

Consultant: Upstate Laboratories, Anthony Scala

Date: April 1, 2015

Phone Number: (518) 459-3134

Spoke with: answering machine

Nature of Conversation: left a message

Landfill: Cragston

Consultant: Adironadck Environmental Services, Inc.

Date: April 8, 2015

Phone Number: (518) 434-4546

Spoke with: Kelly

Nature of Conversation: Need to know the engineering firm doing the sampling in order to

look the landfill up in their system.

Landfill: Phillipstown

Consultant: Sergio Smiriglio Environmental Consultants, Inc.

Date: April 10, 2015

Phone Number: (548) 534-3816, (845) 534-3314

Spoke with:



Nature of Conversation: called the above numbers that I got from the 2003 report and it said

they were no longer in service.

Landfill: St. Columba

Consultant:

Date:

Phone Number:

Spoke with:

Nature of Conversation:

***Could not find any reports in SW digital filing cabinet or in the basement so I could not

determine who the consultant was.

Landfill: Olive

Consultant: Clark Patterson Lee

Date: April 10, 2015

Phone Number: (518) 463-4107

Spoke with: Secretary

Nature of Conversation: The secretary was unsure, but transferred me to Timothy Moot. I got

his voicemail and left a message asking him to call back.

Called me back on April 14, 2015, but I was not in the office.

Returned his call to his cell @ (845) 220-7154 as requested on April 15, 2015 and requested that

he call back on Friday.

NOTE: Steve advised me not to make calls to the following landfills: Hurley, Plattekill, and

Milan



Appendix C

Documents

2014 WQM Report