"Port Townsend Paper Company (PTPC) has operated an unlined landfill for disposal of ash and lime grits from its mill since 1983. "

"The PTPC facility currently stands out as the only landfill in Washington 
which disposes of these types of paper mill wastes under an inert waste 
landfill permit. Other mills dispose of similar wastes in facilities which 
address the monitoring, financial assurance, and other standards for limited 
purpose landfills.

BACKGROUND:

Port Townsend Paper Company (PTPC) has operated an unlined landfill for 
disposal of ash and lime grits from its mill since 1983. The wastes are very 
alkaline, but not enough to designate as dangerous waste.

Inert waste landfills are not subject to several requirements which apply at other landfills which dispose non-inert solid wastes. Most notably, inert 
waste landfills are not required to perform groundwater monitoring or to 
provide financial assurance for closure and post-closure care.

In 1989, Ecology appealed Jefferson Countyís permitting of the landfill as an 
inert waste landfill under the Minimum Functional Standards for Solid 
Waste Handling. Ecology appealed on the basis that PTPCís waste didnít 
meet the definition of inert in that rule. The Pollution Control Hearings Board upheld Ecology’s appeal in a 1990 ruling.

In 2004, Ecology agreed that PTPCís wastes could be designated as inert 
under the new criteria in the Solid Waste Handling Standards, which had 
recently replaced the Minimum Functional Standards rule. The Jefferson 
County health department then issued PTPC an inert waste landfill permit.

In 2007, Ecology determined that some highly alkaline solid wastes should 
no longer be categorized as inert under the Solid Waste Handling Standards criteria because of the potential for their leachates to violate water quality 
standards. PTPC’s ash and lime grits fall within this category.

In late 2010, Ecology W2R staff began assisting Jefferson County Public 
Health (JCPH) in updating the PTPC landfill permit in anticipation of 
changes to the waste stream that might result from PTPC’s biomass-cogeneration proposal. Both agencies identified concerns regarding the continued permitting of the facility as an inert waste landfill.

In April 2011, Ecology recommended to JCPH that the agencies begin 
working with PTPC to transition the landfill to a permit under the limited 
purpose landfill requirements of the Solid Waste Handling Standards. This 
could include re-establishing groundwater monitoring and financial 
assurance for the facility.

At JCPH’s request, Ecology provided its recommendation in a letter, which 
also highlighted significant events in the landfillís permitting since 1989, and explained Ecology’s 2007 determination that some highly alkaline wastes should be excluded from the inert category.

ADDITIONAL CONSIDERATIONS:

The PTPC facility currently stands out as the only landfill in Washington 
which disposes of these types of paper mill wastes under an inert waste 
landfill permit. Other mills dispose of similar wastes in facilities which 
address the monitoring, financial assurance, and other standards for limited 
purpose landfills.

PTPC’s landfill is in a unique setting. It sits on a bluff above Glen Cove and 
Port Townsend Bay, and about 80 to 135 feet above the uppermost 
continuous groundwater aquifer. It’s in the rain shadow of the Olympic 
Mountains and receives an average annual rainfall of less than 20 inches, 
among the lowest amounts in Western Washington.

Ecology is not contending that there is an immediate public health or 
environmental problem associated with PTPCís landfill. However, Ecology 
also cannot say with assurance that PTPCís landfill has no adverse impact.

Ecology has concerns about the precedent that would be established by 
continued designation of PTPC’s wastes as inert. There have been recent 
proposals in Western Washington to permit disposal of other highly alkaline 
wastes, including hog fuel boiler ash, as inert wastes in locations that don’t 
have the low rainfall and large separation from groundwater provided by the site of PTPC’s landfill.

Community members have raised questions with Ecology and the Jefferson County Commission about the appropriateness of the inert waste 
designation, the landfill’s permitting, and the absence at PTPC of 
requirements which other landfills disposing of these types of wastes would 
be required to meet.

If PTPC’s landfill were not available, PTPC would be unlikely to find another 
permitted inert waste landfill which could accept PTPCís wastes.

If PTPC were to go out of business suddenly, Jefferson County would 
presumably be saddled with the immediate responsibility to conduct and 
pay for any closure and post-closure care of the landfill.

KEY POINTS MOVING FORWARD:

JCPH and Ecology need to maintain their primary focus on the appropriate 
designation of PTPCís waste, independent of any particular attributes of the 
landfill. The proper permitting of the landfill flows from the waste 
designation.

JCPH can consider specific permit conditions within a limited purpose 
landfill permit to align requirements for the landfill with the particular 
characteristics of the wastes, the landfillís setting, and the fundamental 
need to be protective of human health and the environment.

JCPH can consider variances from the Solid Waste Handling Standards where it believes they are appropriate and meet the criteria provide in the rule. Variances from the Solid Waste Handling Standards require Ecology’s 
formal concurrence.

NEXT STEPS:

Ecology will support JCPH in working with PTPC on an application for 
repermitting the landfill as a limited purpose landfill.

Ecology will consider requests proposed by PTPC for variances from the 
Solid Waste Handling Standards, and where we find them to meet the 
criteria in the rule for variances, we will concur with them.

Ecology will provide technical support to JCPH in developing suitable permit 
conditions for operation of PTPC’s landfill as a limited purpose landfill."

Source
http://ptwatchdogs.wordpress.com/2012/09/21/port-townsend-paper-company-waste-designation-laurie-g-davies-doe/