In review of Land Protection and Revitalization Guidance Memo. LPR-SW-2020-01: Managing Leachate in Compliance with the VSWMR, we request that the Department consider and respond to the following:

Part V. A. (page 4 of 16)

Current Language: Schedule and frequency for cleaning out leachate lines

Comment: This language should be revised to “Perform cleaning out of leachate lines as needed to maintain proper functionality of the system”.

Part V. A. (page 5 of 16)

Current Language:  In addition to servicing the pumps, leachate collection lines should be periodically (e.g. annually) back flushed, water jetted, or chemically cleaned to remove biological scum and sediment buildup that could block the line.

Comment:  This language should be revised to “In addition to servicing the pumps, leachate collection lines should be back flushed, water jetted, or chemically cleaned to remove biological scum and sediment buildup that could block the line on an as needed basis as supported by site specific indicators.”

Requiring miles of leachate force main to be jetted annually or on a predetermined schedule places an undue burden and expense on facilities. Historical maintenance practices have shown that leachate conveyance lines can fully function for years prior to requiring cleaning and the length of time before the need to flush lines can vary greatly between sites. Maintenance and inspection practices outlined within this draft Guidance should provide the facility the flexibility to properly maintain leachate systems on as an as needed basis rather than a prescriptive frequency.

Part V. A. 2. (page 6 of 16)

Current Language:  General Comment – Facility reports within 24 hrs/5 days (unless alternate time is specified in the permit)

Comment:  WM of VA is in favor of the note that defers to alternate notification timeline within the solid waste permits.

Current Language:  General Comment – “...can demonstrate and return level to below 12in within 7 days,..”

Comment:  The agency should consider adding language reflecting uncontrollable events that may affect the ability of facilities to return head levels to below 12” within 7 days, such as severe weather. A 14-day period to return head levels to below 12” on the liner is requested.