It’s Not Just About The Water In The Lake…

When considering the potential pollution effects on Lake Memphremagog from the operation of the NEWSVT Inc. landfill in Coventry, it’s not just about water quality impacts: it’s also about a toxic mix of air emissions. The Air Quality and Climate Division (AQCD) of the Vermont Department of Environmental Conservation (DEC) is currently reviewing four air emissions permit applications for the landfill. The leadership of DUMP has been preparing to participate in the expected upcoming public comment process regarding these four applications for permits that are pending with AQCD. If issued, these permits would allow the continued discharges of several toxic emissions into the air above the Lake and surrounding lands.

The US EPA and the state AQCD suggest that the majority of emissions from the landfill are methane and carbon dioxide gases. But a consideration of the adverse effects on human health and the environment can not end there. The landfill also emits approximately 26 other emissions that are classified as Hazardous Air Contaminants (HACs) under federal and state standards. According to state air regulations, a developer must reduce or control HAC emissions by implementing what are called the Hazardous Most Stringent Emission Rate (HMSER) for each HAC. The long story made short is that NEWSVT and the AQCD pretty much agree that the acceptable HMSER is the flaring (i.e., burning off with a presumed “minimum 98% destruction efficiency)” of the gases from the landfill. DUMP rejects this oversimplified “solution”.

There are also other specific concerns about sources of air pollution from the landfill known as Non-Methane Organic Compounds (NMOCs), many of which are HACs.  This is highly technical subject matter but the overview is that it is critical that the people of the Northeast Kingdom are aware of these existing air pollution emissions. The simplified approach taken by both NEWSVT’s consultants and the AQCD is that the general prevailing winds In Vermont are from the northwest during the winter and from the southwest during the summer. But DUMP believes that this approach improperly discounts the actual topographical and physical characteristics surrounding the landfill property and the proximity of Newport City to the landfill operation.

There are actually two sources of air pollution in operation on the NEWSVT property: 1) the landfill itself and 2) a facility that converts landfill gas to energy/electricity.  (LFGTE) These sources have been subject to prior AQCD permits over the years and the most recent permits expired in 2023. State law allows a developer to continue in operation under an expired permit as long as the developer files an application for the renewal of the permit prior to the expiration date. NEWSVT and the LFGTE corporation both filed timely renewal applications.

The expired permits for the two operations will be templates (or regulatory “road maps”) for the AQCD’s proposed draft renewal permits that will be subject to public comment. Here are some examples (Just examples! Not an exhaustive list!) of concerns that DUMP has identified about the AQCD’s past actions based on a review of the expired permits. Page references are to permit AOP-17-018, the expired permit for the landfill.

  Read the permit here

*The AQCD granted “Permit Shields” (i.e., exemptions from rigorous review under the regulations) for “particulate matter” (PM) and odors (pages 19 and 20). DUMP believes that there are serious pollution impacts from PM 2.5 and 10 that result from the heavy volume of truck traffic to the landfill in addition to the LFGTE equipment. A shield for impacts from odors is an insult to nearby residents. We also assume that odors are an “indicator” that other contaminants are also present in the same air.

*Variants of silica pollutants are among the landfill and LFGTE emissions. Silica emissions are known to cause very serious human health impacts. The emissions at the landfill result during the combustion of siloxanes in the LFG. The AQCD allowed these emissions based upon a vague NEWSVT proposal for a siloxane removal system (page 23).

*The AQCD determined that the landfill will have emissions of NMOCs, hydrogen sulfide, formaldehyde, acetaldehyde and silica in excess of their respective “Action Levels” under state regulations. Nevertheless, the AQCD decided not to require NEWSVT to conduct an Air Quality Impact Evaluation under its regulations (page 25).

There are also two other applications pending with the AQCD and they present yet another layer of complex issues and significant concerns for undue air pollution:1) the proposed permitting of the “pilot” Surface Active Foam Fractionation (SAFF) system which is intended to provide pretreatment of the landfill leachate with the goal of removing some PFAS content, and 2) the “after the fact” permitting of the enormous volume of wastes (e.g., sheetrock) disposed after the floods that hit New England in 2024 and the resulting emissions of hydrogen sulfide.

There is much more to be said about air pollutants from the landfill operations, the upcoming AQCD public comment process and DUMP’s preparation on behalf of the NEK community. But we wanted to keep this update to a readable length. Please stay tuned for further updates as we get ready for the draft permits.