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I. Operational Capacity and the 2022 Cessation

To: SWA Board Members and Operations Personnel

  • Public notices in May 2022 stated there was "no space left" in the dedicated Class D cell. Can you provide the specific engineering survey or site inspection report that confirmed the exhaustion of the "permitted footprint" and "permitted height" at that time?

  • If the cell was officially exhausted in June 2022, why did a 2023 state report continue to reference a five-year lifespan as of 2021?

  • Since the cessation of bulk C&D intake, average monthly tonnage increased from 642 tons (2021) to 673 tons (2023). If the Class D cell was closed, exactly which waste streams or specific material types account for this 31-ton-per-month increase?

  • Between June 2022 and today, has any volume of waste been recorded under "Class D" in your monthly filings to the WVDEP?

II. Regulatory Reporting and Waste Re-categorization

To: Administrative Personnel and SWA Board

  • Regarding the $95.00 per ton tipping fee: Is this fee currently applied to minor renovation debris (e.g., lumber, shingles) that is being diverted into the MSW stream?

  • If construction materials are being co-mingled with MSW, how are you maintaining compliance with state-mandated separation protocols and permit SWF-2001/WV0109436?

  • The SWA policy requires a certification of "asbestos-free" material for all delivered loads. If the C&D cell is closed to the public, why is this certification still being collected from property owners?

  • Is any "non-public" or "emergency" deposit of debris currently permitted in the exhausted cell that has not been disclosed in public notices?

III. Financial Justification and Infrastructure Pivot

To: Pocahontas County Commission and SWA Board

  • You have cited a $10 million threshold for a new facility as "unfeasible". Was an independent formal audit conducted to compare the cost of a new cell versus the long-term cost of trucking all waste to Greenbrier or Tucker County?

  • In the partnership with JacMal LLC and Allegheny Disposal, what specific "Flow Control" regulations are being drafted to ensure tipping fees are collected on "every ounce" of waste?

  • The "Green Box Fee" is projected to rise from $135 to potentially $600 post-closure. What is the legal basis for the County Commission's plan to subsidize fees for seniors while the SWA simultaneously faces potential bankruptcy?

  • The SWA used "Closure Turf" to reduce closure costs from $3.2 million to $2.4 million. Were these saved funds reallocated to debt service or to the construction of the new transfer station?

IV. Future Outlook and Site Integrity

To: Operations Management

  • With a projected total facility closure by 2027, what is the current status of the required leachate treatment plant that was cited as a major cost obstacle?

  • Who is the designated "good steward" responsible for the $75,000 annual post-closure care for the next 30 years once the site is fully capped?

  • What specific mechanisms are in place at the staging point to ensure C&D waste is no longer being buried on-site at the landfill or at private construction locations?


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