Gable dump back in County’s court; DEQ says it will not intervene
By Andrea Gaines
According to a letter sent to Loudoun County Zoning in February, the Virginia Department of Environmental Quality will not intervene in the Gable Farm landfill case.
The letter was sent to Loudoun County Zoning Administrator Mark Stultz by Richard Doucette, DEQ’s Land Protection and Revitalization Program Manager.
Activity at the landfill has been halted by a County Stop-Work Order for years.
The bottom line: ongoing permit violations related to unauthorized and potentially hazardous dumping will not be addressed by DEQ, and is now back in the County’s court.
Massive dumping, with no accountability
Complaints from neighbors and professionals in the field of solid waste management have been continuous. If something really bad is happening beyond permit violations, the public is on its own.
Since the Gable Farm landfill started out as a Personal Recreation Field, zoning regulations alone applied here, as truckloads of waste were dumped and graded for the landowner’s personal use.
But, over time, the activity revealed itself as a very profitable solid waste dumping site, and the County shut it down.
By that time, however, the dumping had totaled some 34,000 truckloads and 500,000 cubic yards of refuse, by some estimates. And, it was by then a landfill of more than 18 acres.
The waste was piled higher and higher, more than 10 feet higher than allowed by County permits. The debris included soil, liquid waste, cinderblock, broken bits of PVC pipe, plastics, rocks, gravel, and big chunks of asphalt.
Permit violations in 2017 and 2018 lead the County to issue the Stop-Work Order.
Enter the Wood Study, which identifies lethal contaminants
As the questions of both zoning violations and the potential build-up of toxins began to heat up, a company named Wood Environment and Infrastructure Solutions, Inc. was hired by the County to double check whether “the imported fill material [contained] contaminants considered harmful to human health and the environment …”
Personal Recreational Fields can only accept “clean fill,” and, as such, do not require owner/operators to use liners, tarps, and other things to keep toxins from getting into water, soils, and the atmosphere. Landfills, of course, do.
The backup studies conducted by DEQ were visual and cursory in nature, only. They did not characterize Gable’s fill as problematic, but, neither did they clear it as purely “clean fill,” and they would not certify that the landfill does not contain hazardous or noxious materials.
The Wood Study, on the other hand, thoroughly analyzed the 17 soil borings taken earlier on the 18-plus-acre landfill, each approximately 20 feet deep.
In doing so, Wood noted that the borings did not reach the bottom of the landfill, and groundwater had not been collected from any of them.
Wood also said that the boring soil samples had been analyzed for a range of contaminants … but not for pesticides or herbicides.
Wood found “two of the soil samples contained TPH concentrations [Total Petroleum Hydrocarbons – a family of chemical compounds originating from crude oil] exceeding 50 ppm …”
Continuing, Wood wrote, “as such, these concentrations would characterize this material as Category C which would exclude them as unrestricted clean fill … require appropriate disposal of this soil at a permitted and approved landfill equipped with liners and a leachate collection system.”
In other words, a large, full blown landfill was being regulated as if it were a simple, “clean fill” Personal Recreation Field. Not only were County permits being violated in terms of how big the site had gotten, the debris was potentially dangerous as an unregulated landfill.
The latest DEQ February letter includes simple “observations,” but does not address the inadequate testing issues raised by the Wood Study.
In its February 2021 letter to the County, DEQ references its review of the Environmental
Soil Characterization Report, dated July 22, 2020; and the Technical Memorandum – Gable Farm Soil Characterization Report Review, dated October 21, 2020. Unfortunately, DEQ does not really address the fundamental and profoundly troubling things the Wood study say is going on here.
DEQ got involved, did its own cursory site visit, and has now punted the decision back to the County.