357 North Main Street
Memphis, TN 38103

The State of Tennessee Department of Environment and Conservation (TDEC), Division of Solid Waste Management has issued proposed changes to the Tennessee Solid Waste Processing and Disposal Rules. Stakeholder meetings were held in January 2017. In general, here are some highlights that may affect your business:

Special Waste
By eliminating the special waste recertification process, the State hopes to remove the potential for rubber stamp approval when research has shown that many of these streams change over the course of three years. Instead, new applications will be required putting the rules more in line with landfill operator requirements.

Electronic Submissions 
The Division will now have the ability to require submittal of documents required by 0400-11-01 electronically. 

Petroleum Contaminated Soil
Excavated soil can no longer be disposed of as petroleum containing soil under this standard. The old limits were not protective of human health or the environment and allowed for contamination above the EPA regional screening levels to be disposed of off-site.

Landfill Permits 
Within one year of submitting their Part I application, applicants must submit either a Hydrogeological Report or Engineering Plans (one component of the Part II application). This change will clear old applications from the books and reduce the likelihood where a Part I could be submitted but further action on the application could be delayed by many years.

Closure/Post Closure Renewal
Resubmittal of the Closure/Post-Closure plans will be required every 10 years. This will allow for the update of itemized cost estimates and will provide owners an opportunity to evaluate the best available technology for closure.  This resubmittal will be processed as a minor modification.

Annual Engineering Report 
This proposal establishes a more robust reporting requirements for Class I, II and III landfills.

Field Filtered Samples
This proposed change removes the requirement that groundwater samples shall not be field filtered prior to laboratory analysis.