Consultant outlines stormwater prevention plan needed for landfill; Park Hill proposes one-time filing cost

A Park Hill consultant told the Tucumcari City Commission on Jan. 23 that the city needs a stormwater pollution prevention plan for its landfill as part of the facility’s permitting and long-term operation. The consultant said the plan documents potential pollutant sources, control measures and a schedule of inspections and reporting required by federal stormwater regulations.

"It is it is required by, US EPA," the consultant, Andy Nuhas of Park Hill, said during the presentation and described the SWPPP as "a written assessment of potential sources of pollutants in stormwater runoff and control measures that we implemented at [the] facility to minimize the discharge of those pollutants in runoff from the site." He added the practice typically includes best-management practices, quarterly inspections and annual reporting to the federal discharge reporting system.

Park Hill told the commission it could not find evidence that the landfill had an active facility-level multi-sector stormwater permit since construction in 2011; staff and the consultant said construction-era temporary permits existed for building cells but not a permanent permit for ongoing landfill operations. The consultant warned that while a missing permit cannot retroactively make prior activity illegal, lacking a registered SWPPP and the associated notice-of-intent filing risks federal agency action and may become a condition on the city’s 20‑year landfill permit.

Commissioners asked whether the city was currently out of compliance and whether previous engineers or consultants had managed permitting. City staff said monitoring at the site had been limited to leachate and groundwater monitoring associated with the leachate plant, while Park Hill said it had not found evidence of a long-term stormwater permit registration. Commissioners also asked about costs: the consultant described the proposal as a one-time development and filing effort, not an annual recurring development cost, and said Park Hill could assist with annual reporting for an additional fee. A figure of roughly $27,000 was mentioned in the meeting as the proposed cost to develop and file the application and SWPPP content.

Commission discussion centered on whether to hire Park Hill to prepare the SWPPP and file the notice of intent with the EPA’s system and on clarifying past practice. The consultant said some construction-era stormwater permits had been used historically for discrete building activities but that no ongoing permit had been found for normal landfill operations since about 2011.

The commission did not complete a formal vote on retention of Park Hill during the segment recorded in the transcript; commissioners asked staff to follow up on past documentation and compliance history.