Demolition Landfill Guidance

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Demolition Landfill GuidanceWater/Solid Waste #5.04, August 2005Solid WasteProgramContentsBackground . 1BackgroundPurposeThe State Solid Waste Rules allow theMinnesota Pollution Control Agency(MPCA) Commissioner considerablediscretion to set site evaluation, design,monitoring, and operationalrequirements for demolition landfills.The exercise of this discretion hasresulted in a lack of consistency in theway that the MPCA has applied theserequirements to demolition landfillsthroughout the state.This guidance is intended to provideimproved consistency and predictabilityin how the MPCA, counties, facilityowners, and facility operators managedemolition landfills under the existingsolid waste management rules in thefollowing areas: locating the facility; developing initial site evaluationinformation; determining facility classification; identification of an acceptablewaste list; appropriate waste-sceeningprocedures; contents of an Industrial SolidWaste Management Plan; need for ground water monitoring;and, liner requirements.Purpose . 1Location Standards . 1Facility Classification . 2Site Evaluation . 3Acceptable Waste . 4Waste Screening . 5Industrial Solid WasteManagement Plan . 6GroundwaterMonitoring. 7Liners . 8Limited AvailabilityLandfills . 8Contact Information . 9Stakeholders List. 9Appendix A: ParametersList for Sampling ofGround WaterMonitoring Network.10Appendix B: BestManagement Practicesfor Waste-screeningProcedures . .12Appendix C:ImplementationPlan 13w-sw5-04Ground water monitoring requirementshave become an emerging issue withregard to assessing impacts fromdemolition landfills. Historically, thehypothesis in the professional arena hasbeen that only inert materials aredeposited at demolition landfills; thus,there is no impact to ground waterquality, and therefore no need for groundwater monitoring.In 2003, the MPCA decided to test thishypothesis by evaluating the limitedamount of ground water monitoring datafrom demolition landfills. The results ofthis evaluation indicated that somedemolition landfills do impact groundwater quality. Therefore, a morethorough approach is needed relative tohydrogeologic evaluations, and indetermining groundwater monitoringrequirements when siting and managingdemolition landfills.This guidance will be applied to allnew and existing demolition landfillsin accordance with theimplementation plan included inappendix C.Location StandardsThe single most effective action thatowners/operators of demolition landfillscan take is to locate demolition landfillsin areas that will inherently protectground water and surface water from theMinnesota Pollution Control Agency, 520 Lafayette Rd. N., Saint Paul, MN 55155-4194(651) 296-6300, toll-free (800) 657-3864, TTY (651) 282-5332 or (800) 657-3864This material can be made available in alternative formats for people with disabilities.

Municipal DivisionSolid Waste Section,risks of contamination. Prohibited locationswhich must be avoided include active karsttopography, flood plains and other areas likelyto result in groundwater contamination. Thefollowing are the basic landfill locationstandards that apply to demolition landfills:Minn. R. 7035.2555 LOCATION STANDARDS,provides the following location restrictions onall solid waste management facilities.Subpart 1. Floodplains. An owner or operatormay not locate a new solid waste managementfacility in a floodplain.Subp. 2. Other location standards. An owneror operator may not establish or construct asolid waste management facility in the followingareas:A. within a shoreland or wild and scenic riverland use district governed by chapters 6105 and6120;B. within a wetland; orC. within a location where emissions of airpollutants would violate the ambient air qualitystandards in chapters 7005, 7007, 7009, 7011,7017, 7019, and 7028 and parts 7023.0100 to7023.0120.In addition, Minn. R. 7035.2825 provides thefollowing location restrictions on permitteddemolition debris land disposal facilities.Subp. 7. Location standards for permittedfacilities. The owner or operator of a permitteddemolition debris land disposal facility must notlocate the facility on a site:A. with active karst features includingsinkholes, disappearing streams, and caves; orB. where the topography, geology, or soil isinadequate for protection of ground or surfacewater.Demolition Landfill GuidanceAugust 2005To better determine what is meant by “floodplain,”reference should be made to the 100-year floodplainas shown on maps provided by the FederalEmergency Management Act (FEMA). Other setbackdistances that are applied to landfill siting based onthe above rule references are 1,000 feet from a lakeand 300 feet from a river, stream or creek.Because the Solid Waste Rules prohibit theplacement of demolition landfills in areas thatwould result in groundwater contamination, anexisting permitted landfill that does not meet thelocation standards above will not be re-permitted.The owner/operator may request a variance tothese location standards under the processoutlined in Minn. R. 7000.7000. If a variance isrequested, MPCA staff will consult with thecommissioner as to whether the request isappropriate and will discuss the need foradditional site investigation, monitoring, and/orenvironmentally protective measures based on thespecific site circumstances.Facility ClassificationOne of the bigger problems with the currentdemolition landfill rules is that they are open endedand leave a great deal of facility requirements toCommissioner discretion. This does not work well topromote consistency in management requirementsgiven the many variables and permutations that existbetween publicly owned and privately owned, largeoperations and small operations, metro sites and ruralsites, etc. Therefore, several meetings were held inJune and August of 2005 to discuss an appropriateapproach to take with demolition landfills. It wasagreed that a three-class system approach todemolition landfills was warranted. Based on thesemeetings and subsequent discussions, the followingclassification system for demolition landfills wasdeveloped.PAGE 2

,Municipal DivisionSolid Waste SectionDemolitionLandfillsClass IAugust 2005Class IIClass IIIAll sites will need to conduct a site evaluation to verify that location standards are met,soils are evaluated, depth to the water table is identified, and groundwater flow direction isdefined (See Site Evaluation section.).Acceptable C&D WasteList Incidental nonrecyclablepackaging consisting ofAcceptable C&D Wastepaper, cardboard andAll C&D wastesList (See list inAcceptableplasticAcceptable WasteWastes Most industrial wastes Demo-likeindustrialsection.)wastes comprised ofwood, concrete, porcelainfixtures, shingles, orwindow glassStringent screening isWasteScreening is required.Screening is required.required.ScreeningDescribe screeningDescribe screening proceduresprocedures and identifyand identify additional C&Dadditional C&D wastesIndustrial Solid Describe screeningwastes and specificand specific demo-likeprocedures, addressWasteindustrial wastes to beindustrial wastes to beasbestos-containingManagementaccepted; address ACM ifaccepted; address ACM ifmaterials (ACM) ifPlan velop waste acceptanceDevelop waste acceptancecriteria.criteria.Determined by decisionmatrix in theGroundwaterYesYesGroundwater MonitoringMonitoringsection.Determined by decisionNoYesmatrix in the LinerLinersection.If the facility takes more than 50% industrial waste based onNAannual gate receipts, it should be reclassified as anReclassificationindustrial landfill.Site EvaluationSite EvaluationWhen permitting or re-permitting a demolitionlandfill, specific tasks associated with a siteevaluation must be completed to determine whetherDemolition Landfill Guidancethe site meets the location standards. The siteevaluation will more precisely identify potentialrisks, as well as help identify the need for long-termground water monitoring. If an owner/operator isapplying for the re-issuance of an existing permit,PAGE 3

Municipal DivisionSolid Waste Section,all the information specified below must be on recordor must be established prior to permit re-issuance.The permit application shall include: verification that the site meets the locationstandards; sufficient documentation to establish theseparation distance between the lowest fillelevation and the water table; sufficient information to establish groundwaterflow direction; and a description of the on-site soils.Site-specific conditions may be defined through theuse of existing soil borings, test pits, or any otherMPCA-approved method. The level of detail will bedictated by the geologic complexity of the site.For re-permitting of existing facilities and thepermitting of new facilities, the need for ahydrogeologic evaluation will be based upon the datasubmitted in the Site Evaluation Report. The numberof borings in the hydrogeologic evaluation should besufficient to enable interpretations that reasonablyanticipate groundwater flow and pollutant migration.Acceptable WasteMinn. R. 7035.0300 provides the followingdefinitions:Subp. 30. Demolition debris. "Demolition debris"means solid waste resulting from the demolition ofbuildings, roads, and other structures includingconcrete, brick, bituminous concrete, untreated wood,masonry, glass, trees, rock, and plastic buildingparts. Demolition debris does not include asbestoswastes.Subp. 31. Demolition debris land disposal facility."Demolition debris land disposal facility" means asite used to dispose of demolition debris.Demolition Landfill GuidanceAugust 2005Minn. Stat. 115A.03 provides the followingdefinition:Subd. 7. Construction debris. "Construction debris"means waste building materials, packaging, andrubble resulting from construction, remodeling,repair, and demolition of buildings and roads.As can be seen by these definitions, demolition debrisis a much smaller subset of the larger overarchingcategory of construction debris. Therefore, thedemolition debris land disposal facility rules werewritten to address the proper disposal of this smalleruniverse of waste. This is verified by the discussionin the Statement of Need and Reasonableness(SONAR) for Minn. R. 7035.0300, subp. 30, “In thepast, unusable construction materials were includedin the definition of demolition debris. Constructionmaterials are waste supplies resulting from theconstruction, remodeling, and repair of buildings androads. This material will consist of waste paints,building putty, packaging, sealants, oils, etc. Thisdefinition is needed to clarify that construction wasteis not considered to be demolition debris and must behandled differently.”This separation of construction debris and demolitiondebris has been an issue between the MPCA andfacility owners/operators. Strict adherence andenforcement of these rules in the acceptance of wasteat demolition debris land disposal facilities has notbeen consistently implemented by MPCA staff.Owners/operators have expressed their concernregarding the ability to identify the origin ofmaterials. For example, how can one tell by lookingat a 2x4 whether it is coming from the demolition of astructure as compared to the construction orremodeling of a structure, or, for that matter, from anindustry, such as a cabinetmaker or mobile homemanufacturer? This has led to the evolution of amuch broader interpretation by staff andowner/operators as to what constitutes acceptablewaste for disposal at demolition landfills. During thePAGE 4

Municipal DivisionSolid Waste Section,last rule revision effort, the rule advisory committeecame to consensus on a revised definition for“construction and demolition (C&D) debris” whichincluded lists of materials as being acceptable as wellas unacceptable for disposal at demolition debris landdisposal facilities.For the purpose of implementation of this guidance,“construction and demolition (C&D) debris”means materials resulting from the alteration,construction, destruction, rehabilitation, or repair ofphysical structures, such as houses, buildings,industrial or commercial facilities, and roadways.This definition also includes wastes generated fromland-clearing activities.The MPCA has developed a list of C&D wastes thatmay be accepted by any demolition landfill which isreferred to as the “Acceptable C&D Waste List”:Acceptable C&D Waste List Bituminous concrete (includes asphaltpavement and blacktop)Concrete (including rerod)StoneUncontaminated soilMasonry (bricks, stucco and plaster)Untreated wood (including painted, stainedand/or varnished dimensional lumber,pallets, tree stumps, grubbing, root balls,particle board, plywood, fencing and dockmaterials)Siding (Includes vinyl, masonite, untreatedwood, aluminum and steel.)Wall coveringsElectrical wiring and componentsRoofing materialsDuct workWall board, sheet rockBuilt-in cabinetryPlumbing fixturesAffixed carpet and paddingCeramic itemsDemolition Landfill GuidanceAugust 2005 Conduit and pipesGlass (limited to window and door glassfrom buildings and structures)Insulation (Includes fiberglass, mineralwool, cellulose, polystyrene andnewspaper.)Plastic building partsSheathingMolded fiberglassRubberDrain tileRecognizable portions of burned structuresMetalCeiling tileWood and vinyl flooringAsbestos-containing materials (pursuant toan approved ISWMP)Class I demolition landfills will be limited to takingonly those C&D wastes listed above.Class II demolition landfills may take the C&Dwastes listed above, incidental nonrecyclablepackaging consisting of paper, cardboard and plastic,and limited demo-like industrial waste. Demo-likeindustrial waste accepted by Class II demolitionlandfills is limited in composition to wood, concrete,porcelain fixtures, shingles or window glass. Theseadditional waste types need to be identified in thefacility’s ISWMP.Class III demolition landfills may accept all C&Dwastes and most industrial wastes as defined by thefacility’s ISWMP.Waste ScreeningAll owners/operators need to establish a wastescreening area where incoming loads would first bedumped and sorted through to remove unacceptablematerials prior to pushing the waste into the workingPAGE 5

Municipal DivisionSolid Waste Section,face. Most Class I demolition landfills will not havegroundwater monitoring. Therefore, waste screeningand sorting at Class I demolition landfills will beparamount to ensuring that only acceptable materialsare disposed in them. Groundwater monitoring willbe conducted at all Class II demolition landfills;however, liners will not be required for most of thesefacilities. Therefore, waste screening is also animportant feature for Class II and III demolitionlandfills.August 2005existing facilities for conducting an analysis of wastescurrently accepted at the facility.All owners/operators need to submit an IndustrialSolid Waste Management Plan (ISWMP) pursuant to7035.2535 subp 5. If a demolition landfill isaccepting anything other than those wastes identifiedin the Acceptable C&D Waste List, theowner/operator needs to specifically identify thosewastes in the landfill’s ISWMP as required by Minn.R. 7035.2535, subp. 5. Item A(2) of this subpartrequires the ISWMP to include, but not be limited to,a procedure for evaluating waste characteristics,including the specific analyses that may be requiredfor specific wastes, and the criteria used to determinewhen analyses are necessary, the frequency of testing,and analytical methods to be used.The ISWMP shall include waste-acceptance criteriaand procedures for rejecting waste that does not meetthe acceptance criteria. Each facility is responsiblefor determining its own waste-acceptance criteria.For MSW landfills, which are required to havecomposite liners, the acceptance criterion is that thewaste passes the Toxicity Characteristic LeachProcedure (TCLP) test (i.e., that it not be a hazardouswaste). Since most of our demolition landfills do nothave liners, simply testing to determine whether awaste is hazardous or not does not provide adequateprotection of the environment. Therefore, the TCLPwould not be an appropriate acceptance criterion tobe used. In the past, facilities have proposed manydifferent acceptance criteria for use in their ISWMPs.Here are a few examples of the acceptance criteriathat have been approved previously: 50% (or some other fraction) of the hazardouswaste limits based on either TCLP or SyntheticPrecipitation Leach Procedure (SPLP) testing; 10 times (or some other multiplier) of the drinkingwater standards [Health Risk Limit (HRL) orMaximum Contaminant Level (MCL)]; Soil Reference Value (SRV) – residential orindustrial; and, Soil Leaching Value (SLV) – residential orindustrial.The frequency and number of samples required willdepend on the variability of the waste proposed foracceptance. For a new facility, the testing should becompleted before the waste is accepted so that thesecharacteristics may be factored into the design andmonitoring requirements for the facility. For existingfacilities, waste must be evaluated prior to acceptanceand at regular intervals throughout the life of thefacility, but at least during each re-permitting event,to determine the need for changes in the facility’sdesign or monitoring requirements. It may benecessary to establish a compliance schedule forThe proposed waste acceptance criteria must bejustified by the permitee, to verify that the site isadequately designed, located and monitored to acceptthe wastes proposed for disposal. If the best availableinformation and data indicate that the facility is notprotective of the environment, given the proposedwaste-acceptance criteria, the facility may be requiredto either lower its proposed waste-acceptance criteriaor change the facility design to ensure protection ofthe environment. This decision will be made on acase-by-case basis using the best available data andinformation. Input parameters would be included inBest management practices for waste screeningprocedures are provided in appendix B.Industrial Solid WasteManagement PlanDemolition Landfill GuidancePAGE 6

Municipal DivisionSolid Waste Section,the permit application along with the results of themodeling.If during the life of the facility, a new industry movesinto the area and asks a landfill to accept its wastes,the following decision matrix should help the landfilldecide whether it may take the waste.Industrial SolidWaste MatrixDo testresults ofthe wasteindicate thatit will meettheacceptancecriteriaidentified inthefacility’sISWMP?YesNoIs the waste identified in thefacility’s ISWMP as an acceptablematerial?YesNoIf facility would liketo accept waste, arevised ISWMP* mustOK tobe submitted to theacceptMPCA for review andwaste.approval prior toacceptance.Otherwise, DO NOTACCEPT WASTE.DO NOTACCEPDO NOT ACCEPTTWASTE.WASTE.*The MPCA will provide templates and forms to ease theprocess of writing and modifying ISWMPs.Groundwater MonitoringBased on the limited amount of groundwatermonitoring data collected from demolition landfills, ithas been noted that some demolition landfills doimpact groundwater quality. Based on discussionswith stakeholders, it was agreed that facilities thataccept only those materials identified on theAcceptable C&D Waste List risk to the environmentmay be minimal. However, there may be risk factorsthat would trigger the need for groundwatermonitoring at these facilities. Facilities that acceptwastes beyond the Acceptable C&D Waste List posea greater threat to the environment. Therefore, allClass II and III landfills should conduct groundwatermonitoring. For Class I landfills, the decisionDemolition Landfill GuidanceAugust erTableSoil TypeClaySiltSand5 feet ormoreNoYes orprovidejustificat

Demolition Landfill Guidance Water/Solid Waste #5.04, August 2005 Minnesota Pollution Control Agency, 520 Lafayette Rd. N., Saint Paul, MN 55155-4194 (651) 296-6300, toll-free (800) 657-3864, TTY (651) 282-5332 or (800) 657-3864 w-sw5-04 Solid Waste Program Background The State Solid Waste Rules allow the Minnesota Pollution Control Agency

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