Prepublication issue for EPA libraries
and State Solid Waste Management Agencies
CHEMICAL WASTE LAND DISPOSAL FACILITY
DEMONSTRATION GRANT APPLICATION
Tnis irttjsrirr, report (SW-8?d) on work to be performed
under solid ixiste management demonstration grant Xo. S803744
was prepared for the Minnesota Pollution Control Agency
Copies will be available from the
National Technical Information Service
U.S. Department of Commerce
Springfield, Virginia 22161
'j.S. ENVIRONMENTAL PROTECTION AGENCY
1975
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ABSTRACT
In June of 1975, the Office of Solid Waste Management Programs, U.S.
Environmental Protection Agency, awarded a five-year grant to the
Minnesota Pollution Control Agency, Division of Solid Waste, to
demonstrate land disposal techniques for potentially hazardous
chemical wastes. This document, prepared by Barr Engineering Co.,
represents the-demonstration approach as it was proposed in the
grantee's application. The application identifies and discusses:
work tasks, potential facility designs, personnel needs, budget
needs, contractor/consultant arrangements, implementation procedures,
evaluating and reporting procedures, and the existing regulatory
framework.
This initial document will be followed by a second interim report
at the end of the second project year (fall 1977) which will discuss
final site selection, final facility design, and environmental impact
analysis. A final report at the end of the demonstration period
(late 1980) will discuss final project results.
This report has been reviewed by the U.S. Environmental Protection Agency
and approved for publication. Approval does not signify that the contents
necessarily reflect the views and policies of the U.S. Environmental
Protection Agency, nor does mention of commercial products constitute
endorsement by the U.S. Government.
An environmental protection publication (SW-87d) in the solid waste
management series, prepared by the Barr Engineering Co., Minneapolis, Minn.
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TABLE OF CONTENTS
DESCRIPTION OF APPLICANT 1
BUDGET SUMMARY 3
MANDATORY REQUIREMENTS 6
5.1 Assurance of Continued Operation 6
5.2 Appropriate State Regulations 6
5.3 Elimination of Unacceptable Disposal Practices 7
5.4 Regulatons in Compliance with OSWMP Guidelines 7
5.5 Grant Operation and Management Requirements 7
EVALUATIVE CRITERIA 8
6.1 Nationwide Applicability 9
6.2 Statewide Needs 17
6.3 Site Selection 28
6.4 Disposal Area Preparation Techniques 36
6.5 Waste Preparation Techniques 46
6.6 Environmental Protection Strategies 53
6.7 Institutional Arrangements 62
6.8 Facility Management Strategy 80
6.9 Cost Accounting Strategy 102
6.10 Social Implications 114
6.11 Implementation Schedule 125
6.12 Project Budget and Funding Strategy 135
6.13 Potential Difficulties 143
SUMMARY OF MINNESOTA LAWS PERTAINING TO 146
HAZARDOUS WASTE MANAGEMENT
CASE STUDIES OF IMPROPER CHEMICAL WASTE 175
MANAGEMENT
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DESCRIPTION OF APPLICANT
The Minnesota Pollution Control Agency (applicant) is the principal state environ-
mental protection advocate within Minnesota. The Agency is an independent unit of
state government consisting of nine citizen members appointed by the Governor and an
Executive Director also appointed by the Governor. The Executive Director oversees
an Agency Staff of approximately 235 employees with expertise in air, water and land
resource protection. Under Minnesota Law, the Pollution Control Agency is empowered
to:
a) administer and enforce all state laws relating to pollution,
b) investigate instances of pollution of the air, water and land resources
of the state,
c) establish pollution control standards and regulations, and
d) regulate the disposal of all wastes which may pollute the environment.
Hazardous waste regulation is administered through the Air, Water and Solid
Waste Divisions of the Agency. Under Minnesota Statutes Chapter 116.1, the Agency is
charged with "achieving a reasonable degree of purity of water, air and land resources
of the state, consistent with the maximum enjoyment and use therefore in furtherance
of the welfare of the people of the state". To carry out this responsibility,
the applicant is presently regulating hazardous waste in the following manner:
Hazardous wastes discharged directly to public waters are regulated through
effluent standards and stream standards established for all public waters of
the state. Waste dischargers must obtain an NPDES permit from the Agency
which sets forth the allowable waste discharge requirements. In a similar
fashion, hazardous wastes discharged directly to the atmosphere are controlled
by emission and ambient air quality standards. Dischargers must obtain a
permit from the Agency to discharge waste to the atmosphere. The permit sets
forth the allowable waste concentrations in the emission.
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0 Hazardous Waste Regulations are in the process of being drafted by the applicant
When adopted, these Regulations will establish performance and procedural
standards for hazardous waste identification,, labeling, classification, stor-
age, collection, transportation, treatment .and disposal. In addition, the
regulations will provide a detailed definition of "hazardous waste".
The Solid Waste Rules and Regulations of the Pollution Control Agency regu-
late hazardous wastes as they relate to disposal at sanitary landfills. The
Rules and Regulations also establish standards for hazardous waste storage,
collection, transportation and incineration. Standards in the Solid Waste
Rules and Regulations which relate to hazardous waste will be included in
the Hazardous Waste Regulations. The present Solid Waste Rules and Regulations
prohibit the land disposal of hazardous waste at sanitary landfills. Sani-
tary landfills, however, must provide hazardous waste storage areas to tempor-
arily store hazardous waste transported to the sanitary landfills. On-land
hazardous waste disposal facilities permitted under former solid waste regu-
lations have been discontinued.
Hazardous waste incinerators must obtain a solid waste facility permit from
the Pollution Control Agency. Hazardous waste incinerators must meet the
Pollution Control Agency air quality regulations and obtain air emissions
permits. If incinerators utilize equipment creating a liquid effluent, a
waste disposal system permit must be obtained.
Minnesota's water pollution control regulations regulate the storage of oil
and other liquid substances capable of polluting the waters of the state.
The regulations require that all areas used to store oil and other liquid
substances have an impervious bottom and be enclosed with continuous dikes.
A permit must be obtained from the Pollution Control Agency to operate a
site storing oil or other liquid substances capable of polluting the waters of
the state.
As discussed in Section 6.2 of this Supplemental Information, a chemical waste-
land disposal facility is needed in Minnesota to insure the effective operation of
its hazardous waste management program. The demonstration grant is not only consis-
tent with Minnesota's hazardous waste management efforts, but is a critical component
of the state hazardous waste management program.
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BUDGET SUMMARY
This section of the demonstration grant summarizes the detailed demonstration
budgets included in Section 6.12. Additional budget information is available in
Section 6.12.
3.1 FIRST YEAR OF DEMONSTRATION PERIOD
First Quarter Second Quarter Third Quarter Fourth Quarter
Total EPA Total EPA Total EPA Total EPA
Personnel
Fringe
Benefits
Travel
Equipment
Supplies
Contractual
Personnel
Services
Construction
Other
$ 8,150
1,222
500
3,100
200
__
6,800
$ 6,112
917
375
2,325
150
_«
5,100
$12,300
1,845
500
200
5,000
4,100
$ 9,225
1,384
375
150
3,750
3,075
$ 15,350
2,303
300
200
50,000
50,000
3,400
$11,512
1,728
225
150
37,500
37,500
2,550
$ 15,300
2,295
390
290
70,000
300,000
4,900
$ 11,475
1,721
292
218
52,500
225,000
3,675
TOTALS $19,972 $14,979 $23,945 $17,959 $121,553 $91,165 $393,175 $294,881
3.2 TOTAL DEMONSTRATION PERIOD (Projected Budgets)
The projected budgets for the total five-year demonstration period are summarized
on page 3-2. Additional demonstration period budget data is included in Section
6.12.
3.3 FUNDING SOURCES
The funding sources and projected funding amounts are summarized on page 3-3.
Additional funding data is included in Section 6.12.
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PROJECTED BUDGETS TOTAL DEMONSTRATION PERIOD
First Year Second Year Third Year Fourth Year Fifth Year
Total EPA Total EPA Total EPA Total EPA Total EPA
Personnel
Fringe
Benefits
Travel
Equipment
Supplies
Contractual
Personnel
Services
Construction
Other
$ 51,100
7,665
1,690
3,100
890
125,000
350,000
19,200
$ 38,325 $
5,749
1,268
2,325
667
93,750
262,500
14,400
62,945 $
9,442
1,860
760,000
1,350
250,000
590,000
30,000
47,209
7,082
1,394
570,000
1,013
187,500
442,500
22,500
$ 72,632
10,895
2,570
320,000
1,400
245,000
1,696,000
25,000
$ 53,327
7,999
1,887
234,944
1,028
179,879
1,245,204
18,355
$ 61,560
9,234
2,020
20,000
1,400
210,000
50,000
16,000
$, 27,463
4,119
901
8,922
626
93,686
22,306
7,138
$ 63,210
9,482
2,020
50,000
1,400
230,000
30,000
16 , 000
$ 17,933
2,690
573
14,186
398
65,254
8,511
4,539
TOTALS $558,645 $418,984 $1,705,597 $1,279,198 $2,373,497 $1,742,623 $370,214 $165,161 $402,112 $114,084
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FUNDING SOURCES
SUMMARY OF YEARS
First Year
Second Year
Third Year
Fourth Year
Fifth Year
TOTALS
FEDERAL
$ 418,984
1,279,198
1,742,623
165,161
114.084
$3,720,050
NONFEDERAL*
$ 139
426
580
55
38
$1,240
,661
,399
,874
,053
,028
,015
USER FEES
$
50,000
150,000
250.000
$450,000
TOTAL
$ 558,645
1,705,597
2,373,'497
370,214
402,112
$5,410,065
* County or Metropolitan Waste Control Commission revenue bonds.
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MANDATORY REQUIREMENTS
5.1 ASSURANCE OF CONTINUED OPERATION
The applicant assures that acceptable operations will be continued beyond the
grant period through a system of user's fees to recover the full cost of the
facility. As set forth in the legal memorandum in Appendix I, the applicant
has the authority to* contract with an intermediate governmental agency to
operate the facility. Intermediate governmental agencies identified in Section
6.7.2 have the authority to collect user fees to support the facility from the
beginning of operation. The user fees will not be reduced by the amount of the
Federal grant during the grant period. As set forth in the cost accounting
strategies outlined in Section 6.9 of .this grant application, the facility
user fees will be sufficient to recover capital expenditures over the life of
the operation, all operating and maintenance costs as well as the cost of closing
and perpetually monitoring the facility. The applicant intends to structure the
user fees to represent the true cost of the environmentally safe land disposal
of chemical wastes.
5.2 APPROPRIATE STATE REGULATIONS
The Minnesota Solid Waste Rules and Regulations are included in Appendix B of
this application. These rules and regulations regulate the disposal of solid
waste as well as hazardous waste in Minnesota. Statewide hazardous waste
regulations are presently being drafted. The hazardous waste regulations will
establish performance and procedural standards for hazardous waste identification,
labeling, classification, storage, collection, transportation, treatment and
disposal. The portions of the Solid Waste Rules and Regulations pertaining
to hazardous waste management will be included in the hazardous waste regulations
when they are adopted. The applicant will continue to enforce the Solid
Waste Rules and Regulations within Minnesota and will enforce the hazardous
waste regulations when they are adopted.
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5.3 ELIMINATION OF UNACCEPTABLE DISPOSAL PRACTICES
Such unacceptable waste disposal practices as -open burning, unregulated land
disposal and uncontrolled dumping have been eliminated by legislation and
by subsequent regulations within Minnesota. The legislation authorizing the
elimination of unacceptable disposal practices will be furnished if necessary.
The regulations mandating the elimination of unacceptable waste disposal
practices are included in Appendix B.
5.4 REGULATIONS IN COMPLIANCE WITH OSWMP GUIDELINES
The Solid Waste-Rules and Regulations are in conformance with OSWMP recommended
guidelines and practices. The applicant is working closely with the Environ-
mental Protection Agency to insure that the statewide hazardous waste regulations
are also in conformance with OSWMP guidelines. The applicant has received other
demonstration grants from the Environmental Protection Agency Office of Solid
Waste Management Program. The Solid Waste Rules and Regulations are uniform
within the applicant's'jurisdiction.
5.5 GRANT OPERATION AND MANAGEMENT REQUIREMENTS
The education and experience of the grant management personnel are summarized
in Appendix F. As shown in Appendix F, personnel on the grant management
team have administered a number of solid waste grants. The applicant agrees
to submit status, and evaluative reports quarterly on technical, economic and
social/institutional aspects of the demonstration project. The applicant
also agrees to carry out an annual project audit. In addition, interim
reports will be completed on certain key project elements as key demonstration
milestones are reached.
As set forth in Section 6.7.2, the site owner and operator have not been
selected due to time constraints and due to the possibility of legislative
changes in the metropolitan area- solid and hazardous waste operating responsi-
bilities.
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EVALUATIVE CRITERIA
The Evaluative Criteria Section of the demonstration grant application outlines
the methods of .approach the applicant intends to follow in selecting the various
technical, economic and social/institutional techniques that will be needed to
establish and operate the chemical waste land disposal demonstration facility.
The sections have been arranged in the approximate order outlined in the Evaluative
Criteria Section of the Requirements and Criteria for the Chemical Waste Land
Disposal Grant as distributed by the Environmental Protection Agency.
Section 6.1 discusses the reasons the applicant believes that results from a
chemical waste land disposal demonstration project located in Minnesota will be
applicable anywhere in the United States. Section 6.2 discusses the statewide
need for a chemical waste land disposal facility and illustrates why the location
of the demonstration project in Minnesota will not only serve a nationwide need,
but will help solve a critical statewide need as well. The various site selection
criteria, alternative sites, for
the demonstration project are discussed in Section 6.3. Section 6.4 discusses
the various disposal site preparation techniques such as bottom liners, rainfall
percolation sealants, leachate collection and recirculation/treatment systems and
waste placement techniques that will be evaluated for incorporation into the
project. The ability of the various techniques to contain the wastes will, of
course, be a critical part of the disposal site preparation demonstration. In
a similar fashion, Section 6.5 discusses the various waste preparation techniques
that will be evaluated for use in the demonstration project. The primary purpose
of the waste preparation techniques will be to supply wastes with a wide range of
characteristics for demonstration purposes.
The "second level" of environmental protection facilities to be provided
at the eventual disposal site are discussed in Section 6.6. The "first level"
of environmental protection facilities are the liners, sealants and leachate
collection systems discussed in Section 6.4. Due to the nature of the demon-
stration project, however, the applicant recognizes that certain demonstrations
may not be completely successful and for this reason a second waste barrier/
leachate collection system as well as a series of barrier wells, surface
runoff storage areas, and air contaminant control facilities will be utilized
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to provide a second level of environmental protection. The first and second
levels of environmental protection plus the site selection criteria have all
been carefully designed to insure -an environmentally fail-safe operation.
Sections 6.7, 6.8 and 6.9 discuss the institutional arrangements, facility
operation and management strategies and cost accounting strategies that will be
evaluated for incorporation into the demonstration project. Section 6.10 discusses
the various social aspects of the project and the strategies that the applicant
will use to gain citizen acceptance and encourage educational use of the project.
Section 6.11 and 6.12 set forth the implementation schedule, project budgets and
funding sources. Section 6.'13 discusses the potential difficulties the applicant
foresees in establishing the demonstration project in Minnesota and outlines
strategies to overcome these potential difficulties.
The applicant believes that the detailed technical, economic and social/
institutional strategies presented in'this section of the grant application illustrate
the competitive advantage that Minnesota enjoys over other areas of the country
in meeting the evaluative criteria set forth in the Requirements and Criteria for
the Demonstration Grant.
6.1 NATIONWIDE APPLICABILITY OF RESULTS
A number of features unique to Minnesota insure that the chemical waste land
disposal demonstration project will generate significant conclusions having
general applicability to chemical waste management problems in other areas
of the country. The features which insure the nationwide applicability of
data generated in Minnesota include:
a The Existence of Comprehensive Hazardous Waste Regulatory Legislation
A High Degree of Citizen Participation in Decision Making
Diverse Industry Producing a Wide Variety of Chemical Wastes
A High Level of Industrial Awareness
e Good Road and Rail Access
Extreme Climatological Conditions
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6.1.1 The Existence of Comprehensive Hazardous Waste Regulatory Legislation
The existing hazardous waste legislative/regulatory atmosphere in
Minnesota is presently well-suited to insure the immediate and long-
term use of the chemical waste land disposal facility. Minnesota was
one of the first states to realize the need for hazardous waste reg-
ulation. Early solid waste regulations adapted in 1970 attempted
to define "toxic and hazardous waste" and set aside special disposal
areas in sanitary landfills. This philosophy has since been abandoned,
however, it'does point out that the applicant has been working
with hazardous waste disposal for over five years. A report entitled,
"Hazardous Waste GenerationTwin Cities Metropolitan Area" has recently
been completed for the applicant and for the counties in the Minneapolis/
St. Paul metropolitan area of Minnesota. ' The study identified the
quantities of various categories of hazardous waste generated in the
metropolitan area, documented that a large portion of the generated
waste was being disposed of in an unknown and, therefore, unregulated
manner and recommended a hazardous waste regulatory system to combat
the problem. The framework for the recommended hazardous waste
regulatory system included a hazardous waste generator licensing
system and a hazardous waste transportation licensing system. The
hazardous waste treatment/disposal facility permit system presently
being administered by the applicant and by the counties was found to
be generally adequate. The recommendations of the study are presently
being implemented through enabling legislation adopted by the 1974
Minnesota Legislature.
A copy of the State hazardous waste legislation is included in Appendix
A of this grant application. As a result of that legislation, the
applicant:
a) must adopt standards relating to identification, labeling, class-
ification, storage, collection, transportation and disposal of
hazardous waste.
Footnotes refer to references listed in the Reference Section of this application.
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b) must issue or deny permits for labeling, classification, storage
and collection of hazardous waste (in the absence of a county
generator licensing system).
c) may issue or deny permits for the treatment and/or disposal of
hazardous waste.
In addition to the applicant's responsibilities, the legislation
enpowered countieg throughout Minnesota to:
a) by ordinance establish rules, regulations and standards relating
to the identification, labeling, handling, collection, trans-
portation, storage and disposal of hazardous waste (this respon-
sibility is mandatory for counties in the Minneapolis/St. Paul
metropolitan area).
b) issue licenses to hazardous waste generators and charge a license
fee to pay for costs incurred by the county in the generator
licensing program (this responsibility is also mandatory for
counties in the Minneapolis/St. Paul metropolitan area).
Existing solid waste, air quality and water quality legislation is
now sufficient to enable the applicant to regulate hazardous waste
management statewide and to implement the demonstration chemical
waste land disposal facility. At the time of this grant application,
the applicant has drafted hazardous waste regulations to implement
the new legislation. The counties in the Minneapolis/St. Paul metro-
politan area have drafted a model hazardous waste ordinance to implement
the new hazardous waste legislation at the county level. A copy of
the draft hazardous waste model ordinance is included in Appendix C
of this grant application.
In summary, the applicant believes that the hazardous waste legislation/
regulatory atmosphere in Minnesota is ideally suited to the implementation
of the demonstration project. The generator licensing system now
being implemented in the metropolitan area will insure that all
hazardous waste sources are identified and required to transport their
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hazardous wastes to a regulated disposal facility. Thus, a supply
of all types of hazardous waste generated in the area is guaranteed
to the demonstration facility. The generator licensing system also
gives the applicant and the counties a means to predict and even
manage the flow of hazardous wastes in the metropolitan area.
6.1.2 A High Degree of Citizen Participation in Decision Making
Minnesota cifizens are well-known for a high degree of concern for a
quality environment. Various citizen groups have lobbied for and
helped pass a large volume of environmental protection legislation
including an Environmental Rights Act giving citizens the right to
initiate lawsuits to enforce environmental regulations, environmental
impact legislation which mandates the preparation of environmental
assessments and environmental impact statements for projects of more
than local environmental significance and a Critical Areas Act which
sets forth procedures to protect identified areas in the state possessing
values of greater than local significance. As a result of these
efforts and as a result of a number of judicial actions such as the
Reserve Mining Co. discharge to Lake Superior and potential mining
and timber cutting in the Boundary Waters Canoe Area, the various
citizen groups are well-organized with identifiable spokesmen. The
high level of citizen interest in environmental matters and the well-
organized nature of the various citizen groups will enable the various
strategies for gaining citizen acceptance of the demonstration facility
to generate significant conclusions applicable on a nationwide basis.
6.1.3 Diverse Industry Producing a Wide Range of Chemical Wastes
The recently completed study of hazardous waste generation in the
Minneapolis/St. Paul metropolitan area illustrated the diverse industry
and wide range of chemical waste produced in the area. The following
table briefly summarizes the number of industries in Minnesota within
the key industrial groups outlined in the grant applicant request.
Detailed information on quantities and categories of hazardous waste
generated by the various industries in the metropolitan area is
included in Section 6.2.1.
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SUMMARY OF KEY INDUSTRIES IN MINNESOTA
SIC
2815
2816
2819
2821
3011
3069
2851
2861
2879
2892
2911
3111
3312
3313
3315
3317
3321
3322
3323
3341
3351
3352
3356
3357
3361
3362
3369
3391
3392
3399
Products
Textile Products
Number of Industries
in Minnesota
37
Industrial Inorganic Chemicals
Rubber and Plastics
Pharmaceuti cals
Paint and Allied Products
Organic Chemicals
Agricultural Chemicals
Explosives
Petroleum Refining
Leather Tanning
Primary Metals
16
32
38
2
22
6
3
2
136
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SUMMARY OF KEY INDUSTRIES IN MINNESOTA (cont.)
Number of Industries
Products in Minnesota
Plating and Polishing 4
Machinery, Except Electrical 201
3691 Battery Manufacturing 7
As summarized in the preceding table, Minnesota is a major planting
and metal finishing center (aluminum anodizing, cadmium, chrome,
nickel, zinc and copper plating, cyanide complexing). The area also
has several paint manufacturers (water and solvent base) and battery
manufacturers including one of the few manufacturers of nickel-cadmium ,
batteries in the United States. The state has three oil refineries
with two located in the Minneapolis/St. Paul metropolitan area. The
area is also a major center for the printed circuit industry.
Various mining companies are beginning to seek the necessary state
and Federal permits to extract the large copper/nickel reserves in
Minnesota. While it is doubtful that these ventures will be generating
waste products during the life of the demonstration grant, it is
likely that potentially hazardous waste products from smelting and
refining of copper/nickel ores may be generated in Minnesota during
the expected life of the chemical waste land disposal facility. Copper
mining and benefaction is presently occurring in northern Michigan
(approximately 250 miles from the Minneapolis/St. Paul metropolitan
area). If awarded the demonstration grant, the applicant will cooperate
with the State of Michigan and with the White Pine Copper Company to
obtain a limited quantity of cooper benefication waste for use in
the demonstration project.
Wood preservatives (pentachlorophenols) are the only organic chemical
(SIC 286) known to be manufactured in Minnesota. Many industries,
however, use various organic chemicals in their industrial processes
and, therefore, organic chemicals are included in the hazardous waste
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stream. The applicant anticipates no problems in securing sufficient
waste organic chemicals for study purposes.
There are no known pharmaceutical manufacturers in Minnesota, however,
pharmaceutical formulators and, of course, users do exist. Formulators
and users (such as hospitals, clinics, etc.) represent the applicant's
source of pharmaceutical waste at this time. If awarded the demonstration
grant, the applicant will contact the large pharmaceutical manufacturers
to obtain a limited quantity of pharmaceutical manufacturing waste
for use in the demonstration project.
In summary, the Minneapolis/St. Paul area has diverse industry producing
a wide variety of candidate wastes for a chemical waste land disposal
facility. The applicant is confident that limited quantities of the
few wastes which may be in short supply can be obtained within a
reasonable distance. Although hazardous waste incineration facilities
are available in the state, a sufficient supply of flammable wastes
will be diverted to the demonstration facility for demonstration purposes.
Also important is the fact that the Minneapolis/St. Paul area, as a
major industrial center, does not exhibit the very complex waste
generation characteristics symbolic.of the "industrial mega-centers"
in the eastern portion of the United States. . The applicant believes
the relatively isolated nature of the-Minneapolis/St. Paul area as
an industrial center represents an advantage. The geographical
separation of the Minneapolis/St. Paul area from other waste generation
centers make the evalution of the economic and social factors associated
with the demonstration land disposal facility easier to evaluate and
the supply of wastes easier to guarantee.
6.1.4 A High Level of Industrial Awareness
Minnesota industries have generally recognized the importance of good
environmental management and have been willing to cooperate with the
various regulatory agencies to seek solutions to waste disposal problems.
Industries in Minnesota have demonstrated an awareness of hazardous
waste disposal and have been supportive of the applicant's efforts to
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implement the various hazardous waste management programs. The
state's,largest industrial association, the Minnesota Associate of
Commerce and Industry, has been working closely with the applicant and
with the metropolitan area counties during the development and imple-
mentation of the various hazardous waste studies and programs including
this grant application. The Minnesota Association of Commerce and
Industry, along with various environmental groups, supported the
applicant's hazardous waste legislation in the 1974 session of the
Minnesota Legislature. If selected for the demonstration project,
the Environmental Protection Agency and the applicant can expect a
high degree of cooperation from the area's industries.
6.1.5 Good Road and Rail Access
The Minneapolis/St. Paul metropolitan area is served by excellent
road, rail and barge systems. The good access to the area represents
an opportunity to safely transport chemical wastes to this area from
other portions of Minnesota. North-south and east-west interstate
freeways and railway systems intersect in the Minneapolis/St. Paul
area. The area is the northwestern terminal of the inland waterway
system, and a number of barge terminals exist on the Mississippi,
Minnesota and St. Croix Rivers. Minnesota is also reasonably centrally
located within the country from east to west. This provides reasonable
access to the area from any part of the country to view the facility.
6.1.6 Extreme Climatological Conditions
The Minneapolis/St. Paul area is "blessed" with extreme Climatological
conditions sufficient to provide data on the operation of a chemical
waste land disposal facility applicable to most other areas of the
country. The area is characterized by generally mild, subhumid summers
and relatively long severe winters. Temperatures at St. Paul, for
example, ranged from -34°F in January, 1936 and 1970, to 108°F in
July, 1936. Monthly precipitation ranged from a trace in December,
1943 to 8.03 inches in May, 1962. Abrupt changes in temperature and
precipitation are common.
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The winter weather will enable the various construction and operation
demonstrations to be conducted under severe conditions. Working with
synthetic liners and placing wastes in the disposal area are but
two of the demonstration processes which will require different
techniques and, therefore, exhibit different unit costs during cold
weather operation.
The hydrological conditions in the Minneapolis/St. Paul area are
sufficient to generate leachate at the demonstration facility. The
applicant is responsible for reviewing .ground water monitoring data
from a number of sanitary landfills in the area and the data indicates
that leachate is generated. Average annual precipitation in the
(2)
Minneapolis/St. Paul area is 28.3 inches. Average annual evapo-
transpiration (actual) has been computed to be approximately 23 inches
and average annual evapotranspiration (potential) has been computed
(2)
to be approximately 24 inches. The gross water balance, therefore,
indicates that on the average, approximately 5 inches of water per
year will be available for leachate production, assuming a plant cover
over the land disposal facility. Transpiration from plants during
the growing season (May-September) represents approximately 9 inches
of the 24 inches of annual potential evapotranspiration. Therefore,
in areas of the land disposal facility without plant cover, as much
as 14 inches of available water per year can be expected to be generated '
for leachate production. The amount of water available for leachate
production can be adjusted in this area by adding or removing snow
as well as vegetation from the surface of the disposal facility.
Artificial rainmaking facilities will also be provided over a portion
of the facility to simulate extreme conditions which could occur in the
Minneapolis/St. Paul area, (as well as other areas of the country),
but which might not occur during the demonstration period.
6.2 STATEWIDE NEED FOR A CHEMICAL WASTE LAND DISPOSAL FACILITY
The applicant believes that the State of Minnesota is ahead of the rest of
the country in regulating and managing hazardous waste. As discussed previously,
counties in the Minneapolis/St. Paul metropolitan area are implementing a
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program to license hazardous waste generators. After Implementation of this
regulatory program, generators will be required to obtain licenses from the
appropriate county before moving hazardous wastes from their property.
Industrial waste discharge pretreatment regulations are being promolgated by
the Metropolitan Waste Control Commission which is the regional sanitary sewer
authority in the Minneapolis/St. Paul metropolitan area. These regulations
will limit the discharge of various hazardous wastes to the regional sewer
system, thereby increasing the pressure on other disposal facilities. Thus,
large quantities of hazardous wastes will be generated and identified and
proper disposal facilities must be available if the overall hazardous waste
management program is to work. As brought out in this section of the
application, Minnesota needs a land disposal facility of the type envisioned
in the demonstration project. The location of the facility in Minnesota will,
therefore, not only satisfy a nationwide need, but will also alleviate a
critical statewide need.
6.2.1 Area-wide Hazardous Waste Generation
Hazardous waste generation in the Minneapolis/St. Paul metropolitan
area was quantified in a recent study completed for the metropolitan
counties and for the applicant. The quantities of hazardous
wastes produced by various generators are summarized on page 6-12.
As shown on page 6-12, approximately 38,000 tons of hazardous waste
(non-oil) are generated annually in the metropolitan area. Of that
total, approximately 27,000 tons/year are presently discharged to the
sanitary sewer systems and 11,000 tons/year are disposed of using
non-sewer facilities (incinerated, recycled, stored, illegally landfilled)
Of the 11,000 tons/year of hazardous wastes disposed of through non-
sewer routes, approximately 3,000 tons/year can be identified as being
disposed of at regulated facilities. Thus, an estimated 8,000 tons/
year of potentially hazardous wastes are presently being disposed of
in an unregulated and, therefore, potentially unsafe manner.
The investigation of hazardous waste management indicated a general
lack of effectiveness in the hazardous waste control system existing
at the time of the study. This was caused by a combination of
18
-------
POTENTIALLY HAZARDOUS WASTES GENERATED IN THE STUDY AREA
ANNUAL GENERATION
SIC
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POTENTIALLY HAZARDOUS WASTES NON- OIL
FLAMMABLES
10TALILBS)
312.000
7,1,000
7.100
21.000
JS.JOO
430.000
J1.600
17I.KOO
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'328.800
l.j$0.000
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1.0.000
18.000
27.000
18.000
13.000
1.000
91. MM
7.500
26.300
192.000
1. 510.000
21, Wl
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291.000
703.100
S, 341. 000
267.100
1,520,000
1.100
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650.000
41.000
1,710,000
1 51. 000
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6.800
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1.194.000
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196.000
30^200
117,000
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100
100
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29.000
ii,«20
56.000
2(.]00
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6,800
73.000
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3,500
1.000
1,000
1,000
3,000
14,000
21.000
4^,800
135.000
16.000
42Jj600
376.000
251,800
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604.000
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159.000
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1.000
8.000
40.000
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106,000
139,000
.13,000
135.000
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113,000
214.800
1. 380,000
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120,400
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5,172,100
336,830
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70,200
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7,399,000
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unknown
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19
-------
circumstances including the lack of a specific definition of the term
hazardous waste and a lack of adequate hazardous waste disposal facilities.
Case studies were documented illustrating that public health and the
environment were being threatened by the uncontrolled disposal of
potentially hazardous waste. Typical Minnesota case studies are
included in Appendix G of this application. As standards and regulations
begin to decrease the availability of water and air as disposal media,
hazardous waste generators can be expected to turn increasingly to
land disposal as a means of solving their hazardous waste problems.
The study concluded that problems associated with the disposal of
hazardous waste could be expected to increase in the future if an
effective hazardous waste management program was not implemented.
6.2.2 State Hazardous Waste Management Program
Legislation to implement the recommendations of the hazardous waste
generation report was passed by the 1974 session of the Minnesota
Legislature. The new legislation along with the previously existing
legislation is now sufficient to regulate the classification, trans-
portation, storage, treatment and disposal of hazardous waste on a
statewide basis. Legislation applicable to the statewide hazardous
waste regulatory program is included in Appendix A of this grant
application. The legislation will lead to the following regulatory
agency responsibilities:
a) County or Multi-County Agencies
i) Prepare a county or multi-county hazardous waste management
plan. The plan could be an amendment to the existing solid
waste management plan and will include an identification of
potential generators, categories and quantities of hazardous
waste generated within the county planning area and procedures
for accident notification consistent with the Statewide
Hazardous Spill Contingency Plan.
20
-------
ii) Adopt ordinances relative to hazardous waste, generation,
licenses and license fees; hazardous was.te classification,
labeling, transportation, and treatment/disposal facilities
consistent with hazardous waste regulations, model ordinances
and guidelines prepared by the applicant. The ordinances
could be amendments to the existing county solid waste
ordinances.
iii) Review and issue hazardous waste generator licenses to
generator's of hazardous waste. Enforce conditions of the
license relative to classification, safe handling, labeling,
transportation, on-site storage and safety requirements
using the enforcement powers of the ordinance. Distribute
license applications and hazardous waste container labels
to generators. Answer routine questions regarding the
hazardous waste management program relative to classification,
labeling and management responsibilities. Collect hazardous
waste generator license fees to cover the county administrative
costs associated with administering the generator licensing
program.
iv) Review and issue licenses for hazardous waste treatment/
disposal facilities in the same manner that county sanitary
landfill licenses are presently issued. Enforce conditions
of the license using the enforcement powers of the ordinance.
v) Trace improperly labeled, but potentially hazardous waste
arriving at approved or nonapproved treatment/disposal
facilities.
vi) Conduct an annual inventory of the quantities and categories
of hazardous waste generated in each county planning area.
Transmit this information semi-annually to the applicant
and to the appropriate regional planning agency.
21
-------
b) Regional Planning Agency
i) Review and approve county hazardous waste plans, ordinances
and licensing procedures.
ii) Prepare a Regional Hazardous Waste Management Plan including
the designation of the hazardous waste treatment/disposal
facilities to serve the region.
iii) Prepare an annual inventory of the quantities, categories
and disposal locations of hazardous waste generated in the
region.
c) State - Pollution Control Agency (Applicant)
i) Review and approve county and regional hazardous waste
management plans, ordinances, licensing procedures and
inventories.
ii) Develop a Statewide Hazardous Waste Management Plan detailing
the location of hazardous waste treatment/disposal facilities
and temporary storage sites throughout the state and the
need for interstate transportation of hazardous waste.
The Statewide Hazardous Spill Contingency Plan will also be
integrated into the State Hazardous Waste Management Plan.
iii) Promulgate statewide hazardous waste regulations concerning
the classification, labeling, temporary storage, collection,
handling, transportation, treatment and disposal of hazardous
wastes. Develop guidelines detailing the specific selection
criteria to be used to identify hazardous wastes and develop
model ordinances for use by the counties.
iv) Print and distribute waste generator license applications to
potential hazardous waste generators. Receive the completed
application, check the information for completeness and
22
-------
distribute the appropriate portions>of the application to
the county hazardous waste generator licensing agency and
to the regional or local sanitary sewer agency (if applicable)
v) Review the waste generator licenses before issuance by the
county generator licensing agency and exercise veto power
if the license violates State Hazardous Waste Regulations.
Depending on staff limitations, the state may only .review
hazardous waste generator licenses from major generators.
vi) Assist the .counties in answering routine questions regarding
the hazardous waste management program. Answer non-routine
questions regarding the hazardous waste management program
and the .classification of various wastes as hazardous or
nonhazardous. Incorporate .training courses relating to
hazardous waste classification, labeling, handling, storage,
and transportation into, the overall solid waste operator
training program.
vii) Issue hazardous waste treatment/disposal site facility
permits,, review and periodically check the monitoring
results supplied by the hazardous waste treatment/disposal
facilities regarding the quality of effluents released to
the environment and enforce other conditions of the permits
relative to handling, storage, treatment and disposal
of hazardous waste at the treatment/disposal facility.
viii) Conduct an annual inventory of hazardous waste quantities
generated throughout the state.
d) State - Public Service Commission
1) Incorporate a hazardous waste transportation licensing system
into the existing hazardous materials transportation
licensing procedures using the technical assistance of the
applicant and the Federal Department of Transportation.
23
-------
ii) Enforce the hazardous waste transportation license through
existing Public Service Commission transportation enforce-
ment procedures.
e) State - Department of Administration
Print and sell hazardous waste labels to generators and to the
county licensing agencies. This will insure uniformity in hazardous
waste labeling.
At the time of this grant application, the multi-county joint power agency in
the Minneapolis/St. Paul metropolitan area has prepared a model county hazardous
waste regulation ordinance (Appendix C) and is in the process of preparing a
multi-county hazardous waste management plan. The regional planning agency has
adopted interim hazardous waste management policies for incorporation into the
regional solid waste management plan. Th>2 applicant has requested consultant
proposals for developing a Statewide Hazardous Waste Management Plan and has prepared
a draft of the State Hazardous Waste Regulations. After adoption of the county
hazardous waste ordinances by the counties and the State Hazardous Waste Regulations
by the applicant, the counties will begin issuing hazardous waste generator licenses
and the hazardous waste management program will be underway in the metropolitan area
and eventually statewide.
6.2.3 Existing Hazardous Waste Management Facilities
At the present time, there are four known hazardous waste disposal
facilities (non-radioactive wastes) serving Minnesota. Two of the
facilities are located within the Minneapolis/St. Paul metropolitan
area and are regulated by the applicant. The other two are out-of-
state facilities known to collect hazardous waste from Minnesota.
The existing facilities are summarized in the following paragraphs. The
estimated quantities of hazardous waste deposited at these facilities
between September 1, 1972 and August 31, 1973, are summarized on page 6-19.
a) Pollution Controls, Inc. - Scott County - Pollution Controls,
Inc. operates a hazardous waste incinerator with a reported
capacity of 12,000,000 gallons/year (60,000 tons/year at 10 Ibs./
24
-------
gallon). The facility has air, water and solid waste permits from
the applicant, and .a solid waste license from Scott'County. The
facility has been in continuous operation since 1971.
b) Minnesota Mining and Manufacturing Co. - Washington County -
Minnesota Mining and Manufacturing Co. owns and operates an incin-
erator. The incinerator is regulated- by air, water and solid
waste permits from the applicant and by a solid waste license from
Washington County. The facility is used only to dispose of waste
generated by Minnesota Mining and Manufacturing Co. and is not
»
available for use by other generators. Data regarding the generation
and disposal of hazardous waste at the Minnesota Mining and
Manufacturing Co. incinerator is not available for publication.
c) Waste Research and Reclamation Co., Inc. - Eau Claire, Wisconsin -
Waste Research and Reclamation Co., Inc. recycles solvents, oils
and forging compounds. The estimated volume of hazardous waste
transported out of the study area by Waste Research and Reclamation
Co., Inc. was estimated using data collected by an industrial waste
survey and by direct communication with the staff of Waste Research
and Reclamation Co., Inc.
d) Conversion Chemical Corporation - Gary, Indiana - Conversion
Chemical Corporation transports contaminated acids from the printed
circuit industry out of the Minneapolis/St. Paul metropolitan area.
The estimated volume of acid wastes transported out of the study
area by Conversion Chemical Corporation was obtained through direct
communications with the staff of.Conversion Chemical Corporation.
In addition to the four disposal facilities currently disposing of hazardous
waste from Minnesota, two additional facilities were in operation a short time ago.
During 1973, use of these two facilities was abandoned in conformance with the
applicant's Solid Waste Rules and Regulations. These two facilities are:
1. Waste Disposal Engineering Sanitary Landfill - Anoka County - The Waste
Disposal Engineering Sanitary Landfill was the only landfill in the metro-
politan area with a permitted on-land hazardous waste disposal site. At
25
-------
one time, the facility had an operating permit from the applicant and
an operating license from Anoka County. Under the newly adopted state
Solid Waste Rules and Regulations, on-land disposal of hazardous waste is
no longer permitted at sanitary landfills and this on-land disposal facility
has been abandoned.
2. University of Minnesota - Dakota County - Until mid 1973, the University
of Minnesota maintained a small on-land hazardous waste disposal site
at the University of Minnesota Roseraount Research Facility. The waste
disposal facility, was viewed as an experimental facility and was not
regulated through a permit from the applicant or through a license from
Dakota County. Leachate from the site and ground water beneath the site
are monitored by the University. Use of the land disposal area has been
discontinued.
The hazardous waste quantities from the Minneapolis/St. Paul metropolitan area
being deposited at the six disposal areas discussed in the preceding paragraphs
are summarized on the following table. The waste disposal quantities for Pollution
Controls, Inc.'s incinerator and Waste Disposal Engineering's on-land disposal
facility were obtained from monthly reports submitted to the applicant. The
quantity of waste deposited at the University of Minnestoa facility was obtained
from a staff member of the University Plant Services Department. As discussed
previously, no data is available for publication from Minnesota Mining and Man-
ufacturing Co. with regard to the quantity of hazardous waste being disposed of
at their incinerator.
NON-SEWERED DISPOSAL OF HAZARDOUS WASTE FROM MINNEAPOLIS/ST. PAUL AREA
Name of Facility
Pollution Controls, Inc.
(Minneapolis/St. Paul)
*Minnesota Mining &
Manufacturing Co.
(Minneapolis/St. Paul)
Type of Disposal
Incinerator
Incinerator
Estimated Disposal
Quantity
(9/1/72-8/31/73)
340,200 gallons
Not Available
Wastes
Solvents, Paint,
Ink, Chemical
Sludge
Company Wet
Scrap and
Security Dry
Scrap
26
-------
NON-SEWERED DISPOSAL OF HAZARDOUS WASTE FROM MINNEAPOLIS/ST. PAUL AREA (cent.)
Name of Facility
Waste Research &
Reclamation
(Eau Claire, Wise.)
Conversion Chemical
Corporation
(Gary, Indiana)
**Waste Disposal Engineering
(Minneapolis/St. Paul)
**University of Minnesota
(Minneapolis/St. Paul)
Type of Disposal
Recycling.
On-land
On-land
On-land
Estimated Disposal
Quantity
(9/1/72-8/31/73)
150,000 gallons
55,000 gallons
17,500 gallons
7,300 gallons
Acids
Solvents, Paints,
Ink, Chemical
Sludge
Research
Chemicals,
Acids
*0nly available for company waste.
**Abandoned in 1973 in conformance with Minnesota Pollution Control Agency Solid Waste
Regulations.
Source: Hazardous Waste Generation - Twin Cities Metropolitan Area
The State of Minnesota Public Service Commission regulates and licenses the
for-hire bulk carrying of most hazardous substances. The Minnesota Public
Service Commission routinely adopts the Federal Department of Transportation's
hazardous substances transportation regulations for use in the intrastate trans-
portation of hazardous materials in bulk. The Public Service Commission is in the
process of incorporating a hazardous waste transportation licensing system into
the existing hazardous materials transportation licensing procedures using the
technical assistance of the applicant. The hazardous waste transportation licensing
system will be enforced by the Public Service Commission through existing trans-
portation enforcement procedures.
At the present time, hazardous waste is being transported by a number of private
haulers. Pollution Controls, Inc., for example, maintains seven tankers (5,000
gallon capacity each) and five 40 foot long vans for transporting hazardous waste
to their incinerator. Septic tank scavengers have also been known to transport
liquid hazardous wastes. Hazardous wastes are also commonly transported in 55
27
-------
gallon drums on flat bed trucks. Once the hazardous waste transportation
licensing system is implemented, the transportation of hazardous wastes will
be much more closely regulated.
As discussed in this section, Minnesota is well on the way toward a program of
environmentally-safe hazardous waste management. Hazardous waste generation,
labeling, storage, handling, treatment and disposal can be effectively regulated
under the proposed program. In addition, the area-wide incineration capa-
bilities are sufficient to dispose of the hazardous wastes from the area which
can be safely incinerated. Incineration is, however, obviously not the disposal
answer for all types of hazardous wastes. Other modes of disposal, such as
land disposal under carefully controlled and monitored conditions, are urgently
needed to make the statewide hazardous waste management program effective. An
environmentally-safe land disposal facility will also demonstrate the true
cost of environmentally-safe waste disposal. Once this true cost is known,
the applicant anticipates that resource recovery and source reduction programs
will be more economically attractive. Without adequate disposal facilities, the
overall hazardous waste regulatory system simply will not function. The location
of the demonstration facility in Minnesota will, therefore, not only satisfy a
nationwide need to demonstrate the feasibility of the on-land disposal of
chemical wastes, but will also alleviate a critical statewide need to provide
environmentally-safe disposal for many of the state's hazardous wastes.
6.3 SITE SELECTION
This section of the demonstration grant application illustrates the procedures
the applicant utilized to select the site for the demonstration facility.
The section is divided into an overview of the applicant's general site
location and environmental protection philosophy, a discussion of the site
selection criteria used to screen perspective sites, a discussion of alternative
sites considered by the applicant and an overview of the two sites selected
as potential locations for the demonstration facility. More detailed information
regarding the two selected sites is included in the Environmental Impact
Appraisals in Section 7 and Section 8 of this application.
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6.3.1 General Overview
The applicant considers the selection of an environmentally-safe site
in terms of ground water quality protection, surface water quality
protection, and air quality protection to be imperative. Even though
one of the demonstration project objectives is to design and construct
a chemical waste land disposal facility that can be built in many
locations, the applicant believes that an environmentally-safe site
must be selected and for that reason a great deal of attention has
been given to environmental protection criteria. The following
philosophy has been used by the applicant to provide an environmentally-
safe site for the chemical waste land disposal facility. Primary
protection of the ground water system will be provided by the various
demonstration techniques prohibiting leachate escape and leachate
generation. Liners, either in the form of barriers or membranes, will
be placed under all chemical waste disposal areas. Leachate collection
systems will be installed above the various liners to collect and remove
all leachate. Primary protection to surface waters will be provided
by diverting all tributary surface runoff around the facility and
collecting and storing all surface runoff from the facility. Air
quality protection will be provided by locating the facility away from
populated areas and by screening and other techniques to reduce wind
movement across the disposal area.
Due to the experimental nature of the demonstration project, however,
the applicant recognizes that leachate leakage may occur through the
primary leachate protection barriers. To provide a secondary leachate
control barrier, the disposal area will be lined with a compacted colloidal
_g
clay barrier (permeabilities in the range of 10 cm/sec.) overlain
by clean sand (permeabilities in the range of 1 cm/sec.). The clay
barrier will be sloped to a secondary leachate collection system
placed in the clean sand. In this way, any leachate leaking through
the primary barriers will be collected in the secondary collection
system before reaching the ground water table. A typical cross-section
through the disposal area illustrating the chemical waste, primary
barrier and leachate collection system, and secondary barrier and
leachate collection system is shown on Figure 6-1.
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Sloped
SlopecL
COMPACTED COVER MATERIAL ^Percolation Barriers
V ' I 11 I ^
'fit'
'. CHEMICAL WASTE
Primary Waste Control Barriers (membranes, 1iners)' '
.f ^^^^ -^*~
Leachate Collection System
Q
O^"TT"
CLEAN SAND (permeabilities in the range of 1 cm/sec to 10 cm/sec) '-.
. . ''. .''.'. V-^LJ^"'. '.'. '. '. Leachate Collection System .''-^J^i-^-^/.'-'..'.' '
-. ...'*. .^-, , ,^^ ... r-r^. +*'
/ / / ^/*~/ '/ /// /^r/Ys/ / / / / / ///^ / / 'r~~7:~^/ '
////////////'/// //^COMPACTED COLLOIDAL CLAY /////////// //
'///// ///(Permeabilities in the Range of 10'9)7///// / // /
NATURAL SOILS
GROUND WATER
TABLE
FIGURE 6-1
TYPICAL CROSS SECTION THROUGH DISPOSAL AREA
SHOWING PRIMARY AND SECONDARY WASTE
CONTROL BARRIERS
30
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In a recent report completed for the U.S. Environmental Protection
Agency, Battelle Pacific Northwest Laboratories recommended that hazardous
waste disposal sites be located so natural soils act as a secondary
/c\
barrier to.unplanned waste releases. The Battelle report indicated
that clay soils were desirable due to their low permeabilities and
high ion exchange capacities. The applicant believes, -however, that
in this area, typical glaciated clay soils do not guarantee an environ-
mentally-safe facility for the following reasons:
a) Clay soils in this area typically exhibit secondary joint p'atterns
likely due to periodic shrink and swell during the post-glacial
period. Percolation rates through these secondary joints may be
many orders of magnitude greater than percolation rates through
the unjointed clay soils. The secondary joints may, therefore,
provide a route for leachate movement downward and away from the
facility.
b) If clay soils became contaminated by leachate movement through the
secondary joints, the leachate will be extremely difficult to
remove. Traditional methods of recovery, such as recovery wells,
may not be effective and excavation may be the only feasible
method of removing the leachate.
c) Due to their geologic history, the glacial tills containing the
clay soil in this area are not homogeneous. In one of the most
promising search areas in the southwestern portion of the metro-
politan area, forty to sixty feet of clay soil is typically under-
lain by ten to twenty feet of sand and gravel used for individual
farm water supplies. This sand and gravel aquifer has the potential
to become contaminated by leachate moving through the secondary
joints in the overlying clay. Water supply wells between the
facility and the ground water discharge zone, therefore, have the
potential of becoming contaminated in the future if leachate
accidentally escapes from the facility.
d) Since precipitation exceeds evapotranspiration in this area,
clay soils are typically accompanied by a water table near the
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ground surface. If a land disposal area is excavated beneath the
water table in these soils, a slow inflow of ground water will
ocqur beneath the primary waste control barriers and the effective-
ness of the various liners will be difficult to evaluate.
As an alternative to placing the disposal facility randomly in the
glacial clay till, the applicant has established criteria which give
priority to locating the facility near a ground water discharge area.
The reason for giving priority to locations adjacent to ground water
discharge areas is to insure protection of underlying water supply
aquifers if Che primary and secondary waste control barriers prove
ineffective at some future date. Since no areas of clay soil adjacent
to a ground water discharge area were located, priority was given to
locating the facility in permeable soils to facilitate the removal of
leachate through barrier wells if the primary and secondary leachate
control barriers are for some reason ineffective in controlling leachate.
Permeable soil such as glacial outwash was believed to be superior to
silty clays or silty sands in facilitating leachate recovery.
The applicant believes that the resulting primary and secondary waste
control barriers and leachate collection systems, the ability to use
barrier wells to recover leachate plus the location of the facility
adjacent to a ground water discharge area will provide an environmentally-
safe facility while still demonstrating a facility design that could
be used at a number of locations across the country under various
geologic conditions.
6.3.2 Site Selection Criteria
The following site selection criteria were used to screen perspective
sites for the chemical waste land disposal demonstration facility.
a) Size Criteria
In order to provide land disposal capacity for a 15 to 20 year
period, approximately 30 to 40 acres are estimated to be necessary
for actual land disposal area, 5 acres are needed for buildings and .
parking, 20 to 30 acres are needed for waste storage and preparation,
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and 30 to 40 acres are needed for buffer zones and screening.
Therefore, between 85 acres and 115 acres of land will be needed
for the demonstration project.
b) Location Criteria
i) The site should be reasonably near the existing chemical
waste generation centers.
ii) The site- should be located on major highway routes, per-
ferably on highway routes being used to transport solid
waste and chemical materials and have rail access.
iii) The site should be near the existing hazardous waste incin-
erator to improve the efficiency of the overall metropolitan
area hazardous waste management program.
iv) The site should be in an area served by a regional wastewater
treatment plant so the treatment plant can be used to dispose
of leachate, contaminated surface water and waste preparation
supernatents which may be generated at the site.
v) The site should be well away from residential areas and well
screened from roads, surrounding buildings, etc. The facility
should not be located adjacent to recreational areas, parks,
and high-intensity public use areas. Residential and high-
intensity public use areas should not be programmed to be
constructed in surrounding areas during the life of the facility.
vi) The site should be located in an area served by an adequate
power supply (220 volt-3 phase for pumps and other heavy equip-
ment) and water supply (either municipal or an aquifer capable
of supplying 200 gpm for fire protection purposes).
c) Environmental Impact Criteria
i) The area should be sufficiently above the ground water table
to demonstrate the feasibility of operating the site with
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a trench and fill- waste placement technique (5-foot minimum
trench depth). A 10-foot minimum freeboard between the ground
water table and the bottom of the lowest portion of the fill
area is necessary and a greater freeboard is desirable to
give sufficient flexibility in site design, operation and
environmental surveillance.
ii) Soils underlying the site should be sufficient to structurally
support the land disposal of chemical waste. Homogeneous
soils in terms of permeability, porosity, and soil structure
are preferred in order to minimize differential settlement.
Permeable, homogeneous soils have a higher priority than silt
or sandy clay to provide fail-safe ground water protection
facilities.
iii) Bedrock beneath the site should not be subject to subsidence
and, if impacted by an unexpected leachate release, should
be homogeneous and nonfractured in order to facilitate the
fail-safe collection of unexpected escaped leachate.
iv) The site should be outside the standard project flood plain.
A 10-foot freeboard between the standard project flood plain
elevation and the bottom of the fill area is a minimum and
a greater separation would be desirable.
v) Due to the short time period available to complete the
grant application, reasonably sufficient background data
should be available or easily attainable. Of particular
interest will be data on soils, ground water, bedrock,
vegetation, air quality, surface water and surrounding land
use.
vi) The site should be located reasonably close to a ground
water discharge area. Ground water within 2,000 feet of the
area influenced by the site should not be used for individual
potable water supply purposes or for commercial/industrial
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purposes affected by, the accidental release of leachate now
or in the future. The discharge area adjacent to the site
should be downstream of the Minneapolis/St. Paul municipal
water intakes.
vii) The facility should be located in an area of low flora and
fauna uniqueness and diversity so that facility operation will
have a low potential for damaging adjacent ecological systems.
viii) Surface slopes in the disposal area should be between 1
percent and 10 percent. Slopes less than 1 percent have
poor drainage potential and slopes greater than 10 percent
have high erosion potential.
d) Ownership Criteria
The site must be governmentally owned (non-federal) or able to
be placed in governmental ownership within a reasonable cost.
e) Institutional Criteria
Institutional arrangements should be achievable to make the use
of the site realistic.
6.3.3 Alternative Sites
The site selection criteria outlined in Section 6.3.2 were used to
locate a .number of alternative sites for the land disposal facility.
Throughout the site selection process, efforts were made to consider
only sites with some form of built-in environmental protection
due to the recognized finite life of the various artificial membranes
which may be utilized in at least a portion of the facility. As
discussed in Section 6.3.1, built-in environmental protection in the
form of locating the facility in clay soils and locating the facility-
near a ground water discharge area were evaluated. Of these two for^is
of environmental protection, the location of the facility near a
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discharge area and the close control over the ground water area
influenced by the facility were considered to be the most environmentally
fail-safe. An environmentally fail-safe operation will be absolutely
necessary to gain acceptance for the project from local, regional and
state units of government and from the general public.
6.4 DISPOSAL AREA PREPARATION TECHNIQUES
The purpose of this section of the grant application is to outline the various
disposal area preparation techniques that will be evaluated for incorporation
into the final design of the facility. Specific processes within the following
four general disposal area preparation techniques will be evaluated.'
- Techniques Prohibiting Leachate Escape
- Techniques Prohibiting Leachate Production
- Leachate Collection and Recirculation/Treatment Techniques
- Waste Placement Techniques
The following subsections discuss the various processes within each technique
that will be evaluated and the evaluative criteria that will be used to
select the final processes.
6.4.1 Techniques Prohibiting Leachate Escape
Various bottom liners to prevent the escape of leachate from the
chemical waste land disposal facility will be evaluated. Bottom liners
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can be classified as synthetic membranes (such as polyvlnyl chloride
and polethelene sheets) which rely on thin impermeable material for
protection and barriers (such as asphaltic concrete and soil-clay
mixtures) which rely on low permeabilities and thickness for protection.
A number of possible bottom liners for sanitary landfills have been
identified in a recent study completed for the Environmental Protection
(3)
Agency. In addition, research studies evaluating various liners
exposed to hazardous waste sludges are currently being conducted by
the Environmental.Protection Agency. The liners found most feasible
for use with chemical wastes in these studies as well as other bottom
liners identified in other on-going studies will be evaluated for
incorporation into the demonstration project by the applicant, by the
land disposal facility operator and their subcontractors using the
following criteria:
a) Stability of the liner material to the chemical and physical
conditions expected in the disposal facility.
b) Cost and availability of the liner material.
c) Application, splicing, handling and storage characteristics.
d) Ability of the material to prohibit the movement of leachate.
Typically, the applicant, after consulting with the operator and with
the Environmental Protection Agency, will propose various demon-
stration related activities to the operator. The facility operator
will then design the demonstration areas within a proposed budget
and the design will be approved by the applicant. A more detailed
discussion of the applicant/operator responsibilities is outlined
in Section 6.7.2.
It is anticipated that between 4 and 6 of the most promising bottom
liners will be chosen with the concurrence of the Environmental
Protection Agency for initial use in the demonstration facility.
Some form of bottom liner will be used under all land disposal areas
37
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to insure leachate containment and facilitate leachate collection.
The selected bottom liners will be placed on adjacent demonstration
areas, perhaps 2 to 3 acres in size. Chemical waste will then be
placed over the demonstration area using the various waste placement
techniques selected using the procedures outlined in 6.4.4. A primary
leachate collection system will be provided above the various bottom
liners to collect leachate generated by the facility. As discussed
in Section 6.8.3, a grid system will be established for the fill
area and careful records will be kept of the types of liners placed
beneath the various demonstration areas in the land disposal site.
As outlined in Section 6.3.1, the various bottom liners will be
placed over a layer of clean sand and a layer of colloidal clay. The
clay will provide a barrier to stop any leachate seeping through the
demonstration bottom liners. The escaping leachate will be collected
by a secondary leachate collection system constructed in the clean
sand. The effectiveness of the various liners in preventing leachate
escape will be monitored through the use of monitoring piezometers,
suction lysimeters, conductivity probes, the secondary leachate
collection system and other appropriate monitoring methods installed
in the sand layer below the bottom liners, but above the clay barriers.
Each demonstration area will have its own primary and secondary
leachate monitoring system so the effectiveness of each liner used
in each demonstration area can be carefully monitored. Special
attention will be devoted to evaluating the performance of splices.
As the performance data becomes available on the initial group of
liners, this data as well as data generated by laboratory, bench
scale, pilot scale and other full scale test projects will be used to
select liner materials for further study in the demonstration project
as the disposal areas are expanded. The performance of the bottom
liners under the climatic conditions experienced in Minnesota will
provide data applicable to other areas of the country.
6.4.2 Techniques Limiting Leachate Production
The effectiveness of various sealants designed to prevent the per-
colation of precipitation into the waste material will also be
38
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demonstrated. Sealants to prevent percolation and the resulting
production-ofleachate can also be classified as synthetic membranes
and barriers. The various liners studied in previous laboratory
and bench scale projects will be evaluated for use in the demonstration
project as percolation prohibitors. The evaluation of sealants
for incorporation into the facility will be carried out by the applicant,
the facility operator, and their consultants as discussed in 6.7.2
using the following evaluative criteria:
a) Stability of the sealant to sunlight and to the freeze/thaw and
moisture conditions expected near the surface of the land disposal
area.
b) Cost and availability of the sealant material.
c) Application, splicing, handling and storage characteristics.
d) Ability of the material to prevent the downward percolation of
rainfall and melting snow.
It is anticipated that 3 or 4 of the most promising percolation
prevention materials will be selected with the concurrence of the
Environmental Protection Agency for initial use in the demonstration
project. The sealant materials will be placed over adjacent 1 or 2
acre demonstration areas (perhaps areas without chemical waste or
chemical waste disposal areas with bottom liners which have been used
for other demonstrations could be used). The effectiveness of the
various sealants in preventing the percolation of precipitation will
be monitored using suction lysimeters, resistivity probes and other
suitable monitoring devices placed beneath the sealants. The performance
of the splices in the various sealants will be carefully monitored.
As the downward percolation of precipitation is prevented, the manage-
ment of the resulting large volume of surface runoff will become a
critical factor. Alternative methods of controlling surface runoff
will be demonstrated. The applicant and facility operator will
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evaluate the possibility of, covering various percolation sealants with
topsoll,and plants with high water consumption characteristics to
reduce the volume of water which must be removed from the surface of
the demonstration area. As data on the performance of the rainfall
percolation sealants becomes available, this data along with data.
generated in other studies will be used to select rainfall percolation
sealants for further study in expansion areas of the demonstration
facility.
6.4.3 Leachate Collectionnand Recirculation/Treatment Techniques
Various leachate collection systems and leachate recirculation/treat-
ment processes will be evaluated for incorporation into the demonstration
project by the applicant, facility operator and their consultants.
Leachate collection facilities will concentrate upon collecting the
leachate before the leachate reaches the ground water table. As
discussed in 6.4.1, this necessitates the use of some form of .liner
under all land disposal areas. As discussed previously, -a primary
leachate collection system will be constructed immediately above all
bottom liners.' 'The purpose'of the primary leachate.collection system
is to monitor the quality.of leachate, generated by the facility. A
secondary leachate collection system will be installed below the bottom
liner and above'the clay waste control barrier. The purpose of the
secondary leachate collection system is to collect all leachate
seeping through the various liners used in the demonstration project,
thereby providing.an additional level of environmental protection and
helping to evaluate-the effectiveness of the various liners.
Leachate collection techniques to be evaluated will include drain tile
and porous media as well as other leachate collection techniques found
to be applicable to the chemical waste land disposal facility.
Evaluation of various leachate collection facilities .will be based
upon the following criteria:
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a) Stability of the leachate cqllectlon facilities when exposed to
the expected quality of the leachate for long'periods of time.
b) Cost of purchasing and installing 'the leachate collection facilities.
c) Ability of the facilities to effectively collect and transport
leachate on a long-term basis.
It is anticipated that at least 3 or 4 different leachate collection
techniques will be utilized with the concurrence of the Environmental
Protection Agency in the various portions of the land disposal areas.
Some form of leachate collection will be utilized under all the chemical
waste land disposal demonstration areas. This is necessary to demon-
strate leachate collection technology, to serve as an important part
of the leachate quality and leachate quantity monitoring system, and
as a critical component of the leachate collection and treatment
system necessary to insure an environmentally-safe operation.
The effectiveness of many of the bottom liners is likely to be dependent
upon the efficiency of the leachate collection facility used over the
liners. For this reason, the effectiveness of various'bottom 'liner/
leachate collection systems will be evaluated as combined environmental
protection techniques as well as separately. The evaluation-will be
based at least in part upon the results of the data collected from
the monitoring system placed beneath the liners as discussed in
Section 6.4.5.
Leachate recirculation and/or treatment is likely to be necessary
once the leachate is collected and before discharge to the sanitary
sewer system. One obvious general technique to be evaluated- involves
recirculating the leachate back onto the chemical waste disposal
area during the warm summer months when- land evaporation could be
utilized as a disposal mechanism. Another recirculation alternative
to be evaluated is the irrigation' of selected grasses and other
plants on the surface of the disposal area. The need- for storage and
auxiliary leachate treatment facilities for use during the winter
months when recirculation cannot be carried out will be assessed.
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Leachate treatment systems, to be evaluated will include off-site
disposal at a regional wastewater treatment plant with and without
pretreatment and on-site treatment by such unit processes as clari-
fication and surface skimming, chemical precipitation, ion exchange,
and evaporation as well as other chemical, physical and biological
processes dictated by the anticipated quality of the leachate.
Evaluative criteria for selecting the necessary leachate treatment
processes will include:
a) Anticipated quality and quantity of leachate generated by the
facility as well as the expected seasonal variation In leachate
generation.
b) Capital and operating costs of the various techniques as well as
the need to demonstrate a range of leachate treatment techniques.
c) Ability of a regional wastewater treatment facility to accept
the raw or partially treated leachate from the facility and the
anticipated pretreatment standards for the leachate prior to
discharge to the regional wastewater treatment facility. ,
d) Availability of waste preparation facilities which could be
utilized as leachate treatment facilities. The selection of
leachate treatment facilities will be coordinated with the selection
of the waste preparation facilities discussed in Section 6.5 to
insure that techniques applicable to both leachate treatment and
waste preparation are provided.
e) Long-term applicability of the various leachate treatment techniques
will be evaluated. It is recognized that leachate treatment may
have to continue after the facility is closed.
Sufficient leachate recirculation/treatment facilities will be provided
to insure that no discharge of leachate occurs to the environment
which does not meet state standards and that no discharge to the
sanitary sewer system occurs which does not meet applicable pretreatment
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standards of the Metropolitan Waste Control Commission. The temporary
storage of leachate prior to recirculation or treatment is recognized
as a necessary component of many leachate recirculation/treatment
techniques. Leachate will likely not be generated at a constant rate
throughout the year and storage of leachate may, therefore, be necessary
for efficient design and operation of the recirculation/treatment
facilities. Sufficient flexibility in leachate recirculation/treatment
systems will be provided to insure that a range of leachate recirculation/
treatment technology is demonstrated.
Waste Placement Techniques
Various waste placement techniques will be evaluated for use in the
demonstration project. Candidate waste placement techniques for
initial evaluation will include conveyor and truck transportation
of chemical sludge from storage and preparation areas to land disposal
areas; placement of sludge in lifts; placement of liquids, slurries
and sludges and solids in shallow trenches and by soil mixing; place-
ment of pumpable wastes by flooding, soil injection, spray irrigation
and by truck application; above and below ground encapsulation of
extremely hazardous waste and other appropriate waste placement
techniques. Criteria used to evaluate the various waste placement
techniques for use in the project will include:
a) Ability of placement techniques to dispose of a variety of chemical
wastes.
b) Ability of the waste placement techniques to overcome air pollution
problems from blowing contaminated particulates and noxious gases.
c) Capital and operating costs of carrying out the various waste
placement techniques.
d) Sludge, slurry and liquid waste placement experience and data
gained from laboratory and bench scale experiments and from land
disposal projects carried out in other areas.
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e) Ability of the placement techniques to function under the wide
range of climatic conditions experienced in Minnesota.
It is anticipated that a wide variety of waste placement techniques
will be used in the demonstration project to provide a wide range
of placement costs for different waste characteristics under various
seasonal operating conditions. The location of the demonstration
project in Minnesota will insure a thorough study of various waste
placement techniques under a wide range of climatic conditions.
6.A.5 Other Disposal Area Preparation Techniques
The effectiveness of the various disposal area preparation techniques
selected for use in the demonstration facility will be closely monitored
using the leachate collection facilities, specially designed monitoring
piezometers, suction lysimeters, soil cores, resistivity and pH probes,
and other monitoring techniques. As discussed previously, leachate
collection facilities will be used to collect the leachate from above
the liners and to collect any leachate escaping through the liners.
Suction lysimeters will be used to collect leachate samples at various
levels above the liners in the disposal area. Resistivity and pH
probes will be Inserted at various levels in the disposal area to
obtain data relative to in-place conditions. Soil cores will be
obtained to analyze the exact nature of the waste above the liners.
Before placement of the liners, resistivity and pH probes, suction
lysimeters and other appropriate monitoring devices will be installed
in the sand below the liners, but above the clay waste control barrier
to provide data on liner effectiveness. Special attention will be
devoted to monitoring the effectiveness of liner splices. Barrier
wells (discussed in Section 6.6.2) will be used to monitor the overall
effectiveness of the facility design in preventing leachate escape.
Automatic monitoring equipment will be utilized to continuously
monitor conductivity and pH and automatic sample collection equipment
will be used to collect samples at constant intervals as appropriate.
The effectiveness of the various waste preparation techniques in
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controlling air contamination will be monitored using air quality
monitoring>stations as discussed in Section 6.6.4. Monitoring the
effectiveness of the various site preparation techniques will be
carried out by the applicant, by the facility operator and by their
subcontractors as discussed in Section 6.8.4. Samples will be analyzed
at the laboratory constructed at the demonstration facility. The
capabilities of the laboratory are discussed in Section 6.8.3.
One of the demonstration project objectives will be to determine the
quality of chemical waste leachate under a wide range of "real-world"
operating conditions. The monitoring system will, therefore, not
only be utilized to collect data on the effectiveness of the various
site preparation techniques, but will also be used to collect data on
the quality and quantity of leachate generated by the wastes placed
in the various demonstration areas. Resistivity, pH and other probes
with automatic recording devices will be installed in the waste disposal
areas to aid in interpreting the leachate quality data. As discussed
in Section 6.5, the various waste preparation techniques will be
selected to provide wastes and, therefore, leachate with a wide range
of characteristics.
Surface runoff from the watershed tributary to the actual land disposal
areas will be diverted and not carried through the disposal areas.
Surface runoff from the actual land disposal areas and from waste
storage areas will be collected, stored and, if necessary, treated
prior to discharge to the environment or to the regional sewage
treatment plant. The advisability of removing snow from the frozen
surface of the land disposal areas to reduce surface runoff and
reduce leachate generation will be evaluated by the applicant and by
the facility operator.
It is anticipated that artificial rainmaking facilities will be provided
over approximately one-fourth of the initial land disposal area to
simulate extreme climatic conditions which could occur in the project
area (as well as other areas of the country), but which may not occur
during the demonstration period. The rainmaking facilities will be care-
fully designed to simulate natural rainfall over the demonstration site.
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6.5 WASTE PREPARATION TECHNIQUES
This section of the grant application outlines the various processes and
techniques that will be evaluated for use in preparing the various chemical
wastes prior to land disposal. The primary purpose of the selected waste
preparation techniques will be to provide waste with a wide range in charac-
teristics for demonstration purposes. The ability of the various techniques
to prepare waste with a wide range of moisture content, pH and other charac-
teristics important fpr demonstration purposes will, therefore, be stressed.
A second purpose of the waste preparation techniques will be to prepare the
chemical wastes generated in Minnesota for safe disposal. A preliminary
evaluation indicates, however, that the waste preparation facilities cannot be
designed to be a complete centralized chemical, physical and biological chemical
waste pretreatment facility within a reasonable project budget. The applicant's
general philosophy will be to have generators either pretreat their wastes
at the point of generation or create a demand for centralized pretreatment
facilities serving specific generator groups. Centralized pretreatment
i
facilities would logically be located adjacent to the demonstration facility,
but demonstration funds would not be utilized to plan, design or construct
these additional facilities. The nonsewered portion of the chemical waste
stream will, for the most part, be delivered to the demonstration land disposal
facility either by the generators or by the centralized pretreatment facilities
as a concentrated waste principally in sludge form. The demonstration project's
waste preparation techniques will then be utilized to prepare various waste with
a wide range in characteristics (water content, pH, heavy metal concentrations,
etc.) for land disposal demonstration purposes.
The following section (6.5.1) illustrates the basic package of waste pre-
paration techniques that will likely be included in the demonstration project
and the criteria which will be used to evaluate the various unit processes
within each general technique for eventual incorporation into the project.
Section 6.5.2 discusses additional generalized waste preparation techniques
chat will be evaluated for possible incorporation into the project and the
evaluative criteria which will be used. The methods of integrating the various
waste preparation techniques into the overall demonstration project are
discussed in Section 6.8.1.
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6.5.1 Basic Waste Preparation Techniques
The following general waste preparation techniques have been evaluated
in a preliminary manner and are being suggested for incorporation into
the demonstration project.
Blending
Neutralization
Liquid-Solids Separation
Fixation
Encapsulation
These general techniques are being recommended at this preliminary
stage due to their flexibility in preparing wastes with a wide range
in characteristics. Unit processes .to be evaluated within each technique
are discussed in the following paragraphs. The criteria to be used
to evaluate the various processes ,are discussed at the end of this
section.
a) Blending
Blending techniques will be utilized to mix two or more pumpable
or nonpumpable chemical wastes to obtain a waste with physical
or chemical characteristics desired,for demonstration purposes.
For example, it may be desirable to add water to a water soluble
paint sludge to produce a paint slurry with a higher water content
for demonstration purposes. Unit processes to be evaluated for
blending pumpable wastes will include stainless steel, fiberglass,
and concrete tanks with rotating impellers, spiral blenders, air
agitators and mixing jets. Special facilities necessary to empty
pumpable wastes from the tanks will also be evaluated. Blending
unit processes for mixing nonpumpable wastes will .include rotating
drums, double cone blenders and in-line mixing with augers.
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b) Neutralization
Neutralization techniques will be utilized to obtain wastes with
a range of hydrogen ion concentrations for demonstration purposes.
For example, disposal costs and environmental impacts associated
with disposing of acidic metal wastes may be significantly different
with a pH of 3, than with a pH of 5. Most heavy metals precipitate
as hydroxides or hydrous oxides upon neutralization and neutralization
techniques will, therefore, be useful to form metal sludges from
liquid was.te containing metals. Neutralization may be carried out
with a special blending of two or more wastes or may require the
addition of acid or caustic reagents to a waste. For this reason,
it has been included as a separate waste preparation technique
and has not been included under "blending techniques". The
facilities selected for use as "blending techniques" will be evalu-
ated for use as neutralization facilities. Possibly two or three
of the units used for blending can be constructed with sufficient
flexibility for use as neutralization facilities.
c) Liquid-Solids Separation
Liquid-solids separation techniques will be utilized principally
to remove sludges from supernatent and to reduce the water content
of the sludges for disposal related demonstration purposes. The
technique will be used to create wastes with the range of moisture
contents necessary to demonstrate leaching characteristics, place-
ment problems and the resulting unit disposal costs. Unit processes
to be evaluated for incorporation into the demonstration project
will include clarification/surface skimming, vacuum filtration,
centrifugation and flocculation/sedimentation. Flexibility of
equipment will again be stressed. For example, clarification/
surface skimming could potentially be carried out in the tanks
used for blending and neutralization. The general evaluative
criteria to be used in selecting the liquid-solids separation
unit processes are included at the end of this section.
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d) Fixation
Fixation of chemical wastes using cement, asphalt and various
synthetic polymers prior to disposal will also be incorporated into
the demonstration project. The purpose will be to evaluate the
handling problems, disposal problems, leachate quality and subsequent
unit costs associated with this waste preparation technique.
Equipment to be evaluated to carry out the various waste fixation
processes will include "redi-mix" trucks, stationary rotating drums,
a portable asphalt plant, and other "batch" type unit processes.
e) Encapsulation
Experience has shown that some wastes are simply too hazardous and
too persistent for land disposal without encapsulation. Poly-
chlorinated biphenols and pesticides containing mercury, lead,
cadmium and arsenic for example, will no,t be placed in the chemical
waste land disposal areas without encapsulation. An encapsulation
area will be established at the demonstration project and encap-
, sulation facilities will be constructed according to demand. Above
ground as well as below ground encapsulation techniques will be
evaluated for incorporation into the facility.
Preliminary evaluation indicated that the .five general waste pre-
paration techniques outlined in the preceding paragraphs will be
necessary at the facility to insure waste with a wide range of
characteristics for demonstration purposes. The various unit .
processes within each of these five techniques will be, evaluated
for incorporation into the project by the applicant, the, site
operator and their consultants as outlined in 6.7.2 using the
following'evaluative criteria:
i) Unit processes applicable to the batch preparation of wastes
will be given priority. As outlined in Section 6.8.1, chemical
wastes will be initially separated and stored for predisposal
preparation. When a sufficient quantity has accumulated, the
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waste will be prepared using batch processes. Sufficient
wastes are obviously not available to make continuous operation
of the various preparation techniques possible.
ii) Flexibility in equipment will be stressed. Blending and
neutralization for example, could be carried out in the
same properly designed mixing tanks. One or two of the
tanks used for blending and neutralization could also be
designed for clarification and surface skimming.
iii) Capital and operating costs will, of course, be considered
when alternative unit processes are evaluated.
iv) The applicability of the various processes to prepare the
types of chemical wastes generated in the service area will be
considered. The ability of the various facilities to create
less reactive or less hazardous wastes for land disposal will
be stressed.
v) The use of the waste preparation processes to treat chemical
waste leachate will also be considered. As discussed in
Section 6.4.3, the flexibility of unit processes to not only
prepare waste for disposal, but to also pretreat leachate
prior to discharge to a municipal wastewater treatment plant
will be stressed.
vi) The size of the facilities necessary to pretreat the volume
of waste generated in the service areas will also be considered,
but will be given a lower priority than the facilities needed
to provide the necessary range of wastes for demonstration
purposes. It is anticipated that the budget available for
waste preparation will be a factor limiting the sophistication
of selected unit processes.
6.5.2 Additional Waste Preparation Techniques to be Evaluated
The general waste preparation techniques outlined in Section 6.5.1
represent a basic package necessary to prepare waste with a wide
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range of characteristics. In addition, the following general waste
preparation techniques will be evaluated for incorporation into the
i
demonstration project:
Chemical Precipitation
Oxidation/Reduction
Concentration
Filtration
The evaluation \ill be carried out using the evaluative criteria
included at the end of this section. These evaluative criteria were
the criteria originally used to select the basic waste preparation
techniques discussed in Section 6.5.1.
a) Chemical Precipitation
Chemical precipitation will be evaluated as a waste preparation
technique to be incorporated into the demonstration project. The
primary use for this technique will be to generate concentrated
metal sludges from liquid wastes containing metals. Chemical
precipitation with sulfide will often result in supernatent heavy
metal concentrations lower than would occur with neutralization.
Depending on the discharge requirements to the municipal wastewater
treatment plant, this technique may be necessary for leachate and
supernatent treatment.
b) Oxidation/Reduction
It is anticipated that large quantities of cyanide and chromium
bearing wastes will be generated in the service area. For this
reason, oxidation of cyanides and other reductants and reduction
of chromium and other oxidants will be evaluated for incorporation
into the facility. Chlorine oxidation and sulfur reduction are
two candidate unit processes.
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c) Concentration Techniques
Various unit processes will be evaluated for concentrating portions
of the incoming waste stream beyond the liquid-solids separation
and chemical precipitation techniques already discussed. Such
candidate processes as deionization, distillation and refining will
be evaluated. Such relatively sophisticated concentration techniques
are more likely applicable to resource recovery facilities and
may not .be .within the scope of the demonstration project.
d) Filtration Techniques
Various unit filtration processes will be evaluated other than the
liquid-solids separation facilities already discussed. The filtration
processes to be evaluated will include vibrating screens, slow
and rapid sand filters, tri-media filters and membrane filters.
The purpose of these filtration techniques will be to increase the
flexibility of the liquid-solids separation facilities included
in the basic package of waste preparation techniques.
The four additional waste preparation techniques outlined above
will be evaluated for inclusion with the basic waste preparation
techniques by the applicant, operator and their consultants
as outlined in 6.7.2 using the following evaluative criteria:
i) Will the additional technique significantly increase the
ability of the basic waste preparation techniques summarized
in 6.5.1 to create wastes with a wide range of characteristics
(water content, solubility, pH, major ion concentration,
workability, etc)?
ii) Does the additional waste preparation technique represent a
cost effective and environmentally safe method of handling the
waste generated in the area serving the demonstration project?
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Ill) Can the additional waste preparation technique be constructed
and operated within a reasonable budget for the demonstration
project?
If the evaluative criteria outlined above .indicate that one or more
or the additional waste preparation techniques should be included
in the project, the evaluative criteria outlined in Section 6.5.1
will be used to evaluate the select and appropriate unit process
within the selected additional waste preparation technique.
6.6 ENVIRONMENTAL PROTECTION STRATEGIES
The purpose of the various waste control and leachate collection techniques
outlined in Section 6.4 is to contain and collect leachate generated by the
chemical land disposal facility. As discussed in Section 6.3.1 and in
Section 6.4.1, a second waste control barrier will be provided by lining the
facility with compacted clay overlain by clean sand and a second leachate
collection system. The purpose of the second waste control harrier is to
facilitate the collection of any leachate which percolates through the
primary waste control barriers. The second waste control barrier enables
the effectiveness of the various liners and membranes used in the primary
waste control system to be evaluated.
Due to the experimental nature of the demonstration project, however, the
applicant recognizes that certain site preparation and waste placement
demonstrations may not be completely successful. Leachate may be released
by one or more of the unsuccessful demonstrations or by an accidental spill
at the project site. The various artificial membranes which may be used as
primary barriers over a portion of the land disposal area have a finite life
and leakage may eventually occur. A contingency environmental protection and
waste containment strategy is, therefore, necessary to provide a second line
of environmental protection to capture any leachate, or surface runoff which may
be generated by the project. This contingency environmental protection strategy
may not be needed during the life of the facility and indeed may never be needed.
However, the second level system will initially serve as an environmental surveil-
lance network to detect leachate in the ground water, contamination in surface
waters or contamination in the air leaving the site and will be available if
needed to recapture any waste leaving the facility.
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Another important component of the overall environmental protection strategy
is the development of a facility closure plan for use when disposal of
chemical waste at the facility is terminated. The objective of the facility
closure plan will be to prohibit the additional generation of leachate,
prohibit the contact between surface runoff and chemical waste and prohibit
the contamination of the air by waste material.
The third Important component of the environmental protection strategy is a
carefully designed and carried out environmental surveillance program during
facility operation end after facility closure.
This section of the grant application discusses the contingency waste contain-
ment strategies that will be utilized at the selected site, discusses the
facility closure plan, and discusses the environmental surveillance network
that will be utilized out at the selected site. The discussion has been
divided into the following three subsections:
o Contingency Waste Containment Strategies
o Facility Closure Plan
o Environmental Surveillance Strategies
6.6.1 Contingency Waste Containment Strategies
a) Surface Waste
Surface water from areas outside the site boundaries will be
diverted around the site using a designed system of ditches and
culverts. Storage of surface water from areas outside the site
boundaries will be utilized if economically feasible.
All surface water runoff from the actual disposal areas and from
the areas used to load, store and prepare chemical wastes will be
collected in a "contaminated water" storage area. This storage
area will be lined with a suitable liner material (probably one
or more of the materials discussed in Section 6.4.1) to prevent
seepage to the ground water system. The storage area will be
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designed by the facility operator and their consultants using
design criteria supplied by the applicant. Final plans and
specifications for the storage area as well as for the entire
facility will be approved by the applicant as outlined in 6.7.2.
Surface runoff from other project areas-will be diverted around the
storage and disposal areas and collected in a "clean water" storage
area. This storage area will also be lined with suitable material
to prevent seepage to the ground water system.
The quality gf -the water in the "contaminated water" storage area
will likely not meet appropriate surface water discharge standards.
The effluent from this storage area will, therefore, be treated prior
to discharge to the environment or discharged with pretreatment (as
necessary) to the sanitary sewer system. The water in the "clean water"
storage area may meet applicable discharge standards. If standards
are not met, the "clean water" will be pretreated (as necessary) and
discharged to the sanitary sewer. The storage of water in these two
sealed storage areas will insure that all surface runoff discharged
from the site will be in compliance with applicable water quality
regulations.
b) Ground Water
As discussed previously, the various leachate containment and col-
lection techniques outlined in Section 6.4 will provide primary
barriers to leachate generated by the chemical waste land disposal
facility. These leachate containment and collection techniques will
be constructed well above the ground water table. Due to the experi-
mental nature of the demonstration project, however, it is recognized
that certain leachate collection and containment demonstrations may
not be completely successful. Leachate may be generated and released
by one or more of the unsuccessful demonstrations or by accidental
spills at the site. The clay waste control barrier has been included
to contain the leachate and enable the collection of all leachate
escaping the primary barriers. An additional level of ground water
protection will be provided through the use of barrier wells. These
wells will be constructed into the glacial outwash ground water system
down gradient of the project site.
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The barrier wells will be utilized initially as monitoring wells
to monitor the performance of the clay seal and secondary leachate
collection system. Ground water collected at the barrier wells
will be monitored periodically with a gas chromatograph and mass
spectrometer to determine whether leachate is being collected.
If the ground water samples comply with Federal and state water
quality standards and show no evidence of leachate contamination,
the ground water will be allowed to continue to the river. If,
however, ground water samples indicate the presence of leachate
and do not meet applicable water quality standards, the ground water
will be collected using the barrier wells. The collected ground
water will be pretreated prior to discharge to either the regional
wastewater treatment plant or to the surface water system.
In the event that barrier wells are needed to collect escaping
leachate, two sets of barrier wells may be utilized. One set of
wells will be installed up gradient of the site. These wells will
be used to collect clean ground water entering the site area.
Water collected by these wells will be uncontaminated by leachate
and, therefore, will be discharged directly to the environment.
The barrier wells located downstream of the site will then be used
to collect ground water from beneath the site. This will reduce
the amount of water that must be pretreated prior to discharge
while insuring that all leachate escaping from the waste containment
systems will be collected.
In summary, a back-up level of ground water protection will be
provided by barrier wells constructed down gradient of the site.
The barrier wells will initially be used as sample collection
-facilities to enable the monitoring of ground water flowing beneath
the site. If the monitoring indicates the presence of leachate,
the wells will be used to collect all leachate leaving the demon-
stration facility.
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c) Air
As discussed in Section 6.A.4, air quality contamination from the
site will be primarily controlled through the various waste place-
ment techniques. Air quality will be continuously monitored through
the use of a number of air quality monitoring stations surrounding
the site as discussed in Section 6.6.3. As a contingency air
quality protection strategy, wind movement across the site will
be minimized with screening around the site. Additional ground
surface preparation techniques will also be utilized if the air
quality monitoring data indicates that air-borne contaminants are
leaving the site.
The use of the contingency air quality protection strategies will
be evaluated by the applicant, by the facility operator and by
their consultants using data generated by the monitoring facilities.
The availability of natural screening to minimize air movement
across the site will also be evaluated and incorporated into the
design of the project.
6.6.2 Facility Closure Plan
As part of the facility design, a facility closure plan will be developed.
This closure plan may be implemented in stages as the various portions
of the land disposal areas are closed. The facility closure plan
will include the repair of any disposal areas which show leachate
generation, surface runoff contamination, or air quality contamination.
Also included will be the removal of the various buildings, storage
facilities and a general site clean-up. The capping of the waste
disposal areas with a suitable material to eliminate future production
of leachate, surface runoff and air contamination will also be evaluated.
The objective of the facility closure plan will be to eliminate future
problems from the facility after closure. If leachate, contaminated
surface runoff or air quality contamination are not being generated
at the time of closure and if the facility is closed and the disposal
areas properly capped, it is reasonable to expected that, with proper
maintenance, the facility should not present a future problem.
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The cost of implementing the closures-plan will be included in the user
fees as discussed in Section 6.9 qf the grant application. As dis-
cussed in Section 6.9, one of tire objectives of the cost accounting
strategy will be to create a £und to implement the closure plan.
The design of the closure pl£n will be continually updated as the project
is implemented to take into account any leachate generation, surface
runoff contamination or air quality contamination problems which may
be occurring and were not foreseen in the project design. In a similar
fashion, the cost of implementing the closure plan will also be
periodically-re-evaluated and if closure costs change, the revised
cost will be reflected by revisions to the user fee.
6.6.3 Environmental Surveillance
The purpose of this section of the grant application is to outline
the various methods and techniques that will be used to monitor the
air, water, vegetation and soils in the project area during facility
operation and after facility closure.
a) Surface Water Monitoring
Surface water will be monitored in the "clean water" and "con-
taminated water" storage areas as well as in the storage area
inflow and outflow conduits. The inflow conduits will carry
surface runoff from the chemical waste storage areas and disposal
areas to the "contaminated water" storage area and from the rest
of the facility to the "clean water" storage area. Samples will
be periodically collected from the storage area inflow and outflow
conduits as well as from the storage areas themselves. These
samples will be analyzed by mass spectrometry and gas chromatography
to detect the presence of any undesirable elements and compounds.
Continuous recording pH and conductivity monitors will be installed
in the storage area inflow conduits to act as primary indicators
of contamination. Surveillance activities used to evaluate the
impact of the facility on the surrounding environment will be
conducted by the applicant or by his subcontractors. This is
believed to be necessary to insure public acceptance of the resulting
data and conclusions.
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b) Ground Water Monitoring
As discussed in Section 6.4.5,leachate collected by the primary
and secondary leachate collection systems will be monitored. This
monitoring, however, is for the purpose of evaluating the effective-
ness of the various leachate containment and collection systems
and for determining the quality of leachate generated by the chemical
waste. Leachate will be collected by the primary and secondary
collection systems before reaching the ground water table.
In order to insure the effectiveness of the primary and secondary
waste control barriers, the ground water beneath the site will
also be monitored. Ground water monitoring will be conducted
through the use of barrier wells constructed down-gradient of the
land disposal area. The use of the barrier wells for ground water
monitoring purposes and for leachate collection purposes in the
event of leachate escape from the primary and secondary waste control
barriers, is discussed in Section 6.6.1. Water quality samples
collected from the barrier wells will be periodically analyzed
using mass spectrometry and gas chromatography to detect the presence
and concentration of any leachate. In addition, continuous record-
ing pH and conductivity probes will be inserted in the barrier
wells and used to measure changes in these indicator parameters.
If changes in the indicator parameters are detected or if mass
spectrometry and gas chromatography analysis indicates the presence
of potentially harmful characteristics, additional analyses will
be carried out.
Soil borings taken at areas adjacent to both potential land dis-
posal sites do not indicate the presence of perched water table
conditions. If additional soil borings taken during and after
site selection indicate that perched water table conditions exist,
the quality of the perched ground water as well as the quality of
the true ground water will be monitored.
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The barrier well systart discussed in the preceeding paragraphs will
be 'supplemented with smaller diameter piezometers. The piezometers
will be placed up-gradient and down-gradient of the site and will be
used to collect ground water samples. Cased piezometers will also
be installed into the underlying bedrock aquifers to insure that
leachate from the facility is not degrading the quality of the water
in the lower bedrock aquifers. Background ground water quality will
be collected from the various monitoring systems before waste is
placed in the site.
Ground water levels will be recorded immediately before all water
samples are collected. These measurements will enable the detection
of any changes in ground water levels that may affect the ground
water gradients and flow directions.
c) Soil and Vegetation Monitoring
Recent studies carried out by the Illinois Water Survey indicate
that observation well monitoring systems may not be the most
effective means to trace chemical pollutant ground water flow
(8)
patterns or to determine ground water chemical concentrations.
The studies show that chemical analyses of core samples from the
underlying soil profile may permit a more positive definition of
the chemical constituents within the profile. In addition, the
studies indicate that chemical analyses of soil core samples
usually is a faster, easier and more economical method of soil and
ground water pollution evaluation than the analyses of ground water
samples collected from observation wells.
Due to the need to maintain the integrity of the primary and
secondary waste control barriers, it will be impossible to collect
soil core data into the ground water table below the actual chemical
waste disposal areas. Soil core data, however, will be collected
down-gradient of the facility near the barrier wells and monitoring
piezometers. The soil core samples over the entire saturated
vertical column of soil will be analyzed for various chemical
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parameters. The frequency-of core sample collection is estimated
to be semi-annually, one after the spring ground water recharge
season and the other approximately six months later after the
growing season. Initial soil core test data will be collected as
background data on soil characteristics.
Plant uptake of toxicants will be evaluated by conducting chemical
analyses on a select number of vegetation samples. Plants growing
on the land disposal area will, of course, be obvious candidates
for analysis' Plant residues which accumulate at the end of each
growing season will also be evaluated.
d) Air Quality Monitoring
Air quality monitoring will also be carried out around the site
by the applicant or by his subcontractors. Of major interest will
be the amount and chemical analysis of particulate matter.
Appropriate sample collection devices will be installed at locations
surrounding the site as well as the site. Temperature, precipi-
tation, wind velocity and wind direction will also be measured. Back-
ground air quality data will be collected before waste is placed
in the site.
e) Perpetual Monitoring
Surface water, ground water and air quality monitoring stations
will be selected for perpetual monitoring of the facility. As
outlined in the cost accounting strategies, a perpetual monitoring
fund will be built-up through user fees collected over the life
of the facility. After facility closure, interest from the per-
petual monitoring fund will be used to perpetually monitor the
surface water, ground water and air resources potentially impacted
by the facility. The principal in the perpetual monitoring fund
will then be available for emergency use at the facility if the
perpetual monitoring indicates that environmental degradation is
occurring or if maintenance is necessary at the facility.
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6.7 INSTITUTIONAL ARRANGEMENTS
This section of the demonstration grant application outlines the institutional
arrangements that will be utilized to implement the demonstration grant.
This section includes a summary of the state hazardous waste administrative
framework, two alternative facility owner/operator arrangements, grant admin-
istrative and regulatory responsibilities and the strategy the applicant will
use to select an operator for the facility. The various institutional arrange-
ments are discussed in the following subsections.
State Hazardous Waste Administrative Framework
Grant Administrative Responsibilities
Facility Ownership/Operator Arrangements
Facility Operator Selection Procedures
Facility Regulatory Responsibilities
6.7.1 State Hazardous Waste Administrative Framework
The overall state hazardous waste management administrative framework
being implemented by the applicant and by the counties is discussed in
detail in Section 6.2.2 of this grant application. In summary, counties
will prepare county-wide plans for hazardous waste management and will
adopt ordinances relative to hazardous waste'licensing, classification,
labeling, transportation, treatment and disposal.i Counties will
also review and issue hazardous waste generator licenses to generators
of hazardous waste. Counties will be the prime agency in the enforce-
ment of the generator license relative to classification, safe handling,
labeling, transportation and treatment/disposal of waste. Counties
will also review and issue licenses for hazardous waste treatment/
disposal facilities located in the county.
Under the state hazardous waste administrative framework, the applicant
will review and approve county hazardous waste plans, ordinances and
licensing procedures, develop a statewide hazardous waste management
plan and statewide hazardous waste regulations, review waste generator
licences before issuance by the county, issue hazardous waste treatment/
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disposal facility permits and review and periodically check the environ-
mental surveillance data supplied by the hazardous waste treatment/
disposal facilities. The Minnesota Public Service Commission will
license vehicles transporting hazardous waste and prescribe necessary
safety regulations.
The overall hazardous waste administrative framework represents a
combination of efforts between the counties, the applicant and the
Public Service Commission. Other agencies such as the regional planning
agency, municipalities and regional sewer agencies have supporting
roles in the hazardous waste management framework. In establishing
the institutional framework for the demonstration project, the applicant
has strived to establish institutional arrangements consistent with
the existing hazardous waste management administrative framework in
Minnesota.
6.7.2 Grant Administrative Responsibilities
The applicant will be directly responsible to the Environmental Protection
Agency for administering the grant, as well as for the timely and accurate
implementation of the project in accordance with all Federal, state, and
local requirements. The applicant will assign the demonstration funds
necessary for facility design, construction and operation to an inter-
mediate governmental agency with the legal authority to own the site
and will operate the facility or contract for facility operation. Two
alternative intermediate governmental agency/facility operator arrange-
ments have been identified and are discussed in detail in 6.7.3. The
governmental agency owning the site will then either operate the facility
or contract with the selected operator. The applicant will retain con-
trol of the demonstration project by an agreement with the selected
intermediate governmental agency. An intermediate governmental agency
must be utilized since the applicant does not have the authority to
own the site or operate the facility as outlined in the legal memorandum
included in Appendix I.
The facility operator will be responsible to the applicant for the
design, construction and operation of the chemical waste land disposal
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demonstration facility in accordance with all demonstration and project-
related requirements as established by the applicant. The applicant
will review and approve all facets of the design, construction and
operation of the project to insure that all procedures are carried out
in accordance with demonstration and project-related requirements.
The intermediate governmental agency will serve only as a vehicle to
own and either operate or contract for the operation of the facility.
The land upoh which the facility will be constructed will be owned by
the intermediate governmental agency. The intermediate governmental
agency will hold title to the land and will be responsible for the
perpetual maintenance and monitoring of the facility. Minnesota's
share of the matching grant money will be obtained by the intermediate
governmental agency through the sale of revenue bonds.
The design and construction of the environmental surveillance system
will be coordinated with the site operator, but will be carried out
by the applicant. The applicant will collect background environmental
monitoring data after the environmental surveillance system is con-
structed.
During the five-year demonstration grant period, the applicant, facility
operator, and intermediate governmental agency will have the following
responsiblities to carry out the demonstration project.
a) Applicant
The applicant will receive all federal money and will be responsible
to the Environmental Protection Agency for carrying out the various
demonstration and project-related activities as detailed in the
grant agreement between the applicant and the Environmental
Protection Agency. The applicant will administer the grant through
the following responsibilities.
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1) Select the SiteAs>discussed in Section 6.3, two potential
sites for the demonstration facility have been selected.
After grant award, the feasibility of contructing the demon-
stration facility at these two sites will be investigated
through the collection of additional background data prin-
cipally in terms of citizen and regulatory agency acceptance.
It is anticipated that the necessary permits and approvals
can be obtained for one of the two sites, however, additional
sites may have to be evaluated if the two sites prove to
be unacceptable. The applicant will select the final site
for the facility.
ii) Select the OperatorThe applicant will select the facility
operator using the procedures discussed in Section 6.7.4.
iii) Arrange Minnesota's FundingThe applicant will coordinate
and be responsible for supplying the nonfederal share of the
demonstration grant. Nonfederal grant money will be placed
into an account with the Federal demonstration money. All
project costs will be drawn from this account.
iv) Approve Annual Operating BudgetsThe applicant will approve
annual operating budgets prepared by the facility operator
for each year of the demonstration project. The annual
operating budget will include all money for facility
operation, design, construction, equipment and related needs
spent by the facility operator.
v) Select Demonstration Processes and TechniquesThe applicant
will have final approval on all demonstration processes and
techniques to be incorporated into the demonstration project.
The applicant will base approval on the grant agreement,
on the evaluative criteria outlined in the demonstration
grant application, on the recommendations of the applicant's
staff and on the recommendations of the operator. The
Environmental Protection Agency will be included in the
selection of the various processes and techniques.
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vi) Approval of SubcontractsThe applicant will retain approval
authority over all subcontractors retained by the operator.
vii) Public Education ProgramThe applicant will be responsible
for carrying out the various citizen acceptance and public
education programs outlined in Section 6.10. The applicant
will coordinate the various citizen acceptance and public
education programs with the operator and insure that the
facility is available for the various programs.
viii) Approve Construction Plans and SpecificationsThe applicant
will review and approve all construction plans and specifications
prepared by the facility operator or the facility operator's
subcontractors. Approval will be based on the demonstration
project objectives and on the processes and techniques
selected for incorporation into the project.
ix) Approve Operating ManualsAs discussed in Section 6.8,
operating manuals will be prepared by the facility operator
for all key waste flow management points within the facility.
These operating manuals will detail the procedures and
techniques to be used in managing waste flow through the
facility.
x) Approve Job DescriptionsThe applicant will approve all
job descriptions for personnel to operate the facility
prepared by the facility operator.
xi) Approve Cost Accounting StrategyThe applicant will have
review and approval authority over the cost accounting strategy
recommended by the facility operator for incorporation into
the demonstration project. Approval will be based on the
demonstration project objectives and on the evaluative
criteria outlined in Section 6.9 of the demonstration project.
xii) Inspect Facility ConstructionThe applicant will inspect the
construction of the facility. Since the facility operator
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will also be responsible for inspecting facility construction,
.the applicant's inspection will likely take the form of
reviewing the facility operator's project inspection efforts.
xiii) Monitor Facility Start-up and Routine OperationThe
applicant will monitor and inspect the start-up and routine
operation of the facility to insure that the various demon-
stration project objectives, operating agreements and
operating manuals are being followed.
xiv) Coordinate Waste Flow to the FacilityAs discussed in Section
618, the generator licensing program will be a useful tool
to plan and, if necessary, regulate the flow of waste to the
facility. The applicant will be responsible for coordinating
this planning and regulatory effort and will inform the
operator of expected facility waste volumes on a quarterly
basis. The applicant will also approve all waste acceptance
criteria. If necessary, the applicant will also coordinate
the regulation of waste to the facility by imposing necessary
restrictions on the waste generator licensing program.
xv) Design and Construct Environmental Surveillance SystemThe
applicant will be responsible for the environmental
surveillance of the site including the design and construction
of the environmental surveillance system.
xvi) Collect Environmental Surveillance DataThe applicant or
the applicant's subcontractors will collect all environ-
mental surveillance data during the demonstration period.
This will include the monitoring of surface water, ground
water, air quality, soil and vegetation.
xvii) Project Reports and Annual AuditThe applicant will be
responsible for completing all interim and other reports
connected with the demonstration grant. The applicant will
also be responsible for carrying out an annual audit on the
demonstration project.
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b) Facility Operator
During the demonstration period, the facility operator will have
the following project responsibilities:
i) Prepare an annual operating budget and submit the budget to the
applicant for review and approval.
ii) Select subcontractors to assist in the planning, design,
construction and operation of the facility.
ill) Recommend processes and techniques to be included in the
demonstration project.
iv) Prepare plans and specifications for the construction of the
demonstration project.
v) Prepare operating manuals for key waste flow management
points within the demonstration facility.
vi) Obtain the necessary operating permits and approvals from
the various local, county, regional and state agencies.
vii) Order the necessary equipment to operate the facility within
the annual operating budget.
viii) Recommend a cost accounting strategy to be implemented at
the facility.
ix) Advertise and let contracts for the construction of the
facility consistent with the plans and specifications as
approved by the applicant and within the annual operating
budgets.
x) Inspect the construction of the facility to insure that the
approved plans and specifications are followed.
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xi) Prepare job descriptions and hire personnel to operate the
facility.
xii) Operate an environmentally-safe facility consistent with
the operating manuals and demonstration project objectives.
xiii) Carry out the necessary demonstrations at the project includ-
ing the collection of data sufficient to evaluate the demon-
strations.
xiv) Furnish the demonstration and operational data to the applicant
in the form of interim data reports and in the form of an annual
operating report.
xv) Make the facility available to the applicant's public education
efforts.
xvi) Conduct an annual operational audit of the facility.
c) Intermediate Governmental Agency
As discussed earlier in this subsection, an intermediate governmental
agency will be utilized to own the site and to either operate the demon-
stration facility or contract for the operation of the facility. Two
alternative intermediate governmental agency/operator frameworks have
been identified and are discussed in 6.7.3. Under the proposed grant
administrative responsibilities framework, the intermediate govern-
mental agency will:
i) Purchase the land with demonstration project money.
ii) Own the land upon which the demonstration facility is constructed
and be responsible for perpetual monitoring and maintenance.
iii) Transfer money from the applicant to the operator since the
applicant does not have the authority to operate or to
contract for the operation for the demonstration facility as
outlined in the legal memorandum contained in Appendix I.
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iv) Furnish the nonfederal share of the demonstration grant.
6.7.3 Facility Ownership/Operator Arrangements
The applicant has identified two alternatives for ownership and
operation of the demonstration facility. Both of the alternatives
will meet the demonstration project objectives. One alternative
involves ownership and operation by a public agency and the second
alternative involves public ownership with private sector operation.
Under both alternatives, the applicant will be directly responsible to
the Environmental Protection Agency for administering the demonstration
grant as well as for the timely and accurate implementation of the
project in accordance with all Federal requirements. As discussed
previously, the applicant does not have the authority to operate
the facility or own the land utilized for the facility. Therefore,
an intermediate governmental agency is needed to own the site and either
operate the facility or contract for operation of the facility. Under
both ownership/operator alternatives, the applicant will review and
approve the design, construction and operation of the facility to
insure that all procedures are carried out in accordance with demon-
stration and project-related requirements.
a) Metropolitan Waste Control Commission Ownership and Operation
Alternative
Under this alternative, the applicant will assign the demonstration
funds necessary for facility design, construction and operation
to the Metropolitan Waste Control Commission (MWCC). The MWCC
is the regional agency responsible for the design and operation
of the sanitary sewer system in the seven county Minneapolis/
St. Paul metropolitan area. The MWCC was formerly referred to as
the Metropolitan Sewer Board. The MWCC may then subcontract the
design and construction of the facility although all subcontractors
retained by the MWCC will be approved by the applicant. The
Metropolitan Waste Control Commission will own the land upon which
the facility is constructed and will be responsible for the
perpetual monitoring and care of the site. The MWCC will be
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responsible to the applicant for the design, construction and operation
of the chemical waste land disposal demonstration facility in
accordance with all demonstration and project-related requirements
as established by the applicant. Guidelines within which the MWCC
will carry out these responsibilities will be stipulated in the
contract between the applicant and the MWCC. The applicant will
review and approve the design, constuction and operation of the
project to insure that all procedures are carried out in accordance
with demonstration and project-related requirements. Minnesota's
share of the matching grant money will be furnished by the MWCC
under this alternative.
The MWCC has passed a resolution authorizing an agreement with the
applicant as a prime contractor to manage a chemical waste land
disposal site in order to carry out the applicant's responsibilities
under the demonstration grant. A copy of the resolution is included
in Appendix E.
b) County Ownership/Private Operation
Under this alternative, the applicant will assign the demonstration
funds necessary for facility design, construction and operation
to a county in the Minneapolis/St. Paul metropolitan area. The
county will contract with a facility operator selected from the
private sector using the nationwide search procedures outlined in
6.7.4. The facility operator will be responsible to the applicant
for the design, construction and operation of the chemical waste
land disposal facility in accordance with all demonstration and
project-related requirements as established by the Environmental
Protection Agency and the applicant. Guidelines within which
the facility operator will carry out these responsibilities will
be stipulated in a contract between the applicant and the county
and between the county and the facility operator. The applicant
will review and approve the design, construction and operation of
. the project to insure that all procedures are carried out in
accordance with the demonstration and project-related requirements.
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The county will serve as a vehicle to contract for the operation
of the facility since, as indicated previously, the applicant does
not have the authority to contract directly for the operation.
The land upon which the facility will be constructed will be owned
by the county. The county will, therefore, be responsible for the
perpetual maintenance and monitoring of the facility using money
generated from the facility user fees. Minnesota's share of the
matching grant money will be obtained by the county through the
sale,of'revenue bonds likely underwritten by all the counties in
the metropolitan area.
The applicant has worked closely with the metropolitan counties
and county planning agency in developing the institutional arrange-
ments for 'this 'demonstration project. The counties are interested
in" being the'intermediate governmental agency to own the site and
contract for facility operation, however, a county board resolution
could not be obtained prior to grant application. A copy of1the
resolution will be forwarded to the Environmental Protection Agency
as soon as it is received from the county.
c) Discussion of Alternatives
The following advantages and disadvantages of the two alternative
fac.ility ownership/operator frameworks have been identified
by the applicant:
The Metropolitan Waste Control Commission reportedly
has sufficient money available to furnish Minnesota's share of
the demonstration grant. The counties, on the other hand, will
issue revenue bonds to generate Minnesota's share of the demon-
stration grant. Due to project time constraints, money availability
would seem to give a slight advantage to the Metropolitan Waste
Control Commission alternative although a reasonable amount of
time has been provided in the implementation schedule to issue
revenue bonds.
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The Metropolitan Waste Control Commission indicates they have the
legal authority under existing legislation to own and operate the
demonstration facility. Likewise-, the counties have the legal
authority to own and contract for the operation of the demonstration
facility under the existing solid and hazardous waste legislation.
Both agencies also have the authority to collect fees from facility
users.
At the present time, counties have solid and hazardous waste
operating responsibilities throughout the state. Debate is presently
occurring as to*whether solid and hazardous waste operating
responsibilities should be regionalized in the metropolitan area.
County ownership and contracted operation of the facility, therefore, is
consistent with existing solid and hazardous waste planning
legislation. This would seem to present an advantage to the county
alternative.
Regulatory relationships would seem to be stronger and better
defined under the Metropolitan Waste Control Commission alternative.
The county in which the facility is located will have responsibilities
in the regulation of the chemical waste land disposal facility.
Mixing county ownership and operation with county regulatory
responsibilities may weaken the regulatory responsibilities of
the county alternative.
The need for the site is the result, at least in part, of pre-
treatment regulations being promulgated by the Metropolitan Waste
Control Commission. These pretreatment regulations will control
the discharge of chemical waste to the sanitary sewer system and
necessary pretreatment will lead to the generation of large
quantities of chemical sludge. It could be argued that the Metro-
politan Waste Control Commission should carry the responsibility
of providing an alternate means of disposal for this sludge.
The Metropolitan Waste Control Commission and the counties have
powers of eminent domain and both can obtain the necessary technical
expertise to design and construct the facility.
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The counties are willing to select the most qualified operator
from the private sector. Experience available in the private
sector will be useful in operating the demonstration facility,
therefore, the commitment to use private sector operation would
seem to represent an advantage to the county ownership/private
operator alternative.
In summary, the Metropolitan Waste Control Commission owernship/
operator alternative has the following advantages:
i) Stronger and more clearly defined regulatory relationships
ii) Has money available to provide Minnesota's share of the grant
iii) Involved in the generation of chemical waste sludges
The county ownership/private sector operator alternative has the
following advantages:
i) Consistent with existing solid and hazardous waste operating
legislation
ii) Willing to utilize expertise and efficiency of the private
sector
d) Selection of Ownership/Operator Framework
Due to time constraints placed on the preparation of the grant
application by the Environmental Protection Agency, the applicant
has not been able to reach a final decision on the ownership/
operator alternative to be incorporated into the demonstration
project. The Minnesota Legislature will also be considering a
transfer of the solid and hazardous waste operating responsibilities
from the counties to a regional agency in the Minneapolis/St. Paul
metropolitan area during the current legislative session which
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began in1January. For these reasons, the applicant proposes to
continue to evaluate the two ownership/operator alternatives after
grant application submittal and prior to grant award. If required
by the Environmental Protection Agency, the applicant will select the
facility ownership/operator framework during the grant application
review period prior to grant award. The applicant's decision will
be based on the status of legislation to reorganize the solid and
hazardous wasjte responsibilities and on the interest expressed by the
principals in the two ownership/operator frameworks.
The applicant wishes to emphasize that both of the two ownership/
operator alternatives will "get the job done". Both are consistent
with existing legislation and no new legislation will be needed
to implement either alternative. Both alternatives have stable
funding sources and the ability to acquire land through eminent
domain, if necessary. The intermediate governmental agencies
involved in both alternatives have many other responsibilities
and can be expected to be in existence for perpetuity to carry out
the necessary perpetual monitoring and maintenance activities at
the facility after closure. Both intermediate governmental agencies
have expressed an interest in owning and operating the demonstration
facility.
6.7.4 Facility Operator Selection Procedures
This section of the demonstration grant application discusses the
procedures to be used by the applicant to select a facility operator if
the county ownership/operator framework is selected for incorporation
into the demonstration project. If the MWCC alternative is selected,
the MWCC will also likely operate the facility and the following
selection procedures will not be needed.
The company or agency selected to eventually operate the land disposal
facility is, of course, a component critical to a successful demon-
stration project. The operator must have personnel well-qualified
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in terms of experience and'education with the ability to work with the
general public and with the regulatory agencies monitoring the planning,
design and operation of the facility.
Due to the severe time constraints placed on the submittal of the
grant application by the Environmental Protection Agency, the applicant
was unable to select an ownership/operating framework. If the county
ownership/private sector operator alternative is selected, a nationwide
search and evaluation of the various industries of the private sector
interested in operating the demonstration facility will be conducted
by the applicant. Under state law, the applicant must conduct such a
nationwide search to find the most qualified operator. For this reason,
a private sector operator to go with the county ownership/private sector
operator alternative has not been selected.
The operator selection procedures, however, have been established.
In order to locate qualified potential 'operators for the facility from
the private sector, the applicant contacted the National Solid Waste
Management Association. The National Solid Waste Management Association
submitted a list of nine industries the Association believes would
be interested and qualified to operate the disposal facility.
A Solicitation of Interest has been prepared by the applicant and will
be forwarded to the nine chemical waste management industries if the
county alternative is selected. The Solicitation of Interest outlines
the details of the demonstration project and requests interested
industries to submit the qualifications and experience that would enable
them to carry out the responsibilities of the facility operator.
After reviewing the responses from the interested operators, the
applicant will interview the three or four most qualified operators.
Based on these interviews and based on the qualifications submitted
in response to the Solicitation of Interest, the applicant will select
a facility operator. Upon selection, the applicant will enter into
a contract with the county and the county will enter into a contract with
the facility operator to design, construct, and operate the facility.
All contracts will be submitted to the U.S. Environmental Protection
Agency for review and approval.
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The following operator selection criteria will be utilized by the
applicant in reviewing the qualifications and experience records of
the potential facility operators:
a) Ideally, the candidate operator should have a record of experience
in the land disposal of waste (i.e., waste placement, compaction,
covering, equipment maintenance, monitoring, collection of user
fees, etc.), as well as experience in hazardous waste management
(i.e., proper disposal methods with practical yet environmentally-
safe alternatives, transportation, storage, handling, treatment,
and safety precautions).
In the alternative, the candidate must either:
i) be able to show an experience record in the land disposal of
waste and be able to exhibit an understanding of hazardous
waste management; or
ii) be able to show an experience record in hazardous waste
management and be able to exhibit an understanding of the
land disposal of wastes.
b) The candidate should have in-house experience in designing,
constructing and operating a project of the size envisioned in
the grant application (i.e., 100 acres, 500,000 dollars per year
estimated gross income, coordinating many diverse disciplines in
design and operational activities) and must be willing to operate
the project as the parent company and not as a separate single
project entity.
c) The candidate must demonstrate a record of good working relationships
with various regulatory agencies either in Minnesota or in other
states. A list of all regulatory agency permits and licenses held
by the candidate must be furnished.
d) The candidate must furnish a detailed experience record of the
person responsible for direct management of the chemical waste
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land disposal facility. The person so indicated must be willing
to. spend 100 percent of his or her time on the project or on project-
related activities and not less than 90 percent of his or her time
at the project site. The project manager must have a broad back-
ground in chemical materials handling and in the management of
projects involving a number of diverse disciplines.
e) The candidate must exhibit an experience record in working with
local citizens and with local, regional and state decision makers
(in Minnesota or in other states) in gaining citizen acceptance
for the potentially unpopular activities. A list of projects
demonstrating this experience should be furnished.
f) The candidate should be sound financially and be able to obtain
the necessary bonding and insurance to construct and operate the
facility.
6.7.5 Facility Regulatory Responsibilities
The operation of the facility will be regulated by the applicant as
well as by the county and municipality in which the facility is
located. All permits and approvals will be obtained by the facility
operator with the cooperation and assistance of the applicant. The
following responsibilities will be utilized to regulate the facility:
a) Applicant
The demonstration facility must obtain a number of permits from
the applicant. These permits will include a solid waste permit,
an air quality permit (if the facility has an air emission),
an NDPES permit (if the facility has a discharge to public water),
and a treatment facility permit. Since the applicant will be
responsible for reviewing and approving the design, construction
and operation of the facility, it is anticipated that the necessary
operating permits can be obtained from the applicant.
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b) County
A solid waste facility license will have to be obtained from the
county in which the facility is located. In order to obtain a
county solid waste license, the facility operator will likely be
required to furnish a performance bond and the facility must meet
certain operational and environmental protection criterial In
addition, the county will review the design of the facility and
the location of the facility to insure that the facility is
consistent with the county solid waste plan. The county also
has the authority to regulate user fees charged by the facility.
The county will likely be the mechanism for regulating user fees
based on the recommendations by the applicant.
c) Municipality
The municipality in which the facility is located has the authority
to grant various building permits, utility permits and land
alteration permits. The municipalities will also be given the
opportunity to review and comment on the various state and county
permits and licenses.
d) Other Regulatory Responsibilities
The solid waste permit must be approved by the Metropolitan
Council (regional planning agency) before issuance by the applicant.
By the time the facility is constructed, and industrial discharge
permit to discharge liquid waste to the metropolitan sanitary
sewer system will likely have to be obtained from the Metropolitan
Waste Control Commission. Highway access permits will also have
to be obtained from the Minnesota Highway Department.
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6.8 FACILITY MANAGEMENT STRATEGY
This portion of the demonstration grant application presents the various
facility management strategies to be used at the facility during routine
operation. The facility management strategies are summarized according to
the following activities:
Waste Flow Management
Management of Don-Waste Flow Activities
Equipment and Buildings
Project Personnel Needs During Operation
Personnel Training Programs
6.8.1 Waste Flow Management
This section of the demonstration grant application illustrates the
generalized flow of waste through the disposal facility and discusses
the various waste flow management techniques that will be evaluated
for incorporation into the project. A generalized waste flow diagram
for the demonstration facility is illustrated on page 6-91. As shown
by this diagram, waste flow through the facility will be by way of the
following four major components:
Waste Receiving
Waste Storage
Waste Preparation
Land Disposal
The purpose of the following paragraphs is to discuss the various
management techniques that will be evaluated for use within each
waste flow component and to discuss the various transfer techniques
that will be evaluated to transfer waste between the various components.
a) Waste Receiving
A brief overview of the statewide hazardous waste administrative
program is needed to obtain a clean understanding of the management
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techniques needed at the demonstration project's waste receiving
station. The overall hazardous waste administrative program being
implemented in Minnesota by the applicant and by the counties
includes the following assignment of responsibilities for handling
hazardous waste.
Treatment/
Generator »»- Transporter ^-Disposal Facility
Each of the three-functions outlined above (Generator, Transporter,
Treatment/Disposal Facility) will carry out a unique role in the
proper management of hazardous waste in Minnesota. The following
breakdown of responsibilities between the three functions is being
implemented:
Generator - Under the hazardous waste management system being
implemented in the Minneapolis/St. Paul metropolitan area,
every generator of hazardous waste will be responsible for
obtaining a hazardous waste generator license from the appro-
priate county. The license will indicate the quantity and
characteristics of the hazardous waste or wastes being generated,
means of on-site storage including safety precautions, method
of transporting the waste to the final treatment/disposal
facility and the locations of the final treatment/disposal
facilities which will be used to dispose of the generator's
hazardous waste. After obtaining the license, the generator
will be responsible for properly classifying the waste as
hazardous and will be responsible for separating and labeling
the waste consistent with the hazardous waste generator license
and with the statewide hazardous waste regulations currently
being drafted by the applicant. The generator will also be
responsible for employing a transporter with a valid license
from the Minnesota Public Service Commission to transport
hazardous waste, advising the transporter of the presence of
the hazardous waste and advising the transporter of the treat-
ment/disposal facility set forth in the generator license.
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CHEMICAL WASTE STREAM
Inspect, Samole, Label, Weigh,
Assign Flow Route
| Storage I | Storage | | Storage | | Storage] | Storage! | Storage | | Storage ] | Storage |
o
?
<
I
Ul
at
a.
Ul
^
1/1
pH<7
ENCAPSULATION! BLENDING
| Cement | |Po1ymer|
EUTRALIZATIO
m
SEPARATION
oo
Return for Additional Waste Preparation
UL1
!
' \
i
FIXATION
OTHER
_r
MATERIALS TRANSFER
Inspect, Sample, Route
"* To Another
Fom of
Hazardous
Waste
Disposal
Supernatent
To Off-Site
Sewage
1/1
Liquid Slurry Sludge Solid
1 I I 1
LAND DISPOSAL AREAS
With Various Demonstration Areas
Leachate & Surface
Runoff Collection Systems
Recirculate to
Land Disposal Area
Return for Additional Waste Preoaration
Storage
Treatment
Plant
FIGURE 6-9. CHEMICAL WASTE FLOW DISPOSAL FACILITY
-------
All of the above information will be transferred from the
generator to the transporter by way of a "hazardous waste
shipping paper". The shipping paper will be used to describe
the hazardous waste and will accompany the hazardous waste
as it moves from the generator's property. The shipping paper
will contain the hazardous waste characteristics and quantities
contained in the shipment. The location of the permitted
treatment/disposal facility as well as the name of the licensed
transportation company transporting the waste will be included
on the shipping paper. If all waste is going to the same
treatment/disposal facility, one shipping paper will be adequate.
If the shipment is to be transported to more than one treat-
ment/disposal facility, one shipping paper should be used for
each facility. Compliance with the above procedures will
transfer responsibility for proper hazardous waste management
from the generator to the transporter.
Transporter - Under the hazardous waste management system being
implemented in Minnesota, the transporter will be responsible
for obtaining and maintaining an up-to-date license from the
Minnesota Public Service Commission to transport hazardous waste.
Upon receiving the hazardous waste and the hazardous waste
shipping paper from the generator, the transporter's respons-
ibility will be to safely carry the hazardous waste to the
treatment/disposal facility designated on the shipping paper.
The transporter's responsibility for proper hazardous waste
management will terminate after the waste is delivered to the
treatment/disposal facility and after personnel at the treat-
ment/disposal facility are made aware of the hazardous nature
of the waste through the transfer of the hazardous waste
shipping paper.
Treatment/Disposal Facility - Upon receiving the properly
labeled hazardous waste along with the properly completed
shipping paper, the responsibility of the treatment/disposal
facility will be to treat and dispose of the hazardous waste
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in accordance with state, county and local regulations. A
copy of the hazardous waste shipping paper will be furnished
by the treatment/disposal facility to the regulatory agency
issuing the hazardous waste generator license as a record of
the generating source, type and volume of waste, and methods
of transportation, treatment and disposal.
It is emphasized that enabling legislation to implement the
administrative system outlined above has been passed by the
Minnesota -Legislature. The administrative system is currently
being implemented by the counties and by the applicant. The
complete program will be implemented at least in the Minneapolis/
St. Paul metropolitan area and likely statewide, by the time the
chemical waste land disposal demonstration facility is operational.
The generator licensing system being implemented in Minnesota
gives the applicant the ability to plan and, if necessary, regulate
the flow of chemical waste to the demonstration facility. For
example, a condition of the generator license may be that the
license must be obtained 60 or 90 days before waste is transported
to a disposal facility. Since the license application will detail
estimated waste types and quantities, the lead time will give the
applicant and facility operator necessary time to plan the flow
of the various wastes through the facility.
Since the final disposal location will be stipulated on the
generator license, the generator license can also be utilized to
regulate the flow of waste to the various hazardous waste dis-
posal facilities. For example, if incineration of a certain waste
is environmentally safer than land disposal, incineration will be
stipulated on the generator license. Thus, the generator licensing
system gives the applicant the necessary planning tool to predict
waste quantities arriving at the demonstration facility and to
divert wastes to or from the facility.
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The applicant and facility operator will establish waste acceptance
criteria as outlined in Section 6.7.2. These criteria will establish
minimum or maximum waste characteristics (such as pH, water content,
radioactivity, etc.) above or below which the waste will not be
accepted. These threshold waste characteristics will be based
on the waste processes and site preparation area techniques
selected for incorporation into the facility. The applicant intends
to avoid limiting the inflow of waste to the facility as much as
possible, but the applicant recognizes that some wastes may have
to be limited"unless the disposal facility has the capability to
prepare and safely dispose of all chemical wastes.
Waste acceptance criteria will be difficult to enforce if waste
acceptance or rejection judgements must be made at the facility's
receiving station. The generator licensing system will enable the
applicant to enforce the waste acceptance criteria by allowing
the acceptance/rejection decision to be made before the waste is
transported to the disposal facility.
All chemical waste transported to the demonstration facility will
be accompanied by a shipping paper summarizing the characteristics
and quantities of the various wastes in the shipment. As a
practical matter, it is recognized that the detail of information
contained in the shipping paper will vary depending on the cap-
abilities of the waste generator. A minimum level of detail,
however, will be established by the demonstration facility operator,
the applicant and the county regulatory agency. At the demonstration
project's receiving station, the shipping paper will be reviewed
for completeness and the waste containers will be reviewed for
proper labeling. If the shipping paper or labels do not meet
appropriate requirements, the waste will not be accepted. It
will then be the obligation of the waste transporter to return the
waste to the waste generator, who must revise the shipping paper
or relabel the waste in conformance with state and county regulations
and have the waste redelivered to the disposal facility.
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Upon acceptance by the facility, pertinent data from the shipping
paper will be recorded and the various wastes will be weighed.
The objective will be to keep an accurate record of the types and
quantities of chemical wastes entering the demonstration facility.
A sample of each waste will be obtained and sent to the laboratory
for gas chromatograph/mass spectrometer analysis. The waste will
next be assigned a flow route through the demonstration facility.
The flow route assigned will be based on the type of waste, as
well as .the demonstration needs and work load of the facility.
General flow routing schedules will be developed prior to waste
arrival through use of the generator licensing data. The waste
will be assigned an identification number coded to the type of
waste and to the flow route through the facility. All of the above
activities will be carried out by the facility operator.
Once the flow route and identification code have been assigned,
the waste will be separated and transferred to a storage area
on the basis of the assigned initial waste preparation process.
When the chemical analyses are available from the laboratory,
the analyses will be coded with the waste identification number
and sent to the waste preparation area where the waste is stored.
All procedures to be used in the demonstration project's receiving
station will be summarized in a "Receiving Station Manual" prepared
by the facility operator and approved by the applicant. This
manual is necessary to avoid confusion and misunderstandings
relative to the acceptance, identification, analyses, and routing
of waste through the disposal facility. The facility operator will
make acceptance and routing decisions using the procedures out-
lined in the manual. The manual will be continually updated to
reflect new equipment, procedures and the most efficient and
environmentally-safe methods of operating the facility. This
type of communication and implementation system will be utilized
at key points throughout the facility.
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b) Waste Storage
Once the waste has cleared the receiving station, it will be trans-
ported to one of the various storage areas at the facility. Storage
areas will be provided for each of the waste preparation techniques
available to prepare the waste prior to disposal. Delivery to the
storage areas will be by truck or fork lift if the materials are
in barrels or drums, or by the original transport truck if the
material is in hulk volume. Holding tanks will be provided at the
various storage areas to store waste delivered in bulk. Once the
waste is in the waste preparation storage area, additional separation
will likely take place for safety purposes. For example, waste
delivered to the neutralization waste preparation storage area may
be stored in separate areas if the pH is less than 3, in another
area if the pH is between 3 and 7, and in another area if the pH is
greater than 7. Waste utilized as reagents in chemical precipitation
processes may also be stored in separate areas of the storage area.
Wastes will be stored in the waste preparation storage areas until
sufficient quantities have accumulated to prepare a batch of chemical
waste for land disposal.
Operating manuals will be prepared by the operator and approved by
the applicant for each storage area. The manuals will set forth
wastes to be stored in the area as well as clearly define occupa-
tional safety and health measures and waste transfer instructions.
Waste unloading and storage areas will be equipped with catch
basins to collect any spilled material. All work areas will
be equipped with emergency and safety equipment and apparel for
employees including safety showers, independent breathing equipment,
chemical and fire resistant clothing, fire-fighting devices and
alarm systems to warn of hazardous conditions.
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c) Waste Preparation
Once a sufficient quantity of chemical waste has accumulated in
the waste preparation storage area to warrant its preparation for
disposal, the quantity of waste will be transported to the actual
waste preparation area. The various waste preparation areas may
be located adjacent to the storage areas to save waste transfer
cost. Methods used to transfer the waste from the storage area
to the preparation process area will be designed in accordance
with the expected waste quantities, waste types and operating
conditions. As discussed in Section 6.5, a number of basic waste
preparation techniques have been initially selected and additional
techniques will be evaluated for incorporation into the demonstration
project.
The primary purpose of the various selected waste preparation
techniques will be to insure a supply of waste with a wide range
of characteristics for demonstration purposes. Operating manuals
will be prepared by the operator and approved by the applicant for
each unit preparation process. The manuals will detail procedures
to be used in the process, maintenance requirements, record keeping
and waste handling precautions.
Once the waste has gone through the waste preparation process, the
portion of the waste intended for land disposal will either go
directly to the disposal area or into storage to await disposal.
The waste may be input to another waste preparation process in which
case it will be transferred to the waste storage area serving the
second waste preparation process. In all likelihood, the routing de-
cision for the waste will be made at the time the original routing was
assigned. Supernatent from the waste preparation process will either
go to an off-site municipal wastewater treatment facility with or
without pretreattnent or to a storage area prior to use in a second
waste preparation process. If the waste is internally routed to
another storage area, it will be weighed, labeled and analyzed,
as necessary. In the early stages of the demonstration project
and for nonroutine wastes, the decision whether to dispose of the
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supernatant at the treatment facility or reroute the supernatent
through the demonstration facility will be based on the quality
and quantity of the supernatent and on the needs of the facility.
Once the various routing and waste disposal procedures have been
established, the flow route for the supernatent will likely be a
matter of routine and appropriate routing procedures and will be
included in the Receiving Station Manual.
d) Land Disposal
As appropriate, waste will be transferred from the various waste
preparation processes and from the various storage areas to the
land disposal areas. The waste placement techniques to be evaluated
for incorporation in the demonstration project are discussed in
Section 6.4.4. As discussed in Section 6.4.4, the waste may be
in the form of solids, sludges, slurries or liquids so a wide
variety of placement techniques and supporting equipment will be
necessary.
Prior to the placement of any liners, sealants, or leachate
collection facilities in the demonstration area, the area will
be subdivided using a convenient grid system (a 100' x 100' grid
system is recommended for preliminary discussion purposes).
Sufficient horizontal and vertical grid control points will be
permanently established so any portion of the grid system can be
quickly re-established in the field. All wastes placed in the
disposal areas will be sampled and their characteristics and
location in the grid system will be recorded. In this way, a very
careful record of the location of all wastes will be maintained.
The leachate data collected from various sub-areas of the overall
disposal area can then be compared to the types and characteristics
of the waste placed over the leachate collection systems. Main-
taining a careful record of the waste characteristics and locations
will also facilitate recovery of valuable waste products at a
future date. A large-scale map of the disposal area will be
maintained illustrating the type of leachate control system used,
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the type of wastes deposited and the waste placement technique
used in each of the grid areas. This map and supporting documents
will provide an easy-to-understand reference to the management
techniques used in the land disposal area. For reasons of security,
disposal records will be maintained in duplicate at separate locations.
As in the other waste flow components, a Land Disposal Operating
Manual will be developed by the facility operator and approved by
the applicant. The operating manual will summarize the acceptable
land disposal procedures as well as safety precautions and equip-
ment maintenance procedures to be used. Record keeping will also
be detailed.
6.8.2 Management of Non-Waste Flow Activities
A number of on-going management activities will be necessary to support
the various waste flow management concepts outlined in Section 6.8.1.
The purpose of this section of the grant application is to discuss
the various necessary support activities and outline the various
management techniques that will be evaluated. The following non-waste
flow activities have been identified:
Disposal Area Preparation
Leachate Collection and Treatment
Environmental Surveillance
Other non-waste flow management activities such as management of
equipment and buildings, project personnel, and personnel training
programs are discussed in subsequent subsections of Section 6.8.
a) Disposal Area Preparation
The disposal area will be prepared by the facility operator or
by the facility operator's subcontractors, using plans and spec-
ifications prepared under the direction of the facility operator
and approved by the applicant. The various disposal area preparation
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techniques to be used in the demonstration project will be based
on the evaluations described in Section 6.4 of this grant application.
It is anticipated that approximately 10 to 15 acres of land disposal
area will be initially prepared. The area of the initial disposal
site will depend on construction and equipment costs at the time
of construction. Additional areas will be prepared as necessary
during the progress of the demonstration project and after the
demonstration period is completed using capital generated by user
fees. It is emphasized that all disposal area preparation will
be carried out in accordance with approved plans and specifications.
No field design of disposal areas will be permitted and design
changes must be approved in writing by the applicant.
b) Leachate Collection and Treatment
Leachate collection and treatment facilities will be constructed
as part of the disposal area preparation activities discussed in
the preceding paragraphs. All leachate collection and treatment
facilities will be constructed and operated by the facility operator
or his subcontractors using methods and procedures approved by the
applicant. A Leachate Collection and Treatment Manual will be
prepared by the applicant. This manual will set forth the allowable
discharge requirements to the wastewater treatment facility,
acceptable procedures for recirculating leachate through the
receiving station, and general maintenance and operating procedures
for using the various leachate collection and treatment systems. This
rather formal means of communication between the applicant and the
facility operator is believed to be necessary to avoid misunderstandings
with regard to the treatment and collection of leachate.
c) Environmental Surveillance
The environmental surveillance of the demonstration project
will be carried out by the applicant or by the applicant's sub-
contractors, This is believed to be necessary to insure the
credibility of the environmental monitoring results from the project.
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An annual environmental surveillance plan will be drafted by the
applicant each year. This plan will summarize the air, water, soil
and vegetation monitoring programs in terms of sampling frequency,
sampled parameters, sample collection methods, preservatives, and
storage and analyses techniques to be used during the year. All
sampling and analyses methods used in the environmental surveillance
program will be carried out in accordance with Environmental Protection
Agency recommended procedures. The laboratory located at the disposal
facility will be used by the applicant's subcontractors for the bulk
of the environmental surveillance monitoring. The applicant's lab-
oratory, which is a part of the Minnesota Department of Health, will
also be used to periodically split samples to insure that proper
analyses and laboratory procedures are being followed.
6.8.3 Equipment and Buildings
The following equipment and buildings will be evaluated for incorporation
into the demonstration project.
a) Equipment
The equipment necessary to operate the demonstration project will
include the waste preparation process equipment as well as the
equipment necessary to transfer the wastes between the waste flow
components discussed in Section 6.8.1. Waste preparation process
and waste transfer equipment, however, have been included within
the waste management processes discussed previously. Equipment
will be needed to properly place the waste in the land disposal
areas. It is anticipated that an earthmover, dozer and trucks
will be needed for waste placement activities. The need for a
crane to lift the waste into place and the need for various pumps
and converyor systems will also be evaluated. A scale will be
needed at the waste receiving station. Clerical equipment will
be needed to carry out the clerical activities of the project. -
The need for a small computer in the cost accounting program will
be evaluated by the facility operator and by the applicant. The
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decision will be based on the expected volume of business and
on the cost accounting strategy used at the facility.
Fire protection and other emergency equipment will also be needed.
The two selected site location have the advantage of being close
to existing chemical fire-fighting equipment. The Pine Bend Site
is adjacent to an oil refinery and the Flying Cloud Site is
adjacent to an airport at which chemical fire-fighting capabilities
are being planned. Fire-fighting equipment at the site will include
foam and necessary nozzels and hose as well as a water supply
system capable of producing 200 gallons per minute. Other emergency
equipment to be evaluated for incorporation into the project will
include safety showers, self-contained breathing apparatus, fire
and chemical resistant clothing and first-aid equipment.
b) Buildings
An administrative building will be needed to house the facility
manager, cost accounting department and clerical activities for
the project. The administrative building will also house the
environmental surveillance laboratory and data storage areas. Also
included will be a meeting room for holding public informational
meetings as well as two or three working offices.
An equipment storage and maintenance building will also be needed.
It is anticipated that this building will be separated from the
administrative building. A small building will also be needed
for the waste receiving station. This building will be used for
the gateman, scale and supporting equipment.
The advisability of housing the waste preparation processes and
storage facilities will be evaluated by the applicant and by the
facility operator. The decision whether or not to house the
various waste preparation and storage areas will be based on the
following evaluative criteria:
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i) The need to carry out the waste preparation activities under
controlled climatic conditions. Some of the waste preparation
techniques may be carried out in the open even under winter
operating conditions while other techniques must be housed
to maintain relatively constant working conditions.
11) The characteristics of the waste material being prepared
and stored at the various facilities. It is anticipated
that many wastes will remain in a workable condition under
the climatic conditions experienced in Minnesota while other
wastes must be housed to preserve their workability.
iii) The- project budget and the costs associated with housing
the various waste preparation and storage areas.
iv) Odors or emissions from waste preparation processes that
require air emission control equipment will be given housing
priority.
The need for storage buildings to temporarily store hazardous waste
to be disposed of elsewhere as well as the need for a building
to detonate shock sensitive wastes will also be evaluated.
c) Laboratory and Equipment
The need for a laboratory and supporting equipment will be evaluated
by the applicant and by the site operator. At the present time,
the applicant believes that a mass spectrometer, gas chromatograph
and atomic absorption-graphite furnace will be needed in the
laboratory. The purpose of the first two instruments is to scan
leachate and incoming waste samples to identify the appropriate
waste characteristics. The need to carry out other routine laboratory
analyses such as metals, organic compounds, nutrients, oxygen
demand, solids and the need for supporting equipment such as glass-
ware and chemicals will be evaluated by the applicant and by the
facility operator. The applicant anticipates that a large number
of analyses will be necessary to evaluate the various demonstration
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activities included in the project as well as collect environmental
surveillance data. The applicant and facility operator will evaluate
the need for a rather sophisticated laboratory at the site against
sending the majority of the samples to subcontractors for analyses.
Of particular importance will be the expected number of samples,
the capital investment and the turn-around-time that can be expected
with both alternatives.
6.8.4 Project Personnel Needs During Operation
This section of the application grant outlines administrative, technical
and support personnel needed to manage the demonstration facility once
the facility has been constructed and is fully operational. The
following personnel needs will be evaluated for incorporation into
the demonstration project by the applicant and the facility operator.
As discussed in 6.7.2, the applicant will approve all job descriptions
for staffing the facility. The final selection of personnel will
depend upon the final design of the demonstration project and on the
qualifications of the personnel available at the time of selection.
a) On-Site Administrative Personnel (Facility Operator's Staff)
Facility Manager - A facility manager will be needed to assume
responsibility for managing and operating the chemical waste land
disposal facility. The facility manager will be responsible for
the smooth operation of the land disposal facility in compliance
with the requirements of the applicant. The facility manager will
be the chief contact between the site operator and the applicant
and will be responsible for carrying out the disposal site pre-
paration techniques, waste preparation techniques, environmental
protection activities, cost accounting strategies, and project
schedule as set forth by the applicant, all within the budget
approved annually by the applicant and by the Environmental
Protection Agency.
Assistant Manager/Accountant - The need for an assistant manager
with principal responsibilities in cost accounting will be evaluated.
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This evaluation will be based on the expected volume of waste,
the complexity of the selected accounting strategy and the extent
of the facility management requirements.
Bookkeeper/Secretary - Secretarial and bookkeeping help will be
needed to carry out the various clerical aspects associated with
the project. Possible clerical duties include preparing and
sending statements based on user charges, preparing payroll,
answering Correspondence, and other clerical activities. At least
one bookkeeper/secretary will be needed and the need for additional
secretarial help will be evaluated. Evaluation will be based upon
the expected volume of clerical work and on the accounting strategy
used at the facility.
b) On-Site Professional Personnel (Facility Operator's Staff)
Chemist/Process Coordinator - A professional level person will be
needed to -carry out the chemical analyses and coordinate the
various waste management processes included within the facility.
This includes overseeing the sampling and analyses of the water
as it is received as well as sampling and analyzing the waste
-prior to disposal. This person will also coordinate the utilization
of the various waste preparation processes and provide input to
the other'various chemical waste disposal demonstrations. The
chemist/process coordinator will be directed by the facility
manager.
Lab Assistant/Process Operator - The need for a lab assistant/
process operator to assist in the laboratory and operate the waste
preparation processes will be evaluated. The evaluation will
be based on the types and complexity of the waste preparation
operations selected for use in the project and on the amount of
chemical sampling and chemical analysis that will be carried out
by the facility operator to attain the objectives of the project.
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c) On-Site Technicians (Facility Operator's Staff)
Gateman - A gateman will be required to record the waste as it
arrives at the project's receiving station and to check the
waste labels and shipping papers as discussed in 6.8.1. This
will be a relatively routine job, but will require someone on
duty during all operating hours to check and accept the waste
as it is received.
Equipment Operator/Maintenance - At least one equipment operator
and one equipment operator/maintenance person will likely be
necessary to carry out the various disposal area preparation,
waste transfer, and land disposal activities associated with the
demonstration facility. The need for additional equipment operators
and maintenance people will be evaluated based on the number and
complexity of the various disposal site preparation techniques and
on the waste disposal methods selected for use in the facility.
d) On-Site Public Education Personnel (Applicant's Staff)
Technical Information Coordinator - A Technical Information
Coordinator will be assigned to the demonstration project by the
applicant. During the early stages of the grant period, the
Technical Information Coordinator will be responsible for imple-
menting the various public acceptance programs. Once the facility
is in operation, the principal function of the Technical Information
Coordinator will be to coordinate the distribution of data from
the demonstration facility and to coordinate the public education
aspects of the project. The coordinator will be responsible for
arranging and conducting tours and seminars at the demonstration
facility and for attracting local, state and national conferences
to the demonstration facility. Additional details on the role
of the Technical Information Coordinator are discussed In Section
6.10.2.
Tour Guides (Students) - Personnel will be necessary to conduct
guided tours of the facility. It is anticipated that college
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students who are otherwise involved with educational projects at
the demonstration facility will primarily be used to carry out this
activity. The number of guides necessary to conduct tours will be
based on the volume of scheduled public education activities and will
vary throughout the year. Tour guides will be employed by the appli-
cant under the direction of the Technical Information Coordinator.
e) Off-Site Personnel (Applicant's Staff)
The following, personnel needs will be evaluated for use in managing
the actual demonstration grant. Grant management personnel will
be employed by the applicant and will likely be located off-site,
probably at the applicant's offices in suburban St. Paul.
Grant Director - The Grant Director will be responsible for
administering all phases of the demonstration grant consistent
with Federal, state and local requirements and regulations. The
Grant Director will be responsible for coordinating the work of
all subcontractors employed by the applicant and will also be
responsible for the timely submission of quarterly, annual and
interim reports on the project. The Grant Director will be respon-
sible for approving all facets of the demonstration project
before implementation by the facility operator. The Grant Director
will be responsible to the Environmental Protection Agency for
all'funds and other requirements associated with the demonstration
project.
Grant Administrator - The Grant Administrator will be needed to
assist the Grant Director in the day-to-day administrative activities
associated with the demonstration project. The Grant Administrator
will be directly responsible to the Grant Director for coordinating
the work of the various subcontractors, for reviewing the work
of the facility operator, and for administering the various portions
of the grant.
Senior Engineer - A Senior Engineer will be utilized by the applicant
to assist in the technical aspects of the project. The Senior
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Engineer will be responsible to the Grant Director for preparing
technical reports, reviewing and overseeing technical work carried
out by the facility operator, and coordinating the work of the
various technical subcontractors used on the project. It is anti-
cipated that the Senior Engineer will devote approximately 50% of
his time to the demonstration project. This percentage may be
adjusted, depending on the specific time requirements.
Secretarial/Nontechnical - Various secretarial and nontechnical
personnel will be utilized by the applicant to carry out clerical,
bookkeeping, drafting and related activities. It is anticipated
that a senior secretary will be necessary to carry out the clerical
and bookkeeping activities and a part-time draftsman will be necessary
to prepare the necessary graphics for the Public Information
Coordinator and for the various reports that will be prepared by
the applicant.
Other - Other technical and support people such as engineers,
pollution control specialists and draftsman will be evaluated for
use on the project by the applicant as appropriate.
f) Subcontractors
The need for subcontractors to assist the applicant after the grant
is awarded will be evaluated by the grant director. The need for
subcontractors will be evaluated after the grant is received and
will be based on the staff capabilities of the applicant and on the
final design of the facility. The facility operator will be permitted
to retain subcontractors as necessary, although the applicant will
retain approval authority over all operator subcontractors.
The following applicant subcontractor assignments have been identified
for evaluation:
Environmental Surveillance - The applicant will consider
retaining the University of Minnesota on a subcontract basis
to carry out at least portions of the various environmental
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surveillance activities under the direction of the applicant.
Maintaining the environmental surveillance activities
under the direction of the applicant offers the advantage of
independence to the subcontractor and will add credibility to
the results of the environmental surveillance. Other sub-
contractors will be retained to carry out environmental
surveillance under the direction of the applicant as necessary.
Occupational Safety and Health - The University of Minnesota
will also be' considered to monitor the operation of the facility
to insure that the various occupational safety and health
requirements are followed. The intent will be to develop an
Occupational Safety and Health Plan for the operation of the
facility at the outset. As with the environmental surveillance
activities, it is believed that the employment of the occupa-
tional safety and health subcontractor by the applicant will
help insure the credibility of the results.
Evaluation of Site Design, Waste Preparation and Disposal Tech-
niques - Various subcontractors will be retained by the applicant
to review facility designs, interpret the data obtained from the
various demonstration areas and evaluate the effectiveness of the
various site design and waste disposal methods. These evaluations
will be prime topics for technical articles in the various technical
journals and will provide valuable input to reports to the Environmental
Protection Agency as well as to future demonstrations carried out
at the site.
Economic and Social Impact Evaluation - Subcontractors including
the University of Minnesota will also be retained to study
the economic and social impact of the demonstration project
on the surrounding area. Of particular interest will be the
success of the various public acceptance and education programs,
the impact of the facility on surrounding land development,
the economic impact of the demonstration facility on' chemical
waste generators and on other hazardous waste disposal facilities
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serving the region, and the impact of the facility on the
institutional framework of the various agencies presently
regulating chemical wastes in this area.
6.8.5 Personnel Training Programs
The purpose of this section of the grant application is to briefly
outline the various personnel training programs which will be evaluated
for incorporation into the management and operation of the demonstration
facility. At the present time, it is anticipated that personnel
training programs in at least the following three areas will be
carried out:
Equipment Operation and Maintenance
Facility Operation and Maintenance
« Occupational Safety and Health
The following subsections briefly describe the objectives of the
various training programs that will be evaluated for incorporation
into the routine operation of the demonstration project.
a) Equipment Operation and Maintenance
Proper equipment operation and maintenance is obviously important
to the smooth operation of the demonstration facility. The
applicant will require the facility operator to incorporate
regular equipment operation and maintenance training programs
into the routine operation of the facility. This will be carried
out by on-the-job training as well as by classroom style pre-
sentations. An incentive program to motivate operation and
maintenance personnel to attend schools relative to the equipment
they operate will also be established.
b) Facility Operation and Maintenance
A basic understanding of the purposes, goals and objectives of
the demonstration facility be each person employed at the facility
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is necessary for the successful operation of the facility.
Periodic seminars for facility personnel will be held to discuss
various aspects of the demonstration facility. These are considered
an important part of the overall personnel training program.
c) Occupational Safety and Health
Due to the nature of the wastes handled at the facility, an
occupational safety and health program will be a high priority
item. An occupational safety and health plan and manual will be
developed as the facility is designed and constructed. The
operator of the facility will hold occupational safety and health
seminars to educate facility personnel to the hazards inherent
in the handling, storage and disposal of the various chemical
wastes. Of particular concern will not only be preventive measures,
but also control measures for accidents that do happen in the
handling and disposal of chemical waste. Fire-fighting and
first-aid are two examples. A comprehensive system of occupational
safety and health protection will be implemented at the facility.
This system will include an understanding of the chemical waste
labeling systems, the prominent posting of emergency telephone
numbers and the thorough training of project personnel in applying
the correct control procedures if accidents do occur.
6.9 COST ACCOUNTING STRATEGY
This section of the demonstration grant summari2es the cost accounting
strategies that will be evaluated for incorporation into the project. Since
one of the primary purposes of the demonstration grant is to demonstrate
the economic feasibility of chemical waste land disposal, the applicant
recognizes the importance of cost accounting in the success of the demonstration
project. All cost accounting strategies selected for evaluation will be
designed to meet the following objectives:
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e A system of user fees will be utilized to recover all capital expend-
itures as well as operating and maintenance expenses over the life
of the facility. User fees will not be reduced by the demonstration
grant during the demonstration period.
Costs associated with facility closure and perpetual monitoring will
be included in the user fee.
e Sufficient cost data must be developed to accurately define the unit
costs associated with preparing and disposing of various chemical
wastes using various waste preparation and disposal methods.
Unit costs will be separated according to labor costs, equipment costs
(capital and operating), expendable supplies, and general project
overhead for cost reporting purposes.
e Non-waste handling costs such as environmental surveillance, admin-
istration, and general facility improvements will be determined and
separated from unit costs associated with waste handling for cost
reporting purposes.
Costs associated with demonstration portions of the project including
grant administration, public education beyond that normally included
in a chemical waste land disposal facility and demonstration orientated
construction and monitoring will also be determined and summarized.
Demonstration orientated costs will not be included in the user fees.
6.9.1 Summary of Cost Components
The various cost components making up the total cost of the demonstration
facility are summarized on page 6-113. The total demonstration project
cost is separated according to direct cost, facility overhead, admin-
istrative cost, closure cost, and demonstration cost. These five
cost components make up the total demonstration project cost. The
costs associated with these five cost components are briefly discussed
in the following paragraphs.
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CHEMICAL WASTE LAND DISPOSAL FACILITY
COST COMPONENTS
Direct Material
Process chemicals,
encapsulation
materials, & fixa-
tion materials.
Direct Labor
All labor directly
involved in the receiv-
ing, handling & storage,
processing & disposal of
waste.
DIRECT COST
Indirect Material + Indirect Labor + Other Indirect Expenses
FACILITY OVERHEAD
Clothing, cleaning
supplies, mainten-
ance supplies, lab-
oratory supplies.
Supervision,
process moni-
toring, waste
analysis, en-
vironmental
surveillance.
*Cost charged to user
for normal operations.
Depreciation of process
& waste placement equip-
ment, amortization of
liners & site prepara-
tion, amortization of
land acquisition, amort-
ization of design & eng-
ineering, maintenance,
utilities, off-site dis-
posal, insurance, taxes,
amortization of environ-
mental surveillance equip-
ment.
Administrative Expenses
Administrative & office
salaries, telephone &
postage, office supplies,
bad debts, legal & audit-
ing expenses, project re-
lated public education.
Closure & Perpetual Care
Development of closure
plan, modifications to
closure plan, implemen-
tation of closure plan,
perpetual monitoring,
contingency fund.
Demonstration Costs
Public education beyond
normal project require-
ments, special testing
& monitoring, salaries
of tour guides, grant
administration costs.
ADMINISTRATIVE COST
CLOSURE COST
TOTAL FACILITY COST*
DEMONSTRATION COST
TOTAL DEMONSTRATION
PROJECT COSTS
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a) Direct Cost
The direct cost is made up of direct materials and direct labor.
Direct materials include all process chemicals, encapsulation
materials and fixation materials which will be needed as annual
material inputs to the various waste preparation and disposal
processes. Direct labor includes all labor directly connected
with receiving, handling, storing, processing and disposing of
the various chemical wastes.
b) Facility Overhead
Facility overhead includes the cost of indirect materials, indirect
labor and other indirect expenses. Indirect materials include all
special clothing, cleaning supplies and other maintenance supplies
which will be furnished to employees directly connected with the
processing and disposal of chemical waste. Indirect labor includes
all labor costs associated with supervision, process monitoring,
waste analysis, leachate monitoring and environmental surveillance.
Indirect expenses include all expenses incurred by the facility
not included as direct materials or administrative costs. These
include depreciation of process and waste disposal equipment,
amortization of site preparation costs, amortization of land
acquisition, maintenance of equipment and buildings, utilities,
off-site disposal costs at municipal wastewater treatment plants
or at other chemical waste disposal facilities, insurance, taxes
and amortization of design and engineering costs.
c) Adminstrative Cost
Administrative costs are comprised of administrative and office
salaries, telephone and postage, office supplies, bad debts,
legal costs, facility auditing expenses, and public education costs
normally associated with a chemical waste land disposal facility
of this type.
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d) Closure 'Cost
As discussed in Section 6.6.2, a facility closure plan will be
developed in the design stage of the demonstration project. In
order to implement the facility closure plan, the costs associated
with the closure plan will be recognized and added to the user
fees-. Costs associated with the closure of the facility include
the development of the closure plan, the implementation of 'the
closure plan, the perpetual monitoring of the site and future costs
either in terms of facility maintenance after closure or modifications
to the perpetual monitoring plan.
e) Total Facility Cost
The direct cost plus the facility overhead plus the administrative
cost plus the closure cost represents the total facility cost.
This cost will be recovered over the life of the facility through
the collection of user fees. The various costs included in the
total facility cost will be estimated before the facility begins
routine operation. Estimates will be based on actual costs
incurred during construction, actual equipment costs, engineering
studies carried out during the design phase and time-motion studies
conducted during the operational start-up 'period. The various
costs will be periodically updated during the progress of the demon-
'stration project so-the full-and true cost of operating the facility
-is charged to the facility users.
f) Demonstration Cost
Since the project is a demonstration project providing valuable
'data for use in other areas of the country, additional equipment,
labor and expenses will be needed beyond those "normally" incurred
in a chemical waste land disposal facility. It is the applicant's
intention to use a portion of the demonstration grant to fulfill
these demonstration-related costs. These costs will, therefore,
not be passed on to facility users. Demonstration costs include
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public education efforts which are beyond normal project requirements,
special testing and monitoring conducted to demonstrate the suita-
bility of various site design and waste preparation processes,
salaries of guides used to conduct tours of the site and grant
administrative costs including the preparation of various interim
and other reports.
g) Total Demonstration Project Cost
The total facility cost plus the demonstration cost equals the
total demonstration project cost. This represents the entire
cost of the demonstration chemical waste land disposal project.
6.9.2 Cost Control Centers
A network of cost control centers will be evaluated for incorporation
into the cost accounting system. Since all waste will be assigned
a route through the facility at the demonstration project's receiving
station, as discussed in Section 6.8.1, the various storage, waste
preparation, site preparation and waste disposal processes will be
evaluated for incorporation into the accounting strategy as cost
control centers. Unit costs for storing, preparing or disposing
of various wastes at the selected cost control centers will be
determined using actual project costs and engineering studies as well
as time-motion studies conducted during facility start-up. The unit
costs will be continually evaluated through the accumulation of
cost data at the various cost control centers during the operation of
the facility. Non-waste handling activities such as environmental
surveillance, closure costs, and public education costs will also
be evaluated as cost control centers. The costs incurred in storing,
treating and disposing the waste can, thereby, be determined by using
the unit costs from the cost control centers used in the waste flow.
It is anticipated that a relatively large number of processes and,
therefore, cost control centers will be necessary to meet the objectives
of the demonstration project. Where appropriate, cost center data will
be developed in terms of costs per unit of waste either in terras of
weight, volume or chemical strength.
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6.9.3 Cost Allocation Strategies
The following strategies for establishing facility user fees will
be evaluated for incorporation into the project. The criteria outlined
in Section,6.9.4 will be used for the evaluation. For explanation
purposes,, the strategies are discussed in terms of direct cost, facility
overhead cost, administrative cost, closure cost and demonstration cost.
a) Direct Cost
As discussed previously, direct cost is made up of direct materials
and direct labor. Standard unit direct costs will be predetermined
through engineering studies conducted in the design phase of the
project and through job costing and time-motion studies conducted
during the facility start-up period. A record of actual direct
costs will be maintained for each cost control center and the cost
control centers will become monitors for measuring variances.
Various strategies will be evaluated for maintaining cost records
for direct costs. These strategies will.include1project time
clocks, daily estimates, of project time, and a constant, allocation
based on total time and total waste flow through each cost center.
Analysis of variances will yield information relative to the
continuing efficiency of the processes and necessary adjustments
in user fees due to cost increases or other various internal, or
external forces. The resultant will, be a unit1 cost for each cost
control center. Units evaluated for use will include weight, volume,
chemical strength, a combination of two or all three, depending
on the nature of the waste1and the nature of the cost'control
center.
b) Facility Overhead
A number of methods will be evaluated for allocating facility
overhead costs into user fees. Three of these methods are discussed
in the following paragraphs.
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Constant Allocation MethodThe total facility overhead for a
one-year operating period will be predetermined through engineering
and time-motion studies. In this allocation strategy, this total
overhead cost is a numerator in the ultimate equation set forth
below. The denominator of the equation is a formula based on the
estimated annual waste volume, weight or strength. The cost
allocation equation, therefore, becomes:
Facility Overhead Cost _ User Fee to
Annual Volume,, Weight Cover Facility
or Strength of Waste Overhead Cost
This cost allocation method yields a single user fee based on waste
volume, weight or strength independent of the processes used for
waste disposal and independent of the various cost control centers.
This system is the easiest to maintain, however, it does not
allow for complete accuracy in allocating facility overhead costs.
The facility user with easily handled waste would carry the same
burden of the facility overhead as will the user with a very
complex waste requiring the use of extensive preparation and disposal
techniques. Depending on the facility overhead cost, the constant
allocation method may not meet the cost accounting objectives of
the demonstration project.
Multiple Allocation MethodUnder this system, annual facility
overhead costs are again predetermined through engineering and
time-motion studies. Instead of allocating this cost evenly to
all wastes, however, the allocation of costs to the facility user
is determined by computing various cost allocation factors repre-
senting the proportion of the cost assignable to each cost control
center. These factors are established for each cost control
center by using the method illustrated on page 6-119.
As shown in the table on page 6-119, eight cost control centers and
six allocation items have been arbitrarily selected. Cost control
centers actually used in the cost accounting strategy will be
selected as discussed in the previous section. The basis for
allocation may include only overhead cost items or may include
direct cost items which represent reasonable criteria for allocation
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ALLOCATION OF FACILITY OVERHEAD COST
MULTIPLE ALLOCATION METHOD
Project Control Centers (Based on Various Processes)
A B C D E F G H
ALLOCATION ITEMS
Percent of Direct Labor 15% 25% 5% 20% 8% 7% 15% 5%
Percent of Space Re- 8% 14% 18% 6% 30% 5% 10% 9%
quired in Project Area
Percent of Time Re- 10% 10% 15% 8% 7% 25% 12% 13%
quired for Monitoring
& Supervision
Percent of Time Re- 0 0 0 0 40% 20% 30% 10%
quired for Treating
Leachate
Percent of Site Design 10% 17% 5% 20% 5% 13% 20% 10%
Cost,
Percent of Equipment 20% 15% 20% 10% 8% 7% 10% 10%
Cost
Total 63 81 63 64 98 77 97 57
Total Elements POO 600 600 600 600 600 600 600
COST CENTER ALLOCATION
FACTOR .105 .135 .105 .107 .163 .128 .162 .095
FACILITY OVERHEAD/YR. = $200,000/yr.
Facility Overhead $21,000 $27,000 $21,000 $21,400 $32,600 $25,600 $32,400 $19,000
Allocated Per Cost
Center
Estimated Volume 2,000 3,000 4,000 5,000 3,000 2.000 4,000 1,000
Through Each Cost ~~
Center (Tons)
Facility Overhead $10.50 $9.00 $5.25 $4.28 $10.87 $12.80 $8.10 $19.00
User Fee (cost/ton) '
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factors. The example allocations include the percent of direct labor
hours required at each cost control center, the percentage of
space required within the project area for each cost control center,
percent of time required for monitoring and supervision at each
cost control center, percent of time required for treating leachate
from each cost control center, percent of facility design cost in
each cost control center and the percent of equipment cost in each
cost control center. The percent of the various allocations that
go into each cost control center are determined using engineering
and time-motion studies. The percentages are totalled and averaged
to obtain a cost control center allocation factor. The cost control
center allocation factor is then applied to the total annual
facility overhead to obtain the portion of the facility overhead
allocated to each cost control center. The estimated volume,
weight or strength of waste through each cost center is determined
using market surveys. Whether waste volume, weight, strength or
a combination of these units are used will depend upon the waste
and on the characteristics of the process utilized. The estimated
waste volume, weight or strength is then divided into the facility
overhead cost allocated to each cost control center to obtain a
facility overhead user fee in dollars per weight, volume or waste
strength for each cost control center.
The allocation item percentages are periodically updated using
information generated by each cost control center during the
routine operation of the facility. The user volumes are similarily
updated and revised cost estimates are obtained. The multiple
allocation method has the advantage that processes having a low
overhead cost are reflected by lower fees for utilization of
those processes.
Fixed/Variable Allocation MethodThe fixed/variable cost allocation
method classifies facility overhead in elements of fixed and
variable costs at each cost control center. A row of cost control
centers and a column of allocation items are selected as in the
previous alternative. Instead of a fixed percentage, however,
provisions for fixed costs and variable costs are included at
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each cost control center. Examples of possible fixed costs Include
depreciation of process and waste placement equipment, amortization
of land aquisltion and site design, Insurance, and taxes. Examples
of possible variable costs include materials, labor and expenses
such as off-site disposal, leachate collection and treatment,
and special site preparation procedures carried out at the cost
control center which vary with waste strength, volume or weight.
This variable cost will be based on the strength, volume or weight
of waste. The resulting cost allocation will more closely define
the costs associated with each process thereby yielding greater
cost controls and additional accuracy in determining user fees.
c) Administrative Costs
The three cost allocation methods discussed in the previous para-
graphs will 'be evaluated for use in allocating the administrative
costs connected with the facility. The facility administrative
costs could either be allocated with the overhead costs or allocated
separately using different allocation percentages.
d) Closure Costs
At sometime the facility will reach saturation, necessitating its
closure. For project planning purposes, 'this has been estimated
at fifteen years., but increased .generation -of waste sludges due to
wastewater pretreatment standards may shorten 'the -estimated facility
life. On the other hand, the -economics of land-disposal versus resource
recovery or source reduction may lengthen the 'facility's estimated
life. The hazardous nature of many of the wastes being despoited
in the facility will necessitate -the preparation and eventual
implementation of a detailed facility closure procedure as well
as -the perpetual monitoring of the site. This closure and perpetual
monitoring cost will be recognized from the start of operations
and a closure and perpetual monitoring fund will be -established
over the life of the project. The-cost of facility closure less
expected salvage value of the equipment'may be carried similar "to
a plant overhead item and funded from annual operations or accumulated
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through a separate user surcharge. The closure cost could be
allocated to the various cost control centers using any of the
three cost allocation methods outlined in the facility overhead
discussion. A portion of the fund will be used for facility
closure activities discussed in Section 6.6.2. After the facility
is closed, interest from the remaining fund should be sufficient
to perpetually monitor the facility. The remaining capital in the
fund will be available for emergency use to maintain an environ-
mentally-safe facility.
e) Demonstration Project Costs
All costs which are accumulated because of their demonstrative
nature should be isolated through the use of one or more cost
control centers. These cost items will be counted as an expense
against the total venture, however, they will be ignored in
determining user fees. The applicant's philosophy is that industries
in the facility service area should not be penalized because the
project is a demonstration project and, therefore, these costs will
not be included in the facility user fees.
6.9.4 Evaluation of Alternatives
The alternative strategies for establishing cost control centers and
allocating costs discussed in the preceding sections will be evaluated
by the facility operator, and by their subcontractors after grant award.
The cost accounting strategy will be designed by the facility operator
and approved by the applicant. The selection of the cost accounting
strategy to be incorporated into the project will be accomplished
using the following evaluative criteria:
a) The cost accounting strategy must attain the demonstration project
objectives outlined at the beginning of Section 6.9.
b) The cost accounting strategy must fit within the facility design
framework in terms of cost control centers and cost allocation
items.
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c) The eventual cost accounting strategy must produce a user fee
which is justifiable to the users of the site. The applicant
and operator must be 'able .to substantiate the costs charged to
the user of the facility. These costs must accurately reflect
the actual cost 'necessary to dispose of the user's waste.
d) The eventual cost accounting strategy must be manageable within
the project budget with the personnel available at the facility.
6.10 SOCIAL IMPLICATIONS
The purpose of this section of the grant application is to discuss the various
strategies that the applicant proposes to incorporate into the demonstration
project to gain citizen acceptance for the project, encourage the use of the
facility for educational purposes, publicize the results of the facility
and monitor the social and institutional impacts of the facility. The various
strategies outlined in this section of the demonstration grant application
will .be carried out by the applicant with the cooperation of the facility
operator.
6.10.1 Strategy for Gaining Citizen Acceptance
As outlined in Section 6.1.2 of this application, Minnesota represents
an excellent opportunity to field evaluate various strategies for
gaining citizen acceptance for a chemical waste land disposal facility.
The citizens of the area have repeatedly demonstrated a high level of
interest in environmental matters and the various citizen organizations
are well organized with easily identified spokesmen. Carrying out
the strategies outlined in this section of the grant application will
represent an opportunity to field evaluate many of the strategies set
forth in the publication entitled, "Public Attitudes Towards Hazardous
Waste Disposal Facilities", conducted by the Human Resources Research
'Organization for the Environmental Protection Agency's National
(4)
Disposal Site Study.
Through consultant studies, legislative hearings, and the news media,
decision makers have been made aware of the generally unsatisfactory
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hazardous waste disposal methods currently being used in Minnesota
as well as nationwide. The general public has also been exposed to
the need for better hazardous waste management through the Minneapolis/
St. Paul based news media. The general public attitude regarding
the need for a chemical waste land disposal facility in the Minneapolis/
St. Paul area seems to be generally positive at the present time.
To maintain this public attitude, the various strategies outlined in
this section of the grant application will be aggressively carried
out by the applicant. A full-time. Technical Information Coordinator
will be assigned to the chemical waste land disposal demonstration
project as soon as the grant is awarded. The Technical Information
Coordinator will be employed by the applicant and will have a technical
and public information background as discussed in 6.8.4. The function
of the Technical Information Coordinator will be to coordinate and
carry out the bulk of the work in implementing the various citizen
acceptance strategies. Once the various environmental and construction
permits have been obtained, the Technical Information Coordinator will
coordinate the various public education programs which are to be
implemented around the facilities. These public education categories
are summarized in Section 6.10.2.
The overall strategy for maintaining a positive public attitude
toward a chemical waste land disposal project has been divided into
two separate phases. The first phase will concentrate upon selling
the need for the facility in Minnesota and the second phase will
concentrate upon selling the facility at the chosen location. The Phase I
strategy for gaining citizen acceptance for a chemical waste land
disposal facility will follow the following outline:
a) Sell the nationwide need for such facilities. The general theme
of this portion of the strategy will be:
"We must improve our present methods of chemical waste disposal.
Lack of adequate methods are significantly damaging the public
health, safety and welfare locally and on a nationwide basis.
The problems associated with inadequate chemical waste disposal
will increase in the near future as discharges to sanitary sewer
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systems are curtailed. A chemical waste land disposal facility
under carefully controlled and monitored conditions is an import-
ant part of improving our present methods of managing our waste
products and presents a technological leap beyond present disposal
systems. A demonstration facility is needed to determine if the
land disposal of chemical waste can be carried out in an environ-
mentally-safe and cost effective manner."
b) Sell the need for such a facility in Minnesota. Proof in the
form of case histories will be presented documenting the damage
to public health, safety, and welfare that is presently occurring
through the uncontrolled disposal of chemical wastes. It will
be stressed that damage associated with the uncontrolled disposal
of chemical waste will be compounded in the near future when the
discharge of chemical waste to the sanitary sewer system is
curtailed.
c) Sell the fact that the project is a Federal Demonstration Project
under the sponsorship of the U.S. Environmental Protection Agency
and that 3.5 million dollars of Federal support will be granted
to help build and operate the facility.
d) It will be stressed that the demonstration project represents
the opportunity for governmental regulatory agencies to select
a site for the facility in the best possible location to minimize
environmental impacts. The only alternative is to react to dis-
posal locations and operational plans brought to the regulatory
agencies either by industry or by another governmental agency.
These site locations might not be as ideally located from an
environmental, economic or land use point-of-view as the demon-
stration facility. The fact will be stressed that the area needs
a chemical waste land disposal facility. The choice is not between
locating or not locating a site in the area. The choice is
only between the various ways to locate the site in the area and
the demonstration facility route is clearly the best way to go.
e) Stress that a chemical waste land disposal facility will encourage
the recovery of valuable chemical byproducts and the reduction of
waste generation at the source since:
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i) The cost of disposal in the chemical waste land disposal
1 facility will represent the true cost of proper land
disposal of chemical wastes and will make the economics of
many resource recovery and source reduction techniques more
attractive.
ii) The use of a chemical waste land disposal facility will
place potentially valuable materials in a known location,
thereby making recovery and reclamation of today's waste
products more feasible at a future date.
iii) The construction of a chemical waste reclamation and
recovery facility will be an obvious addition to a chemical
waste land disposal facility. In fact, the predisposal
preparation of many wastes could eventually lead to the
recovery and reuse of many valuable resources.
f) It will be stressed that the Minnesota Pollution Control Agency,
the agency responsible for protecting the environment in the
State of Minnesota, supports the need for the project and will
be the administrator of the demonstration grant. The project
will be designed and constructed with a number of fail-safe levels
of waste containment to insure an environmentally-safe facility.
The facility will be thoroughly monitored to insure that all
waste containment procedures are functioning properly.
The program detailed above, represents a first phase strategy to
gain citizen acceptance for the facility. The applicant will stress
the basic need for the project and will not cloud the issue with
site specific details in the early stages of the citizen acceptance
program. The first phase program will be directed at statewide
in general with particular emphasis on the metropolitan area.
State, regional, county and selected local decision makers will be
contacted with a project overview and a definition of the need for
the project. In addition, spokesmen for the various environmental
groups active in the metropolitan area will be contacted also with
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a project need definition and with a project overview. This will
result in' a .good understanding of public attitudes and a sample of
the types of rallying points likely to arise when actual site location
is discussed in the second phase of the strategy.
The applicant has already initiated critical portions of this first
phase program to gain citizen acceptance for a chemical waste land
disposal facility in the Minneapolis/St. Paul area. Initiatives
taken to date inolude:
a) The formation of a Hazardous Waste Steering Committee which has
been working on metropolitan and statewide hazardous waste manage-
ment problems for approximately three years. The Steering
Committee is made up of decision makers (or their representatives)
who will be making many of the decisions regarding the eventual
implementation of a hazardous waste management system in Minnesota.
Industry representatives are also members of the Hazardous Waste
Steering Committee.
b) The report quantifying the generation of hazardous waste in the
metropolitan area was given excellent publicity by the media in
the Minneapolis/St. Paul area. The various news reports stressed
that unregulated hazardous waste disposal methods were currently
being used and pointed out the need for better disposal methods.
c) Minnesota's application for the chemical waste land disposal
demonstration grant was given excellent news coverage in the
Minneapolis/St. Paul area. The coverage stressed the need for
better disposal facilities and pointed out that the applicant
has been selected as one of the seven nationwide applicants for
a Federally supported demonstration project.
All of the information on the various hazardous waste efforts released
to date has been well received by the public. No negative feedback
has been received from industry, environmental groups or frpm the
public in general.
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The second phase of the citizen acceptance program will be to gain
citizen acceptance for a specific site. The major portion of this
effort will obviously be carried out in the geographical area
surrounding the potential site. After award of the demonstration
grant, the suitability of potential sites will be discussed in
detail with local decision makers. If, after these discussions, a
final site locatkrti cannot be selected, the strategies outline in
the following paragraphs will be carried out and the most successful
site from a citizen acceptance point-of-view will be selected. If
an early decision can be made, the following strategies will be
carried out only at the selected site.
The general strategy for gaining local support for a specific site
will be to point out that the facility will be a model facility
supported by the Federal Government. It will be demonstrated
through appropriate question and answer brochures with technical
support, that the chemical waste land disposal facility will not
contribute to any form of environmnetal degradation.
Potential rallying points for opposition to the site specific project
will be identified. Among these rallying points are likely to be:
safety during transportation, long-term impact on local water supplies
and short-term and long-term impact on land values. Specific answers
to these rallying points will be identified and enumeated in
illustrated brochures with question and answer formats For example,
answer to the question of transportation safety , it will be pointed
out that all vehicles transporting chemical waste will be licensed
by the Public Service Commission and routes to the disposal facility
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from the major centers of generation will be Interstate Freeways, and
major fout-lane roadways. The impact on water supply will be discussed
in terms ,of the environmental protection measures to be utilized at
the site and the location of the site relative to ground water use
for potable water supply purposes. The negative impact on land values
will be minimized by showing that the facility will be located in an
industrial area, by pointing out that screening will shield the
facility from view and by assuring that there will be no odors or
emissions from.the facility.
Targets for acceptance will be key decision makers at the state,
regional and local levels and the local population around the specific
site. Tools for carrying out the strategy will include:
a) Brochures detailing the need for the facility by illustrating
problems with the present chemical waste disposal methods as
well as future problems that can be expected without adequate
disposal facilities.
b) Question and answer brochures giving facts relative to the potential
rallying points for opposition to the site.
c) A press information kit for use by the various environmental
reporters working for local newspapers, radio and television.
d) A site plan model showing the site, the surrounding area, the
disposal techniques and the environmental protection facilities.
f) A slide presentation illustrating the site area in its natural
condition with overlays illustrating the proposed site plan.
Use of the strategies outlined in this section along with the
location of the facility and the environmental protection
measures set forth in other sections of this application hopefully
will result in the issuance of the appropriate construction.
and operating permits for the facility. Once the construction and
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subsequent operation of the facility is underway, the citizen acceptance
program will take the form of the public education program discussed
in the following section of this application.
6.10.2 Use of Facility for Educational Purposes
As the chief environmental advocate in Minnesota, the applicant
recognizes the need to use the demonstration facility as an educational
aid illustrating, an environmentally-safe method of chemical waste
disposal. The following general strategies will be followed by the
applicant with the cooperation of the facility operator to develop
the educational potential of the facility.
a) The Technical Information Coordinator, discussed in 6.8.4 and
6.10.1, will be assigned the responsibility of coordinating the
use of the facility as an educational aid. His responsibilities
will include:
i) promoting, organizing and overseeing seminars, workshops
and specialty conferences structured around the demonstration
facility. The conferences could either be held at the
facility or at a neighboring meeting place.
ii) promoting, organizing and conducting tours through the
entire facility or through selected portions of the facility.
Tours will be scheduled for the general public, for
interested local, regional and state decision makers, and
for interested individuals and groups from outside the
state. After the facility is in operation, the Technical
Information Coordinator will have a staff of guides (possibly
students working on various subcontracts) to conduct tours.
iii) disseminating environmental surveillance, cost accounting,
and process operational data generated by the facility to
interested individuals, institutions, agencies and industries
throughout the world. It is anticipated that the facility
will become a technical information center for the land
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disposal of chemical wastes. A library will be maintained
not only for data generated by the project, but also for
data and reports generated by other studies carried out
on the land disposal of hazardous waste.
iv) write informational articles and press releases relative
to the facility for newspapers, radio and television as
well as for such special interest magazines as Public Works,
American City, Water and Wastes Engineering, etc.
v) coordinate, for the applicant, any research or research
related activities carried out at the facility.
vi) communicate and meet with other people, with state and
regional solid waste management responsibilities to gain
their input into facility operations.
b) Various departments of the University of Minnesota (School of
Environmental Health, Department of Civil Engineering, Department
of Chemical Engineering, Geology Department) will work the
demonstration facility into various courses concerned with waste
management, environmental surveillance, waste treatment, occupa-
tional safety and health and social science. Classes will be
conducted at the facility and data generated by the facility will
be utilized in courses held at the University of Minnesota.
In this way, the facility will become a teaching aid and will
provide a direct educational experience for new people in the
field of hazardous waste management.
c) As discussed in Section 6.8.5, the applicant may subcontract
directly with the University of Minnesota for work in at least
the following three areas:
Environmental Surveillance
Occupational Safety and Health
Social Impact Monitoring
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Subcontracting directly with the University of Minnesota will
allow the University to incorporate work at the facility into
its graduate level programs. It is anticipated that three or
four masters level theses and one or two doctorate level theses
per year can be developed around the facility. In this way, the
project will be providing a very detailed educational experience
to new people in the field of hazardous waste management.
d) The University of Minnesota, as well as other universities and
colleges in"the area and nationwide, will be encouraged to use
the chemical waste demonstration facility as an incentive to
obtain research grants to study various facility aspects and
facility impacts in greater detail than can be accomplished under
the demonstration grant. The applicant clearly understands that
the primary purpose of the facility will be to demonstrate new
and improved chemical waste land disposal techniques, but research
at the facility without using demonstration funds will be encouraged
as long as the research does not conflict or impede the efficient
operation of the facility.
6.10.3 Publicizing Project Results
The applicant recognizes the critical importance of publicizing the
data and conclusions generated by the demonstration project. The
following strategies have been developed to publicize the project.
a) As discussed in the preceding section, the Technical Information
Coordinator will be responsible for publicizing the project to
the local news media.
b) The Technical Information Coordinator will also be responsible for
preparing "general interest" articles of a semi-technical nature
for publication in such magazines as Public Works, American City,
Civil Engineering and Water and Waste Engineering. It is anti-
cipated that the Technical Information Coordinator will be able
to publish two or three semi-technical articles per year during
the five-year demonstration period.
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c) Proceedings of the various seminars, workshops and conferences
which focus on the facility will be published and distributed.
It is anticipated that one national conference and four to five
local seminars per year can be focused on the facility during the
five-year demonstration project.
d) The University of Minnesota belongs to the Committee on Institutional
Cooperation which is an inter-institutional committee of Big Ten
universities plus the University of Chicago organized to share
opportunities and avoid unnecessary duplication in research
activities. Data from the demonstration project will, therefore,
be formally made available by the University of Minnesota to the
universities on the committee as well as upon request to any other
interested institutions.
e) As a part of the subcontract agreements, universities and other
subcontractors will be required to publish the data and con-
clusions of their work in a technical journal. It is anticipated
that three or four technical articles per year will be generated
during the five-year demonstration period.
f) The annual reports, the interim reports on special areas of study
and the final project report will be printed in sufficient quantities
so. they can be distributed to interested individuals, institutions,
agencies and industries upon request.
g) The applicant will prepare at least one technical article for
publication in a technical journal during each year of the demon-
stration project.
h) The applicant will attempt to organize a subcommittee of the'
state solid waste administrators to review project data and
operations and make comments regarding project operation and
design.
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6.10.4 Monitoring the Social Impact of the Facility
The social impact of the facility on the surrounding area will be
monitored as the project is implemented. Of particular interest
will be the success of the various public acceptance and educational
programs, the economic impact of the facility on chemical waste
generators and on other hazardous waste disposal facilities serving
this area and the impact of the facility on the institutional frame-
work of the various agencies presently regulating chemical wastes
in this area*. This monitoring program will be carried out either
by the applicant or by the applicant's subcontractors. The information
gained in the monitoring program will be published in an interim
report to the Environmental Protection Agency.
6.11 IMPLEMENTATION SCHEDULE
A generalized schedule for implementing the demonstration grant is illustrated
on page 6-135. The purpose of this section of the application is to discuss
the various scheduled items outlined on page 6-135 in terms of item inputs,
expected outputs and implementation strategies.
1. Organize
Immediately after award of the demonstration grant, the applicant will
organize and prepare to administer the grant. Organizational activities
will include: backgrounding the various personnel, setting up cost
accounting methods, issuing work orders to administer the grant, sending
the Solicitation of Interest to qualified operators if the county
ownership/private sector operator alternative is selected, and signing
necessary contracts and agreements with the intermediate governmental
agency selected to own the site. Inputs to this work item will be EPA
reports on hazardous waste management, state reports on hazardous waste
management and EPA/state discussions relative to the demonstration project.
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CHEMICAL WASTE LAND DISPOSAL DEMONSTRATION PROJECT
IMPLEMENTATION SCHEDULE
Demonstration Period
1. ORGANIZE
2. SELECT APPLICWTS SUBCONTRACTORS
1. SELECT OPERATOR
< SELECT PROJECT SITE
5. PHASE I PUBLIC ACCEPTASCE'PROSRAN £~
6 MR/MCE LOCAL FINDING
7 PURCHASE SITE
(
t. PHASE II PUBLIC ACCEPTANCE PROGRAM
9 COLLECT ADDITIONAL BACKGROUND DATA
10. SELECT PROCESSES I TECHNIQUES
11 DESIGN PROCESSES
12. FACILITY DESIGN
13 ENVIRONMENTAL SURVEILLANCE DESIGN
II. PERMITS I APPROVALS
IS EQUIPMENT PURCHASES 1 DELIVERY
i
16 ENVIRONMENTAL SURVEILLANCE CONSTRUCTION
17 COLLECT BACKGROUND ENVIRONMENTAL DATA
1*. FALlLlTT CONSTRUCTION
19. HASTE FLOW MANAGEMENT SET-UP
20. COST ACCOUNTING SET-UP
21 HIRE I TRAIN OPERATORS
22 FACILITY START-UP
23 ROUTINE OPERATION
24 ENVIRONMENTAL SURVEILLANCE
2S PUBLIC EDUCATION (TOURS.-SEMINARS)
26 STATE HAZARDOUS-WASTE REGULATIONS
(NO DEMONSTRATION FUNDS)
27 STATEWIDE HAZARDOUS HASTE INVENTORY
t PLAN (NO DEMONSTRATION FUNDS)
it HAZARDOUS HASTE TRANSPORTATION
LICENSING SYSTEM (NO DEMONSTRATION
FUNOi]
29. METROPOLITAN AREA MANAGEMENT SYSTEM
(NO DEMONSTRATION FUNDS)
30. STATEWIDE MANAGEMENT SYSTEM
(NO DEMONSTRATION FUNDS)
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2. Select Applicant's Subcontractors
Immediately after award of the demonstration grant, the applicant will
select subcontractors for the early portions of the applicant's work
program. Early in the project, it is expected that the applicant will
obtain subcontract assistance in site and operator selection and process
selection and design review. All subcontractors will be selected by
sending out proposal requests to various consultants. A number of quali-
fied consultants for the various subcontracting assignments will be
selected. Contracts Will then be prepared and the work scope detailed.
The applicant is interested in working with the University of Minnesota
in such areas as environmental surveillance, compliance with occupational
safety and health requirements and monitoring of social and institutional
impacts of the project. These subcontracts, along with other consultant
subcontracts need not necessarily be finalized at this early stage.
Although not shown on the Implementation Schedule, other subcontractors
will be selected as necessary during the demonstration period.
3. Select Operator
After the applicant has organized the various grant administrative
activities, the three or four most qualified site operator applicants
will be interviewed by the applicant and by the Hazardous Waste Steering
Committee if the county ownership/private sector operator is selected.
As discussed in Section 6.7.4 of this application, Solicitation of
Interests will be sent to approximately nine potential site operators.
Replies to the Solicitation of Interest will be evaluated by the
applicant and the three or four most qualified operators will be inter-
viewed. Based on the interviews and on the qualifications of the
applicants, a site operator will be chosen by the applicant using the
advice of the Hazardous Waste Steering Committee. Operator selection
criteria are summarized in Section 6.7.4.
4. Select Project Site
As set forth in the grant application, two potential project sites
have been selected and environmental impact appraisals have been
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prepared on both sites. After award of the grant, the institutional
impacts of locating the facility at the two locations will be evaluated
along with the probability o'f obtaining permits from the county and
local units of government. Based on these evaluations and on additional
data collected after submittal of the grant application, the final
site will be selected for the demonstration project. The applicant
is confident that the necessary approvals can be secured to utilize one
of the two potential sites.
5. Phase I Public Acceptance Program
As discussed in Section 6.10.1, an aggressive public acceptance program
will be implemented to "sell" the need for improved chemical waste
disposal to the public. Phase I of this program involves a detailed
explanation of the need for the project nationwide as well as within
Minnesota. Phase I of the program will, therefore, focus on the need
for the project and not on site-specific details. This phase of the
project has already been implemented as outlined in Section 6.10.1 and
will continue as the project site is finalized. Output from this -item
will be informed public officials who recognize the need for improved
chemical waste disposal facilities.
6. Arrange Local Funding
As discussed in Section 6.7.1, the local share of the demonstration
project funding will be provided by either the counties or the Metropolitan
Waste Control Commission through revenue bonds. Included in this work
item are the preparation, advertisement and selling of the bonds.
7. Purchase Site
This work item includes the negotiations 'and purchase of the selected
project site. Condemnation, if necessary, will be carried out to
secure the site.
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8. Phase II Public Acceptance Program
As the site is being selected, Phase II of the public acceptance
program will be implemented. As outlined in 6.10.1, Phase II includes
"selling" the public on the merits of the selected site. The statewide
and metropolitan area need for the site will be stressed on a continuing
basis.
9. Collect Additional Background Data
After the site has been selected, additional background data may be
needed as input to the design of the facility and environmental surveillance
systems. Additional background data may include soils and subsurface
geology data. Additional data may also be needed on the depth and influence
areas of wells surrounding the project.
10. Select Processes
Early in the first year of the demonstration period, the various waste
preparation and site preparation strategies outlined in Section 6.4 and
6.5 of the grant application will be evaluated. The evaluation will be
carried out by the operator and by the applicant using the appropriate
evaluative criteria outlined in the grant application. Output from this
work item will include the waste preparation and site preparation processes
to be designed and included within the demonstration facility.
11. Design Processes
After the waste preparation and site preparation processes to be incor-
porated into the facility have been selected, the design of the various
processes will begin. The process design will include the preparation
of detailed plans and specifications to construct the various waste
preparation and site preparation processes. The plans and specifications
will be prepared by the facility operator and approved by the applicant.
Outputs from this work item will be used to order the equipment, design
the facility and construct the various selected processes.
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12. Facility Design
After the site has been purchased and necessary additional background
data has been collected, the final design of the facility will be completed.
The final facility design will include the preparation of plans and
specifications for roads, storage areas, parking areas, buildings,
disposal areas and other supporting facilities. The plans and specifi-
cations will be prepared by the facility operator and approved by the
applicant. Output from this work item will be used to order equipment
and construct the facility.
13. Environmental Surveillance Design
As the waste management processes and site are being designed, the design
of the environmental surveillance system will also be completed. Environ-
mental surveillance design will include specifications for all monitoring
wells, piezometers, soil core areas, air quality monitoring stations,
surface water monitoring facilities, sample collection methods and sample
analysis methods. It will also include the design specifications for
the environmental surveillance laboratory. Output from this work will
be utilized to order equipment and construct the environmental surveillance
system.
14. Permits and Approvals
After the project site has been selected and after the process design
and site design have been carried far enough to serve as input, the
various permit applications will be prepared and submitted. This wall
include a solid waste license from the appropriate county; building,
land alteration and utility permits from the appropriate municipality;
solid waste, air quality and water quality permits from the Minnesota
Pollution Control Agency and approval of the solid waste permit by the
Metropolitan Council. A state environmental impact statement may also
be required if the project is found to be of more than local environmental
significance. As the process and facility designs are finalized, the-
final designs will be submitted in support of the permit applications.
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It is expected that approximately nine months will, be required to obtain
the necessary permits and approvals,.
15. Equipment Purchase and Delivery
As the various process and facility designs are completed, the equipment
will be ordered, purchased and delivered. The applicant recognizes the
need to allow a considerable lead-time for equipment delivery.
16. Environmental Surveillance System Construction
After t;he environmental surveillance system has been designed, con-
struction will immediately begin. The applicant recognizes the importance
of the.early construction of the environmental surveillance system so
background data can be collected prior to the disposal of waste at the
site.
17. Collect Background Environmental Data
After construction of the environmental surveillance system, background
environmental data will be collected. Data will be collected over a
six-month period with sufficient frequency to measure the background
levels.of^all critical parameters, If is obviously important to collect
this background environmental data before .waste is actually deposited in
the facility.
18. Facility Construction
After,the facility design has been completed, construction of the
facility will begin. It is estimated that approximately six months
will be needed to construct the roads, buildings, storage and waste
preparation areas and disposal areas at the facility.
19. Waste Flow Management Set-Up
During the,intermediate stages of site construction, the various waste
flow management techniques discussed in Section 6.8.1 will be evaluated
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and a waste flow management strategy will be selected. The evaluation
and selection will be conducted by the facility operator and approved
by the applicant using the evaluative criteria outlined in Section 6.8.1.
The operating manuals for the demonstration facility's receiving station,
the various waste preparation processes, and the various site preparation
techniques will be developed during this work item. The output from
this work Item will be the established -waste flow management system
designed to insure the efficient and environmentally-safe operation of
the facility.
20. Cost Accounting Set-Up
During the later stages of site construction, the cost accounting
strategies outlined In Section 6.9 will be evaluated and a cost accounting
strategy which best fits the evaluative criteria will be selected. The
necessary procedures to carry out the cost accounting strategy will be
developed during the work item. The result will be the development of
a cost accounting strategy to insure that the project fulfills the
demonstration objectives set forth by the applicant and by the Environmental
Protection Agency.
21. Hire and Train Operators
During the later stages of site construction and after most of the
necessary equipment is delivered, the personnel necessary to operate
the disposal facility will be hired. Job descriptions will be developed
by the site operator and approved by the applicant. The site operator
will then fill these job descriptions with the.most qualified personnel
available. After the necessary'personnel are hired, they will be
orientated In waste flow management, cost accounting as well as in the
use of the various waste preparation processes and waste disposal
facilities and supporting equipment.
22. Facility Start-Up
After the site is constructed and after the operators are hired and
orientated, a three-month project start-up period will be carried out.
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The purpose of the project start-up Is to identify and remove any "bugs"
that may -exist' In the overall operation, to obtain unit cost data on
the various cost control1centers through job costing and time-motion
studies and to provide additional orientation time for the various
personnel needed to operate the site. The output of the start-up
period will be an .efficiently, operating facility with established waste
disposal fees.
23. Routine Operation
After the three-month facility start-up period is completed and the
facility is running efficiently, the facility will be opened for
routine'operation. Critical activities in the routine project operation
will be implementing the various demonstration techniques selected for
use in the project, maintaining close control on costs at the various
cost control centers,-monitoring liner and waste preparation process
effectiveness and the routine environmental surveillance which will be
used to insure an environmentally-safe facility.
24. Environmental Surveillance
During project start-up, the environmental surveillance monitoring
system will be implemented. This system will be utilized to insure
that an environmentally-safe operation is being conducted.
25. Public Education
During construction of the facility, a public education program will
be implemented. The purpose of this program will be to educate the
public regarding the operation of the land disposal facility. Public
education programs will be carried out through the printing of infor-
mational brochures and through tours and seminars conducted at the
facility. This public education effort will continue until the end
of the demonstration project.
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26. State Hazardous Waste Regulations
As discussed in Section 6.2, the applicant is currently adopting state-
wide hazardous waste regulations. These regulations will be promulgated
during mid-1975. These regulations will guarantee a supply of chemical
waste to the land disposal facility. No demonstration project funds
will be utilized in implementing the hazardous waste regulations.
27. Statewide Hazardous Waste Inventory and Plan
As discussed in Section 6.2, the applicant has requested and received
proposals from a number of consultants to conduct a statewide inventory
of hazardous waste generation and develop a statewide strategy for
managing hazardous waste. A metropolitan area inventory and ^metropolitan
area plan have been completed by a consultant to the counties and to
the applicant. No demonstration funds will be utilized in carrying out
the statewide inventory or in the development of a statewide plan.
The results of the statewide plan, however, will be very important to
the success of the demonstration project.
28. Hazardous Waste Transportation Licensing Program
As also discussed in Section 6.2, a statewide hazardous waste transport-
ation licensing system is being implemented in Minnesota. The purpose
of this licensing system will be to insure that hazardous waste is
transported in accordance with appropriate safety procedures. The
licensing system is being implemented by the applicant and by the
Minnesota Public Service Commission. No demonstration funds will be
utilized for implementing the hazardous waste transportation licensing
system.
29. Metropolitan Area Hazardous Waste Management System
A hazardous waste management system is currently being implemented by
the counties in the Minneapolis/St. Paul metropolitan area. This
system includes a generator licensing program which requires that all
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generators -of hazardou's waste obtain a license from the appropriate
county. This -license sets forth 'the type and quantity of generated
waste and disposal method. The metropolitan area management system
will be implemented during 1975. No demonstration funds will be utilized
for the implementation of the metropolitan system although the demon-
stration facility
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An annual salary increase of 8 percent has been used to project
personnel salaries. It is emphasized that figures contained
in this budget category are to be utilized for grant administrative
purposes and do not include the salaries for the facility operator.
Facility operator salaries, fringe benefits and all subcontract
assistance are included under Contractural Personnel Services.
b) Fringe Benefits
Fringe benefits provided by the applicant are estimated to be 15
percent of base salary. These fringe benefits include health
insurance, sick leave, life insurance, annual leave and retirement.
c) Travel
The budgeted figures for travel are projected on the basis of the
applicant's policy for allowable travel expenses. Trips to
Washington, D. C., and Chicago, Illinois, have been included for
the purpose of discussing the project with Environmental Protection
Agency personnel. Travel costs associated with these trips
represent airline fares. Meals, lodging and parking have been
estimated at $35 per day for the first year and $40 per day for
the next four years of the demonstration period. It has been
assumed that each trip will result in a one "day" of meals,
lodging and parking expense. Travel by car has been estimated at
$.14 per mile during the first year of the demonstration period,
at $.16 per mile during the second and third year of the demonstration
period, and at $.18 per mile during the fourth and fifth year of
the demonstration period.
d) Equipment
Equipment costs have been estimated for the overall project. During
the first year of the demonstration period, equipment costs will
be consumed by establishing office space and necessary equipment
to support the applicant's staff on the project.
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First year equipment includes a typewriter, filing cabinets, desks,
chairs, bookcases and a dictaphone. During the second year of
the demonstration period, approximately two-thirds of the equip-
ment needed to operate the demonstration facility will be purchased.
This includes site preparation and waste placement equipment,
waste preparation process equipment, office equipment for use
at the site, and laboratory equipment. During the third year of the
demonstrationperiod, the remaining equipment needed to operate
the facility will be purchased. This includes the balance of
the waste preparation process equipment, laboratory equipment,
fire protection and safety equipment and the environmental
surveillance equipment. During the fourth and fifth years of
the demonstration period, money has been budgeted for purchasing
a small amount of additional equipment needed to operate the
facility and to maintain previously purchased equipment. The
actual cost of equipment is obviously impossible to estimate
until the various processes have been selected.
e) Supplies
The budgeted money for supplies are shown at a projected actual
cost to the applicant. Printing and reproduction costs have been
estimated at $.07 per page during the first year of the demon-
stration period and at $.08 per page during the second, third,
fourth and fifth year of the project. Postage has been estimated
at a fixed cost per month based on the experience of the applicant
in administering other grants. The cost of purchasing general
office supplies such as pencils, erasers, paper and envelopes
has also been projected.
f) Contractual Personnel Services
As discussed in Section 6.8.4, the applicant will utilize sub-
contractors for various portions of the grant administration
activities. Contractural personnel service budgets between the
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applicant and various subcontractors have been estimated for site
and operator selection assistance; process selection and design
review; environmental surveillance design; social impact evaluation;
inspection of site construction, start-up and operation; collection
of background environmental data and collection of environmental
data during facility operation. These contractural personnel
service budgets will be administered by the applicant. All
subcontracts will be written with a fixed upper limit so the
budgeted amounts will not be exceeded. A contractural personnel
service budget for the facility operator has also been included
under this budget category. An annual budget will be submitted
by the facility operator to the applicant. This annual budget
will include all salaries, fringe benefits, overhead, travel,
supplies (except equipment), and materials to plan, design,
construct and operate the facility including all subcontracts
administered by the facility operator. All facility operator
subcontracts must be approved by the applicant. The operator's
contractural personnel services budget does not include facility
equipment and construction costs. These items have their own
budgets and are discussed separately.
g) Construction
As illustrated in the implementation schedule, the construction
of the facility will begin during the second year of the demonstration
period. A construction cost estimate has been developed for the
construction of the facility. This estimate is shown on pages
6-149 and 6-150. Total construction cost of the facility,
excluding equipment, but including land, has been estimated to be
$2,716,000. Construction cost will, of course, vary depending on
the actual site. For example, a longer access road and a longer
sanitary sewer system are needed at the Flying Cloud Site than
at the Pine Bend Site. On the other hand, more water supply
wells will be lowered at the Pine Bend Site than at the Flying
Cloud Site. The budgeted construction cost represents an estimate
that will require re-evaluation when the final site is selected.
Detailed construction budgets will, of course, be prepared during
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the design of the facility and will be included in the annual grant
continuation requests. The size of the initial facility will be
structured to stay within the indicated budget or additional funds
will be obtained to supplement Minnesota's share of the demon-
stration grant.
h) Other
This budget category includes project costs to administer the
grant and carry out the demonstration project not included in other
budget categories. Legal support will be needed to prepare and
approve various contracts with the facility operator and with
subcontractors, to purchase land for the facility and to give
legal advice to the applicant regarding various grant administrative
activities. Telephone costs for long distance and local calls
plus additional telephone service have been estimated. Land
costs have been estimated based on the price of land in the two
site location areas. Insurance for the applicant has been included.
The applicant will supplement its present staff to assist in the
various grant administrative activities and, therefore, personnel
recruiting costs have been included. The applicant will also
prepare various graphics for the public education program and for
the various project related reports and the cost of printing
these graphics has been included. The applicant may utilize a
computer for project scheduling and project budget purposes so
the cost of a small amount of computer time has been included.
The applicant will obtain additional office space to administer
this grant, therefore, the cost of renting this office space has
been included. The Environmental Protection Agency also requires
that an audit of the demonstration project be carried out annually,
therefore, the cost of the audit has been included.
6.12.2 Budget Summary
The annual budgets, illustrated on pages 6-152 through 6-163, are
summarized below according to cost category and demonstration period.
Federal, nonfederal and user fees needed to fund the annual budgets
area also included in the table on the following page.
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$ 51,100 $
7,665
1,690
3,100
890
125,000
350,000
.19-, 200
62,945
9,442
1,860
760,000
1,350
250,000
590,000
30,000
§ 72,632
10,895
2,570
320,000
1,400
245,000
1,696,000
25,000
$ 61,560
9,234
2,020
20,000
1,400
210,000
50,000
16,000
$63,210
9,482
2,020
50,000
1,400
230,000
30,000
16,000
$ 311,667
46,718
10,160
1,153,100
6,440
1,060,000
2,716,000
106,200
First Second Third Fourth Fifth
Year Year Year Year Year TOTALS
Personnel Salaries
Fring Benefits
Travel
Equipment
Supplies
Contractural Servit
Construction
Other
Totals 558,645 1,705,597 2,373,497 370,214 402,112 5,410,065
FEDERAL 418,984 1,279,198 1,742,623 165,161 114,084 3,720,050
NONFEDERAL 139,661 426,399 580,874 55,053 38,028 1,240,015
USER FEES 0 0 50,000 150,000 250,000 450.000
$5,410,065
6.12.3 Funding Strategy
As discussed in Section 6.7, revenue bonds will be utilized to generate
the nonfederal share of the demonstration grant. The two agencies
(counties and Metropolitan Waste Control Commission) included in the
two alternative facility ownership/operator frameworks have the
existing authority to issue revenue bonds.
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CHEMICAL WASTE LAND DISPOSAL FACILITY
CONSTRUCTION COST ESTIMATE
1. FACILITY CONSTRUCTION
a) Site Preparation - mobilization, rough grading, erosion
control
$ 100,000
b) Buildings
Administrative
Laboratory
Equipment Storage
Waste Storage
Waste Preparation
Process
2,000 ft.2 @ $35/ft.2
3,000 ft.2 @ $30/ft.2
2,000 ft.2 @ $30/ft.2
7,000 ft.2 @ $25/ft.2
7,000 ft.2 @ $25/ft.2
$ 70,000
90,000
60,000
175,000
175.000
$ 570,000
c) Equipment
Site Preparation & Waste Placement
Waste Preparation Process
Office
Laboratory
Monitoring & Sample Collection
Rainmaking
Fire Protection & Safety
d) Disposal Area Preparation
Primary Barriers & Leachate Collection
Secondary Barriers & Leachate Collection
e) Paving
Storage Areas
Parking
Roads
50,000 ft.2 @ $l/ft.2
4,000 ft.2 @ $l/ft.2
t
1,500' x 24' wide @ $2/ft."
$250,000
500,000
10,000
220,000
40,000
20,000
30.000
$200,000
300,000
$ 50,000
4,000
72.000
$1,070,000
$ 500,000
$ 126,000
f) Utilities (sewer connection, well, water system,
gas, electricty)
$ 200,000
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1. FACILITY CONSTRUCTION (cont.)
g) Landscaping & Screening
h) Lower Water Supply Wells
$ 50,000
$ 120,000
i) Environmental Protection Facilities
Barrier Wells
Surface Runoff Stqrage
$ 60,000
120.000
$ 180,000
j) Fencing
$ 100,000
k) Land Purchase and Relocation
$ 400,000
1) Environmental Surveillance System
(construction cost)
i) Ground Waste Quality (piezometers,
soil cores)
ii) Surface Runoff & Air Quality
$ 80,000
10.000
$ 90,000
m) Contingencies
$ 200,000
TOTAL CONSTRUCTION COST
$3,706,000
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6.13 POTENTIAL DIFFICULTIES
The potential difficulties anticipated by the applicant in implementing the
demonstration project in Minnesota are outlined in this section. Also
included are the plans that the applicant intends to utilize to overcome the
identified difficulties.
6.13.1 Local Area Acceptance
The applicant anticipates that local public objections to the chemical
waste land disposal facility will present difficulties which must be
overcome to implement the project. As discussed in the two Environ-
mental Impact Appraisals, positive impacts to the local community
from the land disposal facility are difficult to identify. Although
industries attracted to the facility may increase the local tax
base, attracted industries may also decrease the desirability of the
community as a residential area. The residents of the local community
can be expected to be hesitant about welcoming a chemical waste
land disposal facility into the neighborhood.
The applicant intends to overcome this potential difficulty by
designing an environmentally-safe facility and by locating the
facility in an industrial area, adjacent to a major river away from
residential areas. The applicant will demonstrate that any leachate
accidentally released by the facility will not impair public health,
safety and welfare. The various occupational safety and health
programs to be implemented at the facility will also be stressed.
The applicant will also carry out an aggressive citizen acceptance
and public education program to bring the environmentally-safe
operation of the facility to people's attention. The applicant
anticipates that sufficient public support can be generated to obtain
the necessary approvals to construct the facility at one of the two
locations discussed in Section 6.3.4. A considerable amount of effort,
however, will be needed to obtain the local approvals.
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6.13.2 Budget Constraints
The applicant is aware that the U.S. Environmental Protection Agency
contemplates budgeting approximately 3.5 million dollars as the
Federal Government's share of the project. In preparing the project
cost estimates outlined in Section 6.12, the applicant became aware
of the constraints on project size and project flexibility imposed by
Federal and local budget constraints. The facility will be constructed
approximately two years after grant award and the increase in con-
struction co*t in two years is, of course, impossible to accurately
predict. The applicant is concerned that the type of facility needed
to demonstrate the various chemical waste land disposal techniques
will not be able to be constructed within the available budgets
in 1976 or 1977 when construction begins. Throughout the preliminary
and final design phases of the project, the applicant will continuously
re-evaluate project budgets and, if necessary, cut back the size of
the facility while still meeting the demonstration objectives. A
second alternative will be to obtain additional local money using the
funding strategies outlined in Section 6.12 or an alternative local
funding strategy that may be more feasible at the time of project
construction.
6.13.3 Obtaining Necessary Building Materials and Equipment
The applicant is aware of the present difficulties in obtaining
certain types of building materials and equipment. Due to shortages
in natural materials, it is expected that delays in obtaining building
materials and equipment will continue. The applicant will overcome
this difficulty by expediting the selection and design of necessary
waste preparation and si'te preparation processes. The implementation
schedule included in Section 6.11 allows approximately nine months
for equipment purchase and delivery. It is anticipated that at least
nine months will be needed to obtain some critical pieces of equipment.
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REFERENCES
1. Barr Engineering Company. Hazardous waste generation,
Twin Cities metropolitan area. Minneapolis,
Metropolitan Inter-County Council, Minnesota
Pollution Control Agency, (Oct. 1973). 1 v.
(various pagings).
2. Norvitch, R .P., T. G. Ross and A. Brietkrietz. Water resources
outlook for the Minneapolis-St. Paul metropolitan area. Minneapolis,
Metropolitan,Council of the Twin Cities Area, 1973. 219 p.
3. Wren, E. J. Preventing landfill leachate contamination of water.
U.S. Environmental Protection Agency, 1973. (120 p.) (Distributed
by National Technical Information Service, Springfield, Va., as
PB-222 468.)
4 Lackey, L. L. et al. Public attitudes towards hazardous waste disposal
facilities. U.S. Environmental Protection Agency, 1973. 181 p.
(Distributed by National Technical Information Service, Springfield,
Va., as PB-223 638.)
5. Evaluation of land and materials exposed to hazardous and toxic sludges.
Request for Proposal No. CI-75-0030. Cincinnati, U.S. Environmental
Protection Agency, 1974.
6. Program for the management of hazardous wastes for Environmental Protection
Agency, Office of Solid Waste Management Programs; final report.
Richland, Wash., Battelle Memorial Institute, July 1973. 385 p.
7. Reeder, H .0. and R. .F. Norvitch. Hydrogeologic reconnaissance of
of ground water pollution in the Pine Bend area, Dakota County,
Minnesota. St. Paul, Minn., U.S. Geological Survey, 1974. 27 p.
(Open-file report.)
8. Walker, W. H. Monitoring toxic chemical pollution from land disposal
sites in humid regions. Groundwater, 12(4):213-218, July-Aug. 1974.
9. Soil investigation of proposed sewage plant near Rosemount, Minnesota.
St. Paul, Minn., Soil Exploration Co., 1971. Unpublished data.
10. Gebhard, A.M. Vertical ground water hydrology in the Pine Bend area.
Minneapolis, Minn., Barr Engineering Co., 1975. 17 p. (Unpublished
report.)
11. United States Department of Agriculture, Soil Conservation Service.
Soil survey; Hennepin County, Minnesota. Washington, U.S.
Government Printing Office, Apr. 1974. 159 p., app.
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SUMMARY OF MINNESOTA LAWS
PERTAINING TO
HAZARDOUS WASTE MANAGEMENT
DEFINITIONS
"Hazardous Waste" means any refuse or discarded material or combinations
of refuse or discarded materials in solid, semi-solid, liquid, or gaseous
form which cannot be handled by routine waste management techniques because
they pose a substantial present or potential hazard to human health or
other living organisms because of their chemical, biological, or physical
properties. Categories of hazardous materials include, but are not limited
to: explosives, flammables, oxidizers, poisons, irritants, and corrosives.
(Minnesota Statutes, Section 116.05, Subd. 13)
"Hazardous Waste Management" means the identification, labeling, classifi-
cation, storage, collection, and removal of hazardous waste from public
and private property. Its transportation to intermediate or final disposal
facilities, and its ultimate disposal by approved methods. (Minnesota
Statutes, Section 400.03, Subd. 7)
RULES AND REGULATIONS
The Minnesota Pollution Control Agency shall adopt standards for the identi-
fication of hazardous waste and for the labeling, classification, storage,
collection, transportation, and disposal of hazardous waste, recognizing
that due to variable factors, no single standard of hazardous waste control
is applicable to all areas of the state. In adopting standards, the Minne-
sota Pollution Control Agency shall recognize that elements of control which
may be reasonable and proper in densely populated areas of the state may be
unreasonable and improper in sparely populated or remote areas of the state.
The Agency shall consider existing physical conditions, topography, soils,
and geology, climate, transportation, and land use. Standards of hazardous
waste control shall be premised on technical knowledge, and commonly accepted
practices. No local government unit shall set standards of hazardous waste
control which are in conflict or inconsistent with those set by the Pollu-
tion Control Agency. (Minnesota Statutes, Section 116.07, Subd. 2)
Pursuant to Chapter 15, the Minnesota Pollution Control Agency may adopt,
amend, and rescind regulations and standards having the force of law re-
lating to any purpose within the provisions of Chapter 116 for the identi-
cation, labeling, classification, storage, collection, treatment, and dis-
posal of hazardous waste and location of hazardous waste disposal facili-
ties. A regulation or standard may be of general application throughout
the state or may be limited as to time, places, circumstances, or condi-
tions. The Public Service Commission, in cooperation with the Minnesota
Pollution Control Agency, shall set standards for the transportation of
hazardous waste in accordance with Chapter 221.
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COUNTY ORDINANCE AND GENERATORS
i
The county may by ordinance establish and from time to time revise rules,
regulations, and standards for hazardous waste management relating to
(a) identification of hazardous waste, (b) the labeling and classifica-
tion of hazardous waste, (c) the handling, collection, transportation,
and storage of hazardous waste, (d) the ultimate disposal site of haz-
ardous waste, and (e) other matters as may be determined necessary for
the public health, welfare, and safety. The county may issue permits
or licenses for hazardous waste generation and may require the genera-
tors be registered with a county office. The ordinance may require
appropriate procedures for the payment by the generator of any costs
incurred by the county an'completing such procedures. If the generator
fails to complete such procedures, the county may recover the costs of
completion in a civil action in any court of competent jurisdiction or,
in the discretion of the board, the costs may be certified to the county
auditor, as a special tax against the land as other taxes are collected.
The ordinance may be enforced by injunction, action to compel performance,
or other action in district court. Any ordinance under this section shall
embody standards and requirements established by rules of the Agency.
Issuing, denying, modifying, imposing conditions upon, or revoking permits
pursuant to the provisions of this section or regulations promulgated here-
under shall be, subject to review, denial, suspension, and reversal by the
Minnesota Pollution Control Agency. The Minnesota Pollution Control Agency
shall, after written notification, have 15 days to review, suspend; modify
or reverse the action of the county. After 15 days, the action of the
county board shall be final subject to appear to the district court as
provided in Minnesota Statutes, Section 115.05. (Minnesota Statutes,
Section 400.161 and Section 473D.051)
STATEWIDE PLAN
The Minnesota Pollution Control Agency shall study and investigate the
problems of hazardous waste control and shall develop a statewide hazard-
ous waste management plan detailing the location of hazardous waste dis-
posal facilities and storage sites throughout the state and the needs
relative to the interstate transportation of hazardous waste.
Elements of the statewide hazardous spill contingency plan which relate
to hazardous waste, shall be incorporated into the statewide hazardous
waste management plan. The Minnesota Pollution Control Agency shall
develop an informational reporting system of hazardous waste quantities
generated and disposed of in the state. (Minnesota Statutes, Section 116.101)
METROPOLITAN PLAN
The Metropolitan Council shall prepare and by resolution adopt a compre-
hensive plan for the disposal of solid waste and the management and dis-
posal of hazardous waste in the metropolitan area for such period as the
Council deems appropriate and reasonable; and, when adopted, such plan
shall be followed in the metropolitan area. In developing the plan the
Council shall consider the preservation and best and most economical use
of land and water resources in the metropolitan area. The plan shall
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METROPOLITAN PLAN (cont'd.)
include a statement of goals and policies for solid waste disposal and
hazardous waste disposal and management, criteria for solid waste dis-
posal and management, criteria for solid waste disposal sites and hazard-
ous waste disposal sites, the general location and capacities of needed
disposal sites and facilities, projections of disposal capacities required,
regulations for the operation of disposal sites and facilities, a des-
cription of disposal techniques which may be used, the type or types of
solid waste and hazardous waste to be disposed of at each site or facility,
and such other details as the Council deems appropriate. Criteria for
solid waste disposal sites and hazardous waste disposal sites and facili-
ties, included in the plati, shall be consistent with regulations adopted
by the Agency pursuant to Sections 116.06 and 473D.07. The plan may be
revised as often as the Council deems necessary in the same manner as
provided for the adoption thereof. A copy of the comprehensive plan and
each revision thereof shall be delivered or mailed to the Agency and the
county auditor of each metropolitan county after it has been adopted.
Prior to the adoption by the Council of its comprehensive plan, no metro-
politan county or local governmental unit shall acquire any solid waste
disposal site or hazardous waste disposal site, or facility unless approved
by the Council, and after the comprehensive plan is adopted no metropolitan
county, local governmental unit, or person shall acquire, improve, or oper-
ate any solid waste disposal site or hazardous waste disposal site or facil-
ity in the metropolitan area except in accordance with the plan, provided
that no solid waste disposal site or hazardous waste disposal site or facil-
ity in use when the comprehensive plan is adopted shall be discontinued
solely because it is not located in an area designated in the plan as
acceptable for the location of such sites and facilties. (Minnesota Stat-
utes, Section 473D.03, Subd. 1)
COUNTY REPORT AND PLAN
Each metropolitan county, as a part of its solid waste plan, shall prepare
and submit to the Council for its approval, a report including: a descrip-
tion of the county hazardous waste ordinance, the county hazardous waste
generator licensing procedures, proposed procedures for implementing the
system, and an estimate of the total number of generators. Council approval
or disapproval of the report shall be consistent with this section.
(Minnesota Statutes, Section 473D.04, Subd. 2)
PERMITS
The Minnesota Pollution Control Agency may issue, continue in effect, or
deny permits, under such conditions as it may prescribe for the treatment
or disposal or both of hazardous waste, or for the installation or opera-
tion of any system or facility or any part thereof. (Minnesota Statutes,
Section 116.07, Subd. 4a)
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PERMITS (cont'd.)
No permit may be issued for the operation of a hazardous waste treatment
or disposal site, system, or facility in the metropolitan area which does
not comply with the Metropolitan Council's comprehensive plan. A copy of
each permit application and any supporting information furnished by the
applicant shall be sent to the Metropolitan Council within 15 days after
the receipt of the application and all other information requested from
the applicant. Within 45 days after the application and supporting in-
formation are received by the Council, it shall issue to the Agency in
writing its determination whether the permit comples with its comprehen-
sive plan. If the Council does not issue its determination to the Agency
within the 45 day period, the permit shall be Adeemed to be in accordance
with the Council's comprehensive plan.
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MINNESOTA ADMINISTRATIVE
RULES AND REGULATIONS
MINNESOTA POLLUTION
CONTROL AGENCY
DIVISION OF SOLID WASTE
1970 EDITION
Minn. Reg. SW 1, 2, 3, 4, 5, 6, 7,8, 9,10,11
Distributed by
DOCUMENTS SECTION, DEPARTMENT OF ADMINISTRATION
Room 140 Centennial Building, St. Paul, Minnesota 55101
150
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MINNESOTA POLLUTION CONTROL AGENCY
DIVISION OF SOLID WASTE
Solid Waste Disposal Regulations
January 12,1970
TABLE OF CONTENTS
Preamble Page
SW1 Applicability, Definitions and General Conditions for Solid Waste
Collection, Transportation and Disposal SeverabOlty and Vari-
ances ". 7
SW 2 Solid Waste Storage 11
SW 3 Collection and Transportation of Solid Waste 13
SW 4 Intermediate and Final Disposal of Solid Waste 15
SW 5 Plan Approval and Permit Issuance, Denial and Revocation 17
SW 6 Sanitary Landfill 19
SW 7 Incineration 23
SW 8 Composting 25
SW 9 Other Methods of Solid Waste Handling, Processing and Disposal 27
SW 10 Nonconforming Sites and Facilities 29
SW 11 Exemptions and County Solid Waste Management System 31
Index '.. 33
151
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MINNESOTA POLLUTION CONTROL AGENCY
SOLID WASTE DISPOSAL REGULATIONS
PREAMBLE
The high level of production required to meet the varied needs of an ex-
panding population and high standard of living has resulted in a sharp rise
in the amount of waste materials discarded annually. Inefficient and im-
proper methods of waste disposal have caused ever-increasing pollution of
our vital airland and water resources threatening the utility of our resources
and the quality of the environment in which we live. Improper waste stor-
age, collection,.transportation and disposal endanger the public health, safety
and welfare, create public nuisances, result in scenic blight and adversely
affect land values. The close interrelationship of air, land and water pollu-
tion requires concerted action to preserve and improve the quality of our
environment. A problem concerning solid waste will not be solved satis-
factorily by creating air pollution, nor will a problem in air pollution be
solved satisfactorily by intensifying the problems of water pollution. Imme-
diate remedial action is needed to protect our valuable resources, and can
only be accomplished through dedicated joint efforts.
The following solid waste disposal standards and regulations apply to
any solid waste management system located partially or wholly within the
State of Minnesota. Regulations are of general application throughout the
state unless specifically indicated otherwise by their context. The official
policy and purpose of the State of Minnesota in regard to solid waste control
is set forth in Laws 1969, Chapter 1046 (Codified as Minnesota Statutes
1967, Section 116.07):
Subd. 2. The pollution control agency shall also adopt standards for the
control of the collection, transportation and disposal of solid waste for
the prevention and abatement of water, air and land pollution, recognizing
that due to variable factors, no single standard of solid waste control is
applicable to all areas of the state. In adopting standards, the pollution
control agency shall give due recognition to the fact that elements of con-
trol which may be reasonable and proper in densely populated areas of
the state may be unreasonable and improper in sparsely populated or
remote areas of the state, and it shall take into consideration in this
connection such factors, including others which it may deem proper, as
existing physical conditions, topography, soils and geology, climate, trans-
portation and land use. Such standards of solid waste control shall be
premised on technical criteria and commonly accepted practices.
Subd. 4. Pursuant and subject to the provisions of chapter 15, and the
provisions hereof, the pollution control agency may adopt, amend and
rescind regulations and standards having the force of law relating to any
purpose within the provisions of this act for the collection, transportation,
and disposal of solid waste and the prevention, abatement, or control of
water, air. and land pollution which may be related thereto, and the de-
posit in or on land of any other material that may tend to cause pollution.
Any such regulation or standard may be of general application throughout
the state or may be limited as to times, places, circumstances, or condi-
tions in order to make due allowance for variations therein. Without
limitation, regulations or standards may relate to collection, transportation,
disposal, equipment, location, procedures, methods, systems or techniques
152
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or to any other matter relevant to the prevention, abatement or control of
water, air, and land pollution which may be advised through the control
of collection, transportation and disposal of solid waste, and the deposit in
or on land of any other material that may tend to cause pollution.
Consistent with these objectives, it shall be the policy of the Pollution
Control Agency to encourage the development and expansion of solid waste
control programs in cities, counties and other political subdivisions of the
state and to provide planning, technical and enforcement assistance.
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RULES AND REGULATIONS S« I
(Delete pages 7-9 in 1970 Edition and insert SW1)
SW 1 Applicability, Definitions and General Conditions for Solid Waste
Collection, Transportation and Disposal. Severabiliry and Variances.
APPLICABILITY
These are regulations and standards the provisions of which govern the
storage, collection, transportation, treatment, utilization, processing, transfer,
intermediate disposal and final disposal of solid waste by any person and the
issuing of permits for the construction and operation of solid waste disposal
sites and facilities for the protection of the environment in keeping with
Chapters 115, 116, 400 and 473D of the Minnesota Statutes 1971.
DEFINITIONS
For the purpose of these regulations
(1) Agency. The Minnesota Pollution Control Agency, its agent or
representative
(2) Cell. Compacted solid wastes that are enclosed by cover material in
a land disposal site.
(3) Composting The controlled biological decomposition of selected
solid waste in a manner resulting in an innocuous final product.
(4) Cover Material. Material that is used to cover compacted solid waste
in a land disposal site. Important general characteristics of good cover ma-
terial are low permeability, uniform texture, cohesiveness and compactibility.
Suitable cover material includes sandy loam, loam, silt loam, sandy clay
loam, silty clay loam, clay loam, sandy clay and loamy sand
(5) Daily Cover. Cover material that is spread and compacted on the
top and side slopes of compacted solid waste at least at the end of each
operating day in order to control vectors, fire, infiltration and erosion and to
assure an aesthetic appearance.
(6) Decomposition Gases. Gases produced by chemical or microbial
activity during the decomposition of solid waste.
(7) Director. Director of the Minnesota Pollution Control Agency.
(8) Final Solid Waste Disposal. The site, facility, operating procedures,
and maintenance thereof for the complete and ultimate disposal of solid
waste by the sanitary landfill method.
(9) Flood Plain. As defined in Minnesota Statutes 1971, Chapter 104.
(10) Free Moisture. Liquid that will drain freely by gravity from solid
materials.
(11) Garbage. Discarded material resulting from the handling, processing,
storage, preparation, serving and consumption of food.
(12) Hazardous Infectious Waste Waste originating from the diagnosis,
care or treatment of a person or animal that has been or may have been
exposed to a contagious or infectious disease. Hazardous infectious waste
includes, but is not limited to.
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SW 1 DIVISION OF SOLID WASTE
(a) All wastes originating from persons placed in isolation for control
and treatment of an infectious disease.
(b) Bandages, dressings, casts, catheters, tubing, and the like, which
have been in contact with wounds, burns, or surgical incisions and which
are suspect or have been medically identified as hazardous.
(c) All anatomical waste, including human and animal pans or tissues
removed surgically or at autopsy.
(d) Laboratory and pathology waste of an infectious nature which has
not been autoclaved.
(e) Any other waste, as defined by the State Board of Health, which,
because of its hazardous nature, requires handling and disposal in a manner
prescribed for (a) through (d).
(13) Hazardous Wastes. Waste materials that are (a) toxic or poison-
ous; (b) corrosive; (c) irritating or sensitizing; (d) radioactive; (e) hazardous
infectious; (f) explosive; .or (g) flammable and that present a significant
hazard to human health and the environment. They include, but are not
limited to, those materials and concentrations of materials that are deter-
mined to be toxic by the U. S. Secretary of Health, Education, and Welfare
pursuant to Section 10.6, of the Occupational Safety and Health Act of
1970 (Public Law 91-596).
(14) Incineration. The process of burning wastes for the purpose of
volume and weight reduction in facilities designed for such use.
(15) Intermediate'Solid Waste Disposal. The site, facility, operating
procedures and maintenance thereof, for the preliminary or incomplete
disposal of solid waste including, but not limited to, transfer station, open
burning, incomplete land disposal, incineration, composting, reduction,
shredding and compression.
(16) Land Disposal Site. Any tract or parcel of land, including any
constructed facility, at which solid waste is disposed of in or on the land.
(17) Land Pollution. The presence in or on the land of any solid waste
in such quantity, of such nature and duration, and under such condition as
would affect injuriously any waters of the state, create air contaminants or
cause air pollution.
(18) Leacbate. Liquid that has percolated through solid waste and has
extracted, dissolved or'suspended materials from it.
(19) Municipality. A city, village, borough, county, town, sanitary dis-
trict or other governmental subdivision or public corporation, or agency
created by the legislature.
(20) Open Burning. Burning'any matter whereby the resultant combus-
tion products are emitted directly to the open atmosphere without passing
through an adequate stack, duct or chimney.
(21) Open Dump. A land disposal-site at which solid waste is disposed of
in a manner that does not protect the environment, is susceptible to open
burning and is exposed to the elements, flies, rodents and scavengers.
(22) Person. Any human being, any municipality or other governmental
or political subdivision or other public agency, any public or private corpora-
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RULES AISD REGULATI01\S $W 1
tion, any partnership, firm, association, or other organization, any receiver,
trustee, assignee, agent, or other legal representative of any of the foregoing,
or any other legal entity, but does not include the pollution control agency.
(23) Refuse. Putrescible and noputrescible solid wastes, including gar-
bage, rubbish, ashes, incinerator ash, incinerator residue, street cleanings,
and market and industrial solid wastes, and including municipal treatment
wastes which do not contain free moisture.
(24) Refuse Collection Service. A public or private operation engaged in
solid waste>collection and solid waste transportation.
(25) Regional Flood. As defined in Minnesota Statutes 1971, Chapter
104.
(26) Rubbish. Nonputrescible solid wastes, including ashes, consisting of
both combustible and noncombustible wastes, such as paper, cardboard, tin
cans, yard clippings, wood, glass, bedding, crockery, or litter of any kind.
(27) Runoff. The portion of precipitation that drains from an area as
surface flow.
(28) Sanitary Landfill. A land disposal site employing an engineered
method of disposing of solid waste on land in a manner that minimizes
environmental hazards by spreading the solid waste in thin layers, compact-
ing the solid waste to the smallest practical volume, and applying cover
material at the end of each operating day, or at intervals as may be required
by the Agency.
(29) Scavenging. Uncontrolled removal of solid waste materials.
(30) Solid Waste. Garbage, refuse and other discarded solid materials,
except animal waste used as fertilizer, including solid waste materials re-
sulting from industrial, commercial and agricultural operations, and from
community activities. Solid waste does not include earthen fill, boulders, rock
and other materials normally handled in construction operations, solids or
dissolved material in domestic sewage or other significant pollutants in
water resources, such as silt, dissolved or suspended solids in industrial
waste water effluents, dissolved materials in irrigation return flows, or
other common water pollutants.
(31) Solid Waste Collection. The gathering of solid waste from public
or private places.
(32) Solid Waste Management System. A total system for the storage,
collection, transportation, intermediate and final disposal of solid waste.
(33) Solid Waste Storage. The holding of solid waste near the point of
generation.
(34) Solid Waste Transportation. The conveying of solid waste from one
place to another, by means of vehicle, rail car, water vessel, conveyor or
other means.
(35) Transfer Station A facility in which solid waste from collection
vehicles is concentrated for subsequent transport A transfer station may
be fixed or mobile.
(36) Underground Water The water contained below the surface of the
earth in the saturated zone including, without limitation, all waters whether
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SW I UlVISIOiS OF SOLID WASTE
under confined, unconfined or perched conditions in near surface uncon-
bolidated sediment or regolith, or in rock formations deeper underground.
The term ground water shall be synonymous with underground water. Refer
to Minnesota Pollution Control Agency Regulation WPC 22.
(37) Water Monitoring System. A system of wells, lysimeters, or other
mechanisms used to obtain representative samples of both underground water
and surface water where required in the vicinity of a land disposal site
(38) Water Table. The surface of the ground water at which the pressure
is atmospheric Generally this is the top of the saturated zone. Refer to
Minnesota Pollution Control Agency Regulation WPC 22.
(39) Wetland. A natural marsh where water stands near, at or above
the soil surface during a significant portion of most years, and which is
eligible for classification as an inland fresh water wetland type 3, 4 or 5
under U. S. Department of Interior classifications
(40) Working Face. That portion of the land disposal site where waste is
discharged and is spread and compacted prior to the placement of cover
material.
GENERAL CONDITIONS
All solid waste shall be stored, collected, transferred, transported, utilized,
processed and disposed of, or reclaimed in a manner consistent with
requirements of these regulations The Agency is responsible for enforcement
of these regulations and encourages cooperation of municipalities which may
adopt these regulations for use in local laws, ordinances or regulations
SEVERAB1LITY
If any provision of any regulation or the application thereof to any
person or-circumstances is .held to be invalid, such invalidity shall not affect
other provisions or application of any other part of such regulation or any
other regulation which can be given effect without the invalid provision of
application, and to this end the provisions of all regulations and the various
applications thereof are declared to be severablc
VARIANCES
Where upon written application of the responsible person or persons the
Agency finds that by reason of exceptional circumstances strict conformity
with any provisions of the regulations contained herein would cause undue
hardship, would be unreasonable, impractical, or not feasible under the
circumstances, the Agency may permit a variance from these regulations
upon such conditions and within such time limitations as it may prescribe
for prevention, control or abatement of air, land or water pollution in
harmony with the intent of the State and any applicable Federal laws.
Filed with Secretary of State and Commissioner of Administration
September 26, 1973
157
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RULES AND REGULATIONS 8V 0
SW 2 Solid Waste Storage
(1) The owner and occupant of any premises, business establishment, or
industry shall be responsible for the satisfactory storage of all solid waste
accumulated at that premise, business establishment or industry.
(2) Garbage and similar putrescible waste shall be stored in:
(a) Durable, rust resistant, nonabsorbent, watertight, rodent proof, and
easily cleanable containers, with close fitting, fly-tight covers and having
adequate, handles or bails to facilitate handling, or;
(b) Other types of containers acceptable to the municipality and con-
forming to the intent of this regulation.
(c) The size and allowable weight of the containers may be determined
by the refuse collection service subject to requirements of the municipality.
(3) Refuse shall be stored in durable containers or as otherwise provided
in this regulation. Where garbage and similar putrescible wastes are stored
in combination with nonputrescible refuse, containers for the storage of the
mixture shall meet the requirements for garbage containers.
(4) Toxic or hazardous wastes shall be stored in the proper containers
which are adequately labeled in a safe location and in compliance with the
regulations of federal, state and local governments, and their regulatory
agencies.
(5) All containers for the storage of solid waste shall be maintained in
such a manner as to prevent the creation of a nuisance or menace to public
health. Containers that are broken or otherwise fail to meet requirements
of this regulation shall be replaced with acceptable containers.
(6) Solid waste objects or materials too large or otherwise unsuitable for
storage containers shall be stored in a pollution and nuisance free manner
and in compliance with the regulations of federal, state and local govern-
ments, and their regulatory agencies.
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HUES AND BECULATIONS SW 8
SW 3 Collection and transportation of Solid Waste
(1) The owner and occupant of any premises, business establishment or
industry and/or the refuse collection service shall be responsible for the
satisfactory collection and transportation of all solid waste accumulated at
a premise) business establishment or industry to a solid waste disposal site
or facility, for which a permit has been issued by the Agency unless otherwise
provided in these regulations.
(2) Vehicles or containers used for the collection and transportation of
garbage and similar putrcscible wastes, or refuse containing such materials,
shall be covered, leak proof, durable and of easily cleanable construction.
These shall be 'cleaned to prevent nuisances, pollution or insect breeding,
and shall be*maintained in good repair.
(3) Vehicles or containers used for the collection and transportation of
any solid waste shall be loaded and moved in such a'manner that the contents
will not fall, leak or spill therefrom, and shall be covered when necessary
to prevent blowing of material. Where spillage does occur, the material shall
be picked up immediately by the collector or transporter and returned to
the vehicle or container and the area properly cleaned.
(4) Vehicles and containers used for the collection and transportation of
toxic or hazardous wastes shall be durable, enclosed and Icakproof and shall
be constructed, loaded, moved and unloaded in a safe manner and in com-
pliance with the regulations of federal, state and local governments and
their regulatory agencies.
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BULBS AND BEGULATIONS SW 4
SW 4 Intermediate and Final Disposal of Solid Waste
Open burning is prohibited at all intermediate and final solid waste dis-
posal sites, except as shall be allowed by any regulations of the Agency
now or hereafter adopted.
Solid waste shall not be deposited at any intermediate or final solid waste
disposal site in such a manner that material or teachings therefrom may
cause pollution of ground or surface waters.
A persist shall make an intermediate or final disposal of any solid waste,
only at a site or facility for which a permit has been issued by the Agency
unless otherwise provided by these regulations. Permits shall not be required
for sites used for the disposal of solid waste from only a single family or
household, a member of which is the owner, occupant or lessee of the
property, under these regulations, but these shall be operated and maintained
in a nuisance-free, pollution-free and aesthetic manner consistent with the
intent of these regulations.
Disposal of toxic and hazardous wastes shall be in a safe and pollution-
free manner and in compliance with the regulations of federal, state and
local governments and their regulatory agencies.
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RULES AND REGULATIONS SW 8
SW 5 Plan Approval and Permit Issuance, Denial and Revocation
It shall be unlawful for any person to establish, maintain, conduct or
operate an intermediate or final solid waste disposal site or facility except
as provided in these regulations without first obtaining a permit from the
Agency.
(1) Although a permit shall be granted the same shall become effective
only if the location of the site or facility shall conform to all applicable
federal, state and local laws, ordinances and regulations.
(2) EacH, permit application shall be accompanied by plans as described
in these" regulations and a plan of operation indicating procedures which
will be followed to fulfill requirements of these regulations.
(3) Plans and specifications shall be approved and a permit issued when
the Director of the Agency believes that they are in accordance with the
requirements as set forth in these regulations.
(4) Denial of Permit. When a permit is denied, applicant shall be notified
in writing of the reasons theiefor. A denial shall be without'prejudice to the
applicant's right to an appearance before the Agency or for filing a further
application after revisions are made to meet objections specified as reasons
for the denial
(5) Revocation of Permit. Permits may be revoked for violation of these
regulations.
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HUES AND REGULATIONS SW 6
(Delete page* 19-21 in 1970 Edition and inierf SW 6)
SW 6 Sanitary Landfill
The sanitary landfill method shall be used for all final disposal of solid
waste.
(1) The fill and trench areas of sanitary landfill sites aie prohibited within
the following areas, as existing at the time of receipt of the permit application
by the Agency.
(a) l"00b feet from the normal high water mark of a lake, pond or
flowage.
(b) 300 feet from a stream.
(c) A regional flood plain (100 year flood).
(d) Wetlands
(e) Within 1,000 feet of the nearest edge of the right-of-way of any
state, federal or interstate highway or of the boundary of a public park or
of an occupied dwelling. Permission may be granted under this subsection,
without these distance requirements, at the discretion of the Director, taking
into consideration such factors as noise, dust, litter and other aesthetic and
environmental considerations
(f) Locations considered hazardous because of the proximity of airports.
(g) An area which is unsuitable because of reasons of topography,
geology, hydrology or soils.
(2) Any person who maintains or operates a sanitary landfill site or
permits the use of property for such, shall maintain and operate the site in
conformance with the following practices unless otherwise allowed by the
Agency in issuing the required permit:
(a) Open burning shall be prohibited
(b) Solid waste shall not be deposited in such a manner that material
or teachings therefrom may cause pollution of underground or surface
water.
Proposed separation between the lowest portion of the landfill and the
high water table elevation shall be a minimum of five feet This requirement
shall not be construed to render inoperative any other requirements specified
herein and additional ground water protection shall be provided if needed.
(c) Dumping of solid waste shall be confined to as small an area as
practicable and with appropriate facilities to confine possible wind-blown
material within the area. At the conclusion of each day of operation, all
wind-blown material resulting from the operation shall be collected and
returned to the area by the owner or operator.
(d)(i) Solid waste shall be compacted as densely as practicable and
covered after each day of operation, or as specified by the Director, with a
compacted layer of at least six inches of suitable cover material. All previ-
ously filled areas shall be maintained with at least six inches of suitable
cover material
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SW « DIVISION OF SOLID WASTE
(u) If refuse cells will 'be exposed to the elements for a period
of 120 days or longer, an intermediate cover totalling at least twelve inches
of compacted, suitable cover material shall be provided and maintained.
(iii) There shall be an available supply of suitable cover material,
which, if necessary,-shall be stockpiled and protected for winter operation.
(iv) The sanitary landfill shall be constructed and cover material
graded so as to promote surface water runoff without excessive erosion.
(e) Surface water drainage shall be diverted around and away from the
landfill operating area.
(f) A minimum separating distance of 20 feet, or greater as specified
by the Director, shall be maintained between the disposal operation and the
adjacent property line.
(g) Effective means shall be taken if necessary to control flies, rodents,
and other insects or vermin.
(h) The approach road to the disposal site and the access road on the
site shall be of all-weather construction and maintained in good condition
so that they will be passable at all times for any vehicle using the site.
(0 Adequate dust control on the site shall be provided.
(j) Equipment shall be available for adequate operation of the site.
The equipment shall be provided with adequate safety devices and adequate
noise control devices.
(k) Equipment shall be provided and kept at the site during the hours
of operation to control accidental tires and arrangements made with the local
fire protection agency to immediately acquire their services when needed.
(1) Adequate communication facilities shall be provided for emergency
purposes.
(m) Sanitary facilities and shelter shall be available for site personnel.
(n) Scavenging shall be prohibited to avoid injury and prevent inter-
ference with operations.
(o) The site shall be adequately screened by existing or provided means.
(p) There shall be qualified personnel for general direction and opera-
tion of the site on duty at all times while it is open for public use.
(q) Access to the site shall be controlled. A gate shall be provided at
the entrance to the site and kept locked when an attendant is not on duty.
(r) A permanent sign, identifying the operation and showing the permit
number of the site, and indicating the hours and days the site is open for
public use, rates, hazardous wastes information, the penalty for nonconform-
ing dumping, and other pertinent information, shall be posted at ,the site
entrance. " '
(s) A water monitoring program shall be constructed and operated to
determine whether or not solid waste or leachate therefrom is causing
pollution of underground or surface water. The drilling and construction
of all site wells, including those used for monitoring purposes, shall be done
in compliance with Minnesota Statutes 1973, Chapter 747.
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RULES AND REGULATIONS SW «
The conditions of monitoring, including the frequency and the analysis of
water monitoring samples, shall be determined by the Director and may be
changed at his discretion.
(t) Approved leachate collection and treatment systems shall be used
where required to protect underground and surface water.
(u) Decomposition gases shall not be allowed to migrate laterally from
the sanitary landfill. They shall be vented into the atmosphere directly
through the coyer material, or into cut-off trenches, or in.o the atmosphere
by forced ventilation, or by other means approved by th
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SW b DIVISION OF SOLID WASTE
nated during winter conditions. If necessary, seeded slopes shall be covered
with straw or similar material to prevent erosion.
(ni) Prior to completion of a sanitary landfill site, the Agency
shall be notified in order that a site investigation may be conducted by the
Agency, staff before earth moving equipment is removed from the property.
(iv) After completion of a sanitary landfill site, a detailed descrip-
tion, including a plat, shall be recorded with the county register of deeds.
The description shall include general types and location of wastes, depth
of fill, and other information ot interest to future land owners.
(v) IfMhc completed site is to be cultivated, the integrity of the
finished surface shall not be disturbed by agricultural cultivation activities If
cultivated, a sufficient depth ot cover material to allow cultivation and to
support vegetation shall be maintained
(3) Plans, including a permit application, report and drawings shall be
prepared by a registered engineer of Minnesota. Three complete sets of
the plans shall be submitted to the Agency. The submitted plans shall
include the following
(a) A completed permit application form
(b) An engineering report including
0) General information.
(n) Site analysis including consideration of each item in SW 6 (1)
along with data and supplementary reports, including soil boring data and
a hydrogeologic study. Attention to this requirement must include consider-
ation of surface features, underground formations, soil boring data from
soil borings of which at least one is to a minimum depth of SO feet below
proposed excavation and lowest elevation of the site, water table profile,
direction of underground water flow, initial quality of water resources
in the potential zone of influence of the landfill, use of water resources in
the potential zone of influence of the landfill, need and availability of cover
material, and existing refuse deposits. Also considered shall be climate,
average rates of precipitation based on average monthly rates from records
of rain gauge stations, cvapotranspiration, runoff and infiltration.
(in) Proposed operating procedures including consideration of each
item in SW 6 (2)
(iv) Equipment to be used for operation of the site.
(c) Drawings, folded to 8V4 by 11 inch size, including:
(i) An Existing Conditions Plan of the area showing land use and
zoning within '/& mile of the proposed solid waste disposal site The plan
shall show all buildings, lakes, ponds, watercourses, wetlands, sinkholes,
rock outcroppings, roads, public parks and other applicable details and shall
indicate the .general topography with contours and drainage patterns. An
on-site bench mark shall be indicated and a north arrow drawn. A location
insert map and a U.S.G.S topographic map of the area shall be included.
The scale of the existing conditions plan shall not be greater than 300
feet per inch
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RULES AND REGULATIONS S« 6
(u) A Development Plan of the site and immediately adjacent area
showing dimensions, contours, at contour intervals of two feet or less, sod
boring locations with surface elevations and present and planned pertinent
features, including but not limited to roads, screening, buffer zone, fencing,
gate, shelter and equipment buildings, surface water diversion and drainage,
water monitoring system and the hazardous wastes storage area. The develop-
ment plan shall show progressive development of trench and/ or area fills
and any phase construction. The scale of the development plan shall not
be greater than 200 feet per inch.
The development plan shall include consideration of the ultimate land
use, for example, pre-planned building islands, not to be used for landfill ing
of refuse.
(in) Cross Sections Plan including a minimum of two cross sections
of each phase, perpendicular to one another, showing existing grade, excava-
tion grade, final grade, any additional ground water protection, high water
table profile and profile of a separation line five feet above, profile and
identity of soils and profile and identity of bedrock.
(iv) An Ultimate Land Use Plan showing the land use after the site
is completed, final contours, at contour intervals of two feet or less, and
surface water drainage. Consideration shall be given in the design of an
ultimate land use plan to gas control, erosion and differential settlements.
The scale of the ultimate land use plan shall not be greater than 200 feet
per inch.
(4) A sanitary landfill shall not be opened or placed into operation until:
(a) An Agency permit has been issued.
(b) A construction certification has been approved by the Director.
The certification, signed by the project engineer, shall certify, with any
exceptions listed, that the construction has been completed in accordance
with the plans and Agency permit. It shall be certified that an Agency-
approved water monitoring system is functional and includes an analysis of
initial water monitoring samples
If any construction has been scheduled in the plans for phase development
subsequent to the initial operation, then a similar certification shall be
approved for each phase before it shall be operated.
system
(c) The site is consistent with the county solid waste management
plan.
(5) These regulations shall be effective as to the construction of permitted
sanitary landfills when the permit applications and final plans are received
after the date these regulations are filed with the Commissioner of Admin-
istration; provided, however, the Agency reserves the right to require
compliance with any provision of these regulations in order to abate
pollution.
Filed with Secretary of State and Commissioner of Administration
September 26,
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RULES AND REGULATIONS SW 7
SW 7 Incineration
This regulation applies only to existing and new incinerators having a
capacity greater than 6,000 pounds per hour and those for the incineration
of toxic or hazardous wastes: All incinerators shall be designed and operated
in a manner to conform to emission limitations of Regulation APC 7 and
other Air Pollution Control Regulations of the Agency now or hereafter
adopted. All incinerators shall have adequate disposal of liquid wastes. Any
discharge to surface or ground waters of the state must meet the Agency's
regulations of water quality or effluent standards now or hereafter adopted.
Residue from all incinerators must be disposed of in conformance with these
regulation;.
(1) It is unlawful for any person to install a new incinerator or install or
alter any incinerator appurtenances, except for routine maintenance, without
first having been issued a permit by the Agency.
(2) When a permit is desired, the following details shall be submitted to
the Agency for review:
(a) A minimum of three sets of plans and specifications, folded to 8Vi
inch by 11 inch size, prepared by a registered engineer of Minnesota, clearly
indicating the construction which will be undertaken. These details shall
include a plot plan showing land use, zoning, and the location, type and
height of all buildings within 500 feet of the proposed installation.
(b) An engineering report including furnace design criteria and ex-
pected performance data, the present, and future population and area to be
served by the incinerator,, and the characteristics, quantities and sources of
solid waste to be incinerated.
(c) Plans for the disposal of incinerator residue, and emergency disposal
of solid waste in the event of major incinerator plant breakdown.
(d) Information relating to Regulation SW 5.
(e) Owner of the site and/or plant.
(f) Persons responsible for actual operation and maintenance of the
plant and intended operating procedures.
(g) Such additional data and information as may be requested by the
Agency.
(3) The incinerator operation for each proposed installation shall be con-
sidered for approval on its own merits, shall be in compliance with the
following criteria, and in accordance with accepted engineering practices.
(a) The,incinerator plant shall be so situated, equipped, operated, and
maintained as to minimize interference with other activities, in the area.
(b) Shelter and sanitary facilities shall be available for plant personnel.
(c) A permanent sign shall be posted at the site entrance identifying
the operation and showing the permit number of the plant, and indicating
the hours and days when the plant is open for public use. Access to the
plant shall be limited to those times when authorized personnel are on duty.
(d) All incoming solid waste to be incinerated at the plant shall be
confined to the unloading area. Adequate holding bin capacity shall be
provided.
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SW 7 DIVISION OF SOLID WASTE
(e) Facilities shall be designed to provide for dust control in the un-
loading and charging areas.
(f) The incinerator plant shall have weighing facilities available. The
Agency may require that permanent records be maintained for inspection
as to the total weight of material incinerated, the total quantity of resulting
residue and total hours of plant operation.
(g) Fire-fighting equipment, meeting the standards of Underwriters
Laboratory, Inc., or other approved nationally recognized safety standards,
shall be available in the storage and charging areas and elsewhere as needed.
(h) Arrangements shall be made with the local fire protection agency
to provide fire-fighting forces in an emergency.
(i) Adequate communication facilities shall be provided for emergency
purposes.
(j) Equipment shall be provided in the storage and charging areas and
elsewhere as needed to allow cleaning after each day of operation or as may
be required in order to maintain the plant in a sanitary condition.
(k) The charging openings as well as all equipment throughout the
plant shall be provided with safety equipment.
(I) During normal operation, the temperature in the combustion cham-
bers shall conform to Regulation APC 7 and other Air Pollution Control
Regulations of the Agency now or hereafter adopted, to produce a satis-
factory residue and to result in an odor-free operation.
(m) A continuously recording pyrometer shall be provided in order to
maintain continuous records of temperature in the combustion chambers.
A copy of such records shall be available for the Agency upon request.
(n) All residue removed from the incinerator plant shall be promptly
disposed of at an approved site, and in a manner that will prevent nuisances,
pollution and public health hazards. Residue containing combustible ma-
terial shall be disposed of in a sanitary landfill in conformance with Regula-
tion SW 6.
(o) Upon completion of the plant and prior to initial operation, the
Agency shall be notified to allow personnel of the Agency to inspect the
plant both prior to and during the performance tests.
(p) Performance tests of the plant may be required by the Agency. A
report covering the results of the performance tests in such case shall be
prepared by the design engineer of the project and submitted to the agency
with the copy of all supporting data.
(4) Existing incinerators which do not meet the above criteria shall be
reconstructed in order to meet the foregoing standards as specified in Regu-
lation SW 10.
(5) Reports describing the total weight of material incinerated, the total
quantity of resulting residue and residue disposition, and the total hours of
plant operation shall be submitted to the Agency every month, together with
other information on the operation of the incinerator.
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RULES AND REGULATIONS SW 8
SW 8 Composting
(1) It is unlawful for any person to install or alter any composting opera-
tion without first having been issued a permit by the Agency. (See also
SW,4)
(2) When a permit is desired, the following 'details shall be submitted to
the Agency for review, prepared by a registered engineer of Minnesota.
(a) A minimum of three sets of plans and specifications; 'folded to 8V4
inch by 11 inch size, clearly indicating the layout and construction which
will be undertaken.
(b) A minimum of three sets of maps or aerial photographs indicating
land use and zomn« within ]A mile of the facility. The map or aerial photo-
graph shall be of adequate scale to show all homes, buildings, lakes, ponds,
watercouses, wetlands, dry runs, rock outcroppmgs, roads and other applica-
ble details and shall indicate the general topography with contours and drain-
age patterns. Wells and soil boring locations should be identified on the
map or aerial photograph.
(c) Details relating to geological formations of the property whereon
the proposed installation is to be located. Such details shall be determined
by soil borings or other appropriate means to a depth of at least ten feet.
The high water table should be included.
(d) An engineering report outlining the proposed method of operation,
the quantity and source of material to be processed, the proposed use and
distribution of the processed material, and related details.
(e) Information relating to Regulation SW 5.
(f) Owner of the site and/ or plant.
(g) Persons responsible for actual operation and maintenance of the
plant.
(h) Additional data or information may be required by the Agency.
(3) The operation shall be conducted in a manner which minimizes
pollution, public health hazards and nuisances.
(4) Materials resulting from composting or similar processes and of-
fered for sale shall contain no pathogenic organisms, shall not reheat upon
standing, shall be innocuous, and shall contain no sharp particles which
would cause injury to persons handling the compost.
(5) By-products removed during processing shall be handled in a pollu-
tion and nuisance free manner and shall be disposel of as provided in these
regulations.
(6) Reports describing the types and amounts of waste composted, the
amount of compost produced, and the amounts of by-products removed
and the disposition of the by-products shall be submitted to the Agency every
month together with other information on the operation of the compost
plant.
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RULES AND REGULATIONS SW 9
SW 9 Other Methods of Solid Waste Handling, Processing and Disposal
Before a site or facility for any method of solid waste handling, processing
and disposal, including transfer stations, not otherwise provided for in these
regulations is practiced or placed into operation, three sets of complete
plans, specifications, design data, ultimate land use plan and proposed
operating procedures shall be submitted to the Agency for review and permit
issuance. All such information shall be prepared and submitted by a regis-
tered professional engineer of Minnesota.
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BULKS AND RECUIATIONS SW 1O
SW 10 Nonconfortning Sites and Facilities
Modification of existing sites and facilities, and of operating procedures
to conform to the requirements of these regulations shall be accomplished.
When the degree of necessary improvement is of such extent that immediate
compliance cannot be accomplished, special consideration may be given
by the Agency. In such event, the owner of the nonconforming site or fa?
cility shall, not later than six months after the effective date of these regula-
tions, submit to the Agency a report setting forth a program and plan fof
compliance with these regulations. Included with this report shall be a time
schedule for submission of plans and specifications and a time schedule
requiring commencement and completion of construction of necessary opera-
tions or improvements. In any event such construction shall be completed
by not later than July 1, 1972.
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BULES AND REGULATIONS SW 11
SW 11 Exemptions and County Solid Waste Management System
The Agency will consider permitting annual exemptions, during a transi-
tion and planning period ending July 1, 1972, for the operation of existing
intermediate solid waste disposal sites, but only under the following circum-
stances:
(1) When a disposal operation serves a resident population of less than
1,000 people, open dumps may be operated under the following conditions:
(a) The permit is reviewed annually with particular regard to all aspects
of potential Hazard to public health and safety.
(b) At the site entrance is a permanent sign identifying the operation
and showing the permit number of the site, and indicating the hours and
days the site is open for public use, the penalty for non-conforming dump-
ing, that toxic and hazardous wastes may not be dumped therein, and other
pertinent information.
(c) No toxic or hazardous wastes, no domestic sewage, and no indus-
trial wastes are dumped at the site.
(d) The dump is at least V* mile from any residence or place of public
gathering.
(e) The dump is compacted and covered with earth at least 12 inches
in depth at least four times per year, or more often when directed by the
Agency.
(f) Animal carcasses and garbage are buried at least weekly.
(g) Adequate measures are taken to protect the surrounding area from
wind-blown debris, and from the spread of accidental fires from the dis-
posal site.
(h) Open burning of solid waste is prohibited except as otherwise pro-
vided by Agency Regulation APC 8.
(i) Arrangements have been made with a local fire-fighting department
to provide for immediate fire-fighting service in case of an emergency.
(j) That the dumping and disposal at such dump complies with Regu-
lation SW 6 Section (2) (b) and (2) (g).
(2) When the disposal operation serves a resident population of 1,000 to
2,500 people modified sanitary landfills may be operated under the following
conditions:
(a) The permit is reviewed annually with regard to potential hazard
to the public health and safety.
(b) The disposal operation is located at least V* mile from the nearest
residence or place of public gathering.
(c) Animal carcasses and garbage are buried daily.
(d) The fill area is compacted and covered with six inches of earth
weekly, on a regular schedule, or more frequently as may be required by
the Agency.
(e) Adequate measures are taken to protect the surrounding area from
wind-blown debris, and such materials are cleaned up promptly.
(0 Adequate measures are taken to protect the surrounding area from
the spread of accidental fires from the disposal area, and arrangements have
172
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aw 11 DIVISION OF SOLID WASTE
been made with a local fire-fighting department to provide for immediate
fire-fighting service in case of emergency.
(g) An insect and rodent control program is followed for protection
of the public health and safety.
(h) Open burning of solid waste is prohibited except as otherwise pro-
vided by Agency Regulation APC 8.
(i) At the site entrance is a permanent sign identifying the operation
and showing the .permit number of the site, and indicating the hours and
days the site*l$ open for public use, the penalty for non-conforming dump-
ing, and other'pertinent information.
(j) The disposal operation has a gate at the entrance.
(k) The road leading to the disposal site is all-weather construction.
(1) That the disposal of waste at such disposal site complies with Regu-
lation SW 6 Section (2) (b).
(3) On or before July 1, 1971 each county shall submit to the Agency a
workable preliminary plan for a solid waste management system within such
county. On or before July 1, 1972 each county shall submit for the approval
of the Agency a workable final plan for a solid waste management system
within such county. The plan shall be amended from time to time as chang-
ing conditions occur, by filing revisions for the approval of the Agency.
Such plans and revisions shall be adopted by the Board of Commissioners
of the county prior to filing with the Agency.
Each county shall provide for a solid waste management system plan to
serve all persons within the county. Two or more counties may elect to
submit a joint plan.
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RULES AND REGULATIONS SW 13
(Insert opposite page 32)
Sw 12 Solid Waste Land Disposal Site Abandonment
This regulation applies to all land disposal sites, including abandoned
dumps.
The person or persons (as defined in SW 1) having the responsibility for
the operation of the site must accomplish the closure of the site.
The closure of the site shall include the following procedures:
(1) Designate a substitute site or facility which has been approved by the
Agency and notify the media and the general public of the closing and of
the substitute site.
(2) Close access to the site and prohibit refuse disposal.
(3) Stop any burning.
(4) Eradicate rodents.
(5) Provide measures to protect underground and surface water.
(6) Divert surface water drainage around and away from the disposal
area.
(7) Compact refuse and cover with a minimum of two feet of compacted
earth material.
(8) Establish and maintain final grade to promote surface water runoff
without excessive erosion. Seed to provide suitable vegetation.
(9) Record a detailed description, including a plat, with the county
register of deeds. The description shall include general types and location
of wastes, depth of fill, and other information of interest to potential land
owners.
(10) An authorized official shall properly complete the disposal site
closure record and submit it to the Agency.
Filed with Secretary of State and Commissioner of Administration
September S6, 1973
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CASE STUDIES - MINNESOTA HAZARDOUS WASTE POLLUTION INCIDENTS
Improper storage, transportation, handling, treatment and disposal of haz-
ardous wastes has the potential of adversely affecting the public health and
the environment. Possible public health and environmental effects are:
e Danger From Improperly Handling of Hazardous Waste - Improper handling of
hazardous wa>ste can result in burns, fires, explosions, and poisonings.
These effects can occur at any stage of the generation-transportation-dis-
posal chain.
e Pollution of Water, Land and Air from Spills of Hazardous Waste in Transit-
Spills of hazardous waste can pollute the groundwater and surface water
systems. Likewise, spills can release noxious gases into the atmosphere
affecting public health and the environment. Accidental spills of hnzard-
ous waste can also harm plant and wildlife in the spill area.
« Pollution of Groundwater and Surface Water From the On-land Disposal of
Hazardous Waste - The clean-up of groundwater pollution presents a parti-
cularly difficult' problem for a number of reasons. Groundwater moves very
slowly, and the groundwater system has very little permanent waste assimi-
lative capacity. This means that once the contaminant enters the ground -
water system, the effects may be long lasting. Pollution of the ground-
water, system is often not detected until the damage is widespread. With
time, the exact location of land disposal sites can be forgotten and pos-
sible future adverse effects from the wastes may not be recognized nor
attributed to their actual source until serious damage has occurred. Grad-
ual leaching of hazardous materials into surface water systems can have
a chronic effect on public health through public water supply at. well as
a chronic effect on the environment.
0 Pollution of the Atmosphere From Incineration of Hazardous Waste- - Many
hazardous materials will release harmful w
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effect on public health as well as on vegetation and wildlife in the
area surrounding the facility.
Numerous case studies within Minnesota as well as nationwide document tV1
potential danger to the public health and to the environment from the improper
management of hazardous waste. The following case studies are examples:
(2)
PESTICIDE CONTAMINATION - MINNESOTA v ' . An arsenic pesticide was used
to control a grasshopp'er infestation near Perham, Minnesota in 1934. After rhc
infestation was under control, the unused pesticide was buried in an unmarked
shallow trench far from any urbanized areas. In 1972 a shallow well was installed
near the pesticide disposal area to serve as a water supply for a local consLruc-
tion company. Soon after the well was placed in service, thirteen employees
were stricken with what was later diagnosed to be arsenic poisoning. All of the
thirteen employees required medical treatment and two had to be hospitalized. One
employee was hospitalized for more than a month and still suffers from nerve
damage .
ON-LAND DISPOSAL OF INDUSTRIAL WASTES - MINNESOTAV . From the mid-501 s
until 1966, spent industrial solvents and acids were disposed in an on-land dis-
posal pit at a site in Woodbury Township. In May 1966 a private well near the
disposal site was found to be contaminated with one of the industrial solvents
being discharged into the on-land disposal pit. It had taken approximately 10
years for the pollution of the groundwater system to be discovered. It has been
a costly and difficult matter to pump out the aquifer and dispose of the contam-
inated groundwater.
IMPROPER HAZARDOUS WASTE HANDLING - MINNESOTA . An employee of a Dakota
County landfill was seriously burned when a piece of equipment he was operating
crushed and ignited a container of flammable solvent which had been illegally
deposited in the landfill. The employee suffered burns over 857» of his body and
was hospitalized in intensive care for four and one-half months.
CREOSOTE MANUFACTURE AND USE - MINNESOTA ^ . A creosote manufacturer and
a creosote user have been operating at the same site in a Minneapolis suburb
176
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for over 50 years. Over the years much of the 80 acre site has become satur-
ated with 'creos.ote and other petroleum products. In L932, complaints of a
"tarry" taste forced the abandonment of a municipal well. During the snme
period the use of a group1 of shallow private wells was discontinued due to
taste and odor problems. Investigation of the groundwater contamination could
find no other source responsible for the taste and odor than the creosoting
operations. Apparently, because other sources of drinking water were readily
available, no actions were taken to treat the source of the problem. According
to Pollution Control Agjency studies, if surface water, contaminated by creosote
«
saturated soils, are "continually allowed to reach the water table it is likely
that deeper wells and wella-at greater distances from the presently contaminated
area stand a chance of being contaminated. The Pollution Control Agency has
authorized legal action against the two creosoting operations. At the present
time studies are being undertaken to determine what renovative work will be nec-
essary before the companies terminate operations.
GASOLINE POLLUTION - MINNESOTA . It is hypothesized that prior to 1950
an accidental spill of gasoline took place near a large gasoline storage facility
north of St. Paul. During 1957, private wells in the area began to exhibit taste
and odors similar to gasoline. By 1958, the taste and odor had traveled to the
south and had contaminated a municipal well. A carbon filter was installed on
the well to extract hydrocarbons for laboratory analysis. Examination of the
filter media confirmed the presence of gasoline. Since it appeared that new
wells drilled in the area could become contaminated at a later date, the munici-
pality decided to connect to the St. Paul water supply system. Since 1958 more
wells have been contaminated by gasoline. At the present time the contamination
has traveled approximately 2 miles.
LIQUID CHEMICAL WASTE DISPOSAL - MINNESOTA. During 1972, approximately 97
barrels of liquid chemical wastes including oil and paint were deposited in a
shallow pit in Wright County. The barrels of waste were unlabeled and, accord-
in" to wjtnebses, some of the barrels were leaking liquid wastes onto the ground.
The liquid chemical waste was eventually transported to an incinerator for proper
di sposal.
SEPTIC AND HOLDING TANK DISPOSAL - MINNESOTA. In many portions of the study
177
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area, evidence exists that raw septic tank sludge is being placed into sani-
tary landfills. 'Solid waste administrators in Wright and Anoka Counties in-
dicated that such disposal was occurring in their respective counties Scav-
engers who haul septic tank sludge are also employed to pump out industrial
holding tanks which often contain hazardous waste. This represents a known
source of unregulated land disposal of hazardous waste.
Viol290
178
GPO 898-717
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